On 24 and 25 Apr 2018, an official training course on developing national pesticide MRL standard was held in Jiangsu. The event was organized by MoARR and was attended by ICAMA’s head agronomist Ms. Ji Ying. Ms. Ji revealed that the new version of GB2763 will be published this year and that a technical guidance on MRL establishment targeting imported agricultural products would also be drafted.

Pesticide MRL establishment not only protects the integrity of the food supply, but also protects domestic agriculture. China’s response to WTO TBT/SPS notifications varies depending on the impact on trade balance, the value of the commodity, existence of established MRLs and China’s overall trade relationship with the notifying country. Member countries are required to notify other countries of any new or revised regulations which affect trade and to set up offices (official enquiry points) to answer requests for more information on new or existing measures at the WTH level. In regards to pesticide, TBT includes pesticide/chemical registration regulations and measures concerning food safety, production, environmental and labeling, etc., while SPS is more on MRL establishment/amendment/exemption/cancellation, crop grouping and other agricultural or technical practice for pesticide uses. China participated in the WTO TBT/SPS notification activities as early as 2003 and has formed a mature response system to support international trade of agricultural products, protect its domestic agricultural production and consumers. Through the introduction of official comment on MRL notification and studies of recent cases, this article aims to demystify how these WTO MRL notifications impact China's national pesticide MRL establishment. Workflow of Official Comments In the last 2 years, China has made very few WTO notifications on new enactment or amendment of pesticide regulations and the majority of these notifications involved establishment, amendment or cancellation of pesticide MRLs. An official inquiry point was established at the National Quality Standardization Center of Agricultural Product under the MoARA (Ministry of Agricultural and Rural Affair), receiving notifications from 19 countries/regions including the US, EU, Brazil, Canada and New Zealand etc. Each notification will be sent to relevant government body/institutions cover

By the end of 2017, 37888 pesticides registered by 2213 companies were within their validity, of which 3913 pesticides of 1216 companies were newly approved in the past several years. China promulgated a new pesticide regulation and revoked temporary registration. Applications which were being processed at the time of promulgation of the new regulation are still being reviewed and approved based on requirements of the previous regulation: 3365 were full registration for field use, 385 were temporary registration for field use, 153 were full registration for hygienic pesticide and 10 were temporary registration for hygienic pesticide.

On 10 Jan 2018, China MoA’s website released announcement 2622 to promulgate 87 agricultural standards which became effective on 1st of Jan 2018. Among them, 21 standards are for the regulatory studies required during registration of pesticides and fertilizers.

Since the Nov 1st 2017 implementation of  "MoA Announcement 2569-Data Requirements on Pesticide Registration", subsequent registration applications have been subject to increased data requirements and elevated criteria. Other changes include but not limited to the abolishment of temporary registration and mandatory risk assessment. Compared with the previous regulation, MoA Order 10 of 2008, Announcement 2569 includes significant improvements in text structure and information transparency. A comparative analysis between the new and old version offers useful information to aid companies in adapting to new requirements. Chapter Reorganization in Regulation Text In the 2008 version, hygienic pesticides, rodenticides, biochemical pesticides, microbial pesticides, botanical pesticides, GMOs and natural enemy pesticides are defined as special pesticides and their registration requirements were incorporated in an independent chapter similar to the individual chapters  detailing requirements of new active ingredients, new formulated pesticides, me-too and technical concentrations(TKs). In the main body, each of these chapters consists of 3 sub-chapters, corresponding to the requirements for field trial application, temporary registration and full registration. In the new data requirements, three types of biopesticide have equal chapter allocation as chemical pesticides. The requirements for manufacturing “use product” (TC/TK) and end-use product (formulation) are respectively compiled in 2 sub-chapters.  Furthermore,  “atypical” products including agricultural GMOs and natural enemies have been removed from the new data requirements. GMOS are regulated under agricultural GMO regulations and natural enemies are subject to significantly decreased registration data requirements. Conditions for post registration including use scope expansion, amendment to application method and dose are refined in Chapter VI

On 25 Dec 2017, China MOA and MEP jointly solicited public comments on a draft of “Administration Measures for the Recycling and Disposal of Pesticide Packaging Waste”. The draft defines the obligation and requirements on the collection, transportation, transfer, storage and disposal of pesticide packaging waste. The expense will be borne by pesticide producers and dealers.

On 17 Nov 2017, the Chinese State Council's Legislative Affairs Office released the draft of “Regulation for the Prevention and Management of Agricultural Pests” and will solicit public comments until 17 Dec 2017. The draft was compiled by the MoA and clarifies the responsibilities of government departments at all levels and entities engaged in agricultural production and pest control service, as well as standardizes the practices of pest monitoring, forecast, prevention and control.

Dozens of Shandong pesticide producers have already been ordered to halt operations starting from 15 Nov 2017 to 15 Mar 2018. Moreover, Jilin, Sichuan and Henan provinces have also joined the campaign meaning 34 cities in 8 provinces are now affected. In these regions there are hundreds of pesticide and intermediate producers in various scales so we can expect high prices to continue throughout next year.

On 10 Nov 2017, China ICAMA opened a 30-day consultation on the “Guideline on Pesticide Residue Trials on Crop”. As a vital component of pesticide management, residue trial provides scientific justification for MRL development and good agricultural practice for pesticide application, which is of great significance in ensuring food safety.

On 17 Oct 2017, China MoA disclosed the expert panelists nominated for the forthcoming 9th National Committee on Pesticide Registration for public consultation until 31 Oct 2017.