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EPA Compliance and MRL Verification

Risk Management for Food Importers and Exporters
Ned Halaby, Sales & Marketing Manager, Organic and Non-GMO Projectphone icon510.452.6822 Email
Farmer spraying crop field

Manage your risk and meet US EPA or country-of-destination maximum residue limits (MRLs) for pesticides by monitoring and testing your food products prior to shipment. Global consumer awareness, government surveillance, and enactment of FSMA (Food Safety Modernization Act) have made due diligence for pesticides, pathogens, and contaminants more important than ever before.

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Risks to Food Importers

Under the new FSMA Foreign Supplier Verification ruling, importers of record are now responsible for ensuring that their food suppliers meet US EPA pesticide residue tolerances and FDA food safety requirements.  Under FSMA, the FDA has increased surveillance of imported foods, and the process for gaining clearance from FDA detention is now more costly and time consuming than ever before.

Testing and Monitoring

SCS conducts random testing for pesticides, pathogenic bacteria, and industrial contaminants to demonstrate that your products and those of your suppliers meet labeling requirements set by the US EPA and FDA. In addition, we can set up monitoring programs for your operation prior to testing.

SCS uses FDA-approved methods for multi-residue screens, and provides customized tests for residues not detected by routine screens conducted by other testers. This gives you increased assurance prior to clearance. Our sampling and testing programs satisfy FDA mandatory testing requirements for imports from countries under block detention and for those under automatic detention due to previous violations.

Do You Need FDA Detention Clearance?

If you have been caught at the border and need fast help in crisis management for your shipments, call SCS for our expert FDA Detention Clearance services.

Export Compliance
Risks for Food Exporters

Maximum residue limits (MRLs) for pesticides in the European Union, Japan, Taiwan, Korea and Australia are more stringent than those of the US. Therefore, compliance with US regulations does not guarantee that your produce will meet the tolerances or pesticide registration requirements of these countries. Moreover, new pesticide registrations and changes in tolerances can affect the legality of your exports, resulting in rejected shipments or products bans from the exporting company.

SCS' Testing Expertise

SCS tests products for pesticide residues against the applicable MRLs (maximum residue limit) to ensure country-of-destination compliance. Our professional expertise and knowledge of pesticides and usage patterns allows us to target testing toward those classes of compounds likely to exceed acceptable levels. We regularly update our multi-residue testing methods to be able to detect newer generation pesticides as well as the pesticides targeted by export government agencies.

Target High-Risk Products

Start by testing your higher-value, higher-risk exports, such as:

  • Table grapes
  • Apples
  • Berries
  • Peaches and other stone fruits
  • Citrus
  • Nuts

SCS samplers can meet your shipment at the warehouse or other shipping location. Expedited service is available.

Pesticide Residue MRL Management

We offer a comprehensive seed-to-store MRL Management program for growers to help them establish new pesticide use procedures that meet multi-country MRLs and create an export plan to minimize risk.

How does the FSMA Foreign Supplier Verification ruling affect FDA import detention clearance?

Under the new FSMA Foreign Supplier Verification ruling, importers caught with products exceeding EPA pesticide tolerances must provide a Corrective and Preventative Action (CAPA) letter, plus five clean pesticide “entries” in order to file a petition to be removed from FDA detention. The CAPA letter defines prevention and controls for addressing the initial cause for detention, as well as a root cause analysis. This same FDA detention clearance process applies for products that have been detained for filth, heavy metals, non-approved food colorants, and food additives.

The FDA also now requires importers (also referred to as "foreign supplier") to have US agents, and to register as a food facility.

Are pesticides commonly found in food for sale?

Yes. US government testing, under the USDA Agricultural Marketing Service’s Pesticide Detection Program (AMS PDP), indicates that approximately 50% of all produce contains pesticide residues.  The actual level is probably higher, since these tests do not necessarily detect the pesticides that were used. Simply following label use guidelines on the pesticides you use will result in products that meet U.S. tolerances, but does not guarantee that you will meet the MRLs of other countries to which you or your distributors export.

Do pesticide residue tolerances differ between countries?

Yes. For example, the MRL for the pesticide, Captan, used on strawberries is 20 parts per million (ppm) in the US, 5 ppm in Canada, 3 ppm in the United Kingdom, and 0.01 ppm in Taiwan. Because the tolerance range is so broad for some commonly used pesticides, it is important to consider a Pesticide Use Plan in coordination with your expected countries of export. SCS can help prepare you for the next growing season with MRL Management.

United Kingdom

The MRL for agricultural residues in the UK is known as the UK Screen. SCS performs this screen for suppliers to retailers such as Marks & Spencer, Tesco and ASDA/Walmart. For produce consumed by children, the UK only allows 0.01 ppm on all pesticides.


Japan uses a "Positive List System" in which MRLs for 66 pesticides are supplemented with provisional MRLs for 472 additional pesticides. Violations of the thresholds can result in rejection of a shipment, and can be cause to ban the exporter from Japanese markets. SCS is recognized by the Japanese Ministry of Health Labor and Welfare to perform pesticide residue testing for exported food going to Japan.

SCS has the experience and knowledge of US pesticides and their use to test only those classes of compounds most likely to be present, saving you precious time and money.


SCS has worked with the National Toxics Lab in Taiwan to ensure that our testing methods and standards will detect all of the pesticides listed on its banned list.

Additional Countries

SCS has participated in round-robin testing programs with the Netherlands, North Korea, Canada, German, Australia and Norway to ensure that our testing methods and results are consistent with those of major US export countries.

How much would it cost if my shipment exceeded an MRL overseas?

Shippers whose products are detained at a border most likely will lose the full value of the product. In addition, you must pay the cost of shipment along with storage fees overseas while the complaint is processed, a fee to dispose of the product or re-export it, and potentially a violation fee. In short, thousands of dollars. In addition, the shipper is now "on detention," subject to additional monitoring and testing until multiple compliant shipments successfully cross the border.

What are the important steps for preventing product from being stopped at the border?

Gaining a fundamental understanding of the foreign policies governing pesticide use parameters and high-risk pesticides is necessary to guarantee distribution of your product overseas without hassle. Armed with this knowledge, growers can avoid certain pesticides and understand how to apply them in a way that doesn't put product at risk of being detained. SCS provides this knowledge through MRL Management services.

What are SCS' testing credentials?

SCS maintains relationships with and oversees testing by a diverse group of independent laboratories that are experienced in analyzing the full spectrum of pesticides. All of our partner labs are accredited by state and federal agencies and use testing methods and procedures that are well established and accepted by government, academic and industry groups. Labs must participate in:

  • The State of California Environmental laboratory Accreditation Program (ELAP)
  • The internationally recognized Food Analysis Performance Assessment Scheme (FAPAS)
  • The SCS “Split-Sample” program, in which SCS periodically sends split samples to multiple labs and monitors the results for accuracy and consistency.

For immediate service:

Ned Halaby, Sales & Marketing Manager, Organic and Non-GMO Project phone icon 510.452.6822 Email Ned