Glyphosate-free, zero residues, values and rules

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Increasing consumer attention to glyphosateandother pesticides is leading some operators to consider using–on food labels–statements such as ‘
residues

zero
‘, ‘
glyphosate-free
‘, ‘
without

glyphosate
‘. What values do such statements express, and what rules are they subject to?

Glyphosate and pesticides, process certifications vs. product certifications

The supply chain of the biological is the only one to ensure compliance ‘from the farm to the fork‘ of a uniform system of rules EU-wide. This system precisely defines the criteria to be followed throughout the ‘supply-chain’ (in agriculture and animal husbandry, processing, logistics and distribution), certification protocols and control methods.




The logic and ethics



that preside over ‘


bio

‘ They express the utmost respect for the biosphere. To contribute to a

common good


, the health of the environment (biodiversity, soils, water, air), human populations
and animals. Bringing value that affects the entire community, and not just individual operators rather than consumers of individual products. According to an approach that simultaneously realizessupply chain integrity
and the CSV (




Contributing to Social Values




)

.

Statements such as. glyphosate-freeo ‘zero residuals‘, ‘zero pesticides, vice versa, do not mean whichfoods so marked are derived from an organic supply chain. Nor are they worth excluding, per se, the use of chemical pesticides and fertilizers in agriculture. Unless the products in question are also certified ‘organic’. Such endorsements simply attest that the final products do not contain residues of thespecified substances. In an individualistic and competitive logic, which by analogy to NIMBY (
Not in My Back Yard
) – as with the EU-made Paraquat – could inspire the neologism NIMF(
Not in My Food
).



Zero residuals


‘, ‘


glyphosate-free


‘, ‘ rules

and responsibilities


The claim ‘zero residues’ or other similar claims
, on labels and/or advertising, are within the scope of voluntary food information. And are therefore subject, in the absence of specific regulation, to the general criteria set forth below. (1)


A) Veracity and

demonstrability

à
of the news. In this case, the operator must follow a protocol of laboratory sampling and analysis, recording the relevant documents to be made available to control authorities and
stakeholders
. (2)


B) Transparency
, meaning clarity for the average consumer and non-ambiguity of information. This entails, for operators, a number of dutiful attentions:

– it first needs to be clarified whether the data refer only to the absence of detectable traces of pesticides in individual batches of the foods on offer. That is, whether the attestation covers the entire production process,

– the methods followed (sampling, analysis and their performers) should be indicated. Offering details of this on the organization’s website, which is referenced through links and QR codes on the label,

– it is also recommended, to more structured operators at the very least, to use third-party certification with the support of an accredited body (Accredia),

C) Non-deception. It is essential to keep in mind the general principles that guard the accuracy of information. These principles can be summarized in a few essential prohibitions:

– Ban on attributing or even suggesting nutritional virtues or health claims-referring to the food, its ingredients or categories of products-outside those only claims authorized under ‘Nutrition & Health Claims‘ (NHC),(3)

– prohibition against ‘
suggest that the

food possesses special characteristics, when in fact

à

all similar foods possess the same characteristics
‘. (4)



Zero residue


‘, ‘


pesticide-free


‘, ‘ what substances?

I
he database

European

on pesticides
covers 488 metabolites, some of which are not allowed above the so-called ‘technical zero’. (5) Generic indications such as ‘
Zero residuals
‘ o ‘
pesticide-free
‘, when referring to the product, therefore postulate an analytical investigation of extraordinary breadth and cost.


From a logical and procedural point of view.
, it is therefore necessary to define the metabolites of interest. Considering, for example, the plant protection agents/metabolites generally used in the reference crop and those that go in rotation with it. In addition to any environmentally derived metabolites (background contamination) that should still be monitored, all the more so in conjunction with promiscuous facilities.


From the analytical point of view
, the most realistic survey options can be traced back to the monitoring of:

– all metabolites considered at the EU level on the cultures of interest, applying analytical sampling protocols according to practices of accredited laboratories. Eventually,if the supply chain is exclusively Italian, I would excludemetabolites that derive from plant protection products not allowed on domestic soil,

– the only metabolites of which it is intended to ensure a lower level than the legal limits, i.e., absence (e.g. ‘
glyphosate-free
‘).


From an operational point of view.
, a pilot phase of multi-metabolite monitoring needs to be carried out to verify theability tomaintain the promised results over time, across crops, throughout the production chain. Verify the relevance of the processing process, so as to prevent cross-contamination, and demonstrate appropriate professional diligence in each case and maintain a declaratory on GMP applied in the establishment, similar to that provided in organic establishments. Third-party certification is therefore necessary but not sufficient, as a broader product-process veracity must first be observed.




La






chemical safety






of foods


must come at all times and in all cases guaranteed. With special attention to mycotoxins and other contaminants of relevance to food safety and public health. (5)





Zero residues



‘, what consumer information?



Consumer information
must be clear and circumstantial. The wording ‘
zero

residues
‘ should in no way suggest an absolute, generalized promise, since the range of metabolites that can be monitored is ultimately limited. The claim must include an accurate description of its meaning, with brief explanation on the label – e.g. ‘
zero residues – tested to technical zero for the most common phytosanitary residues in the…
‘ – and referral to the website for technical and scientific details.

The boast without residueis thus finally revealed as a ‘free from claim‘. That is, that category of voluntary news items designed to communicate the absence of a particular ingredient, nutrient or substance within the food. A tool for


marketing



proven effective in confirming to the consumer adherence to certain values, which are expressed through the refusal to use unsustainable raw materials, such as bloody palm oil
. Or to unnatural substances, such as GMOs and chemical additives.

Dario Dongo

Notes

  1. See reg.EU 1169/11, articles 7 and 36. Consider also Directive 2005/29/EC on commercialisle practices, which has been implemented in Italy by means of the Consumer Code(Legislative Decree 206/05) and Legislative Decree. 145/07

  2. It is worth mentioning, for this purpose, the distribution’s responsibility in verifying the effective compliance of its suppliers with the applicable rules. When even the information is offered on IDM (Brand Industry) products, or otherwise to brands referable to the supply chain. See previous article



    https://www.greatitalianfoodtrade.it/etichette/responsabilit À








    à








    -of-distributor-appearances



  3. Cf. reg. EC 1924/06, reg. EU 432/12 as amended

  4. V. reg. EU 1169/11, Article 7.1.c




  5. European Pesticides Database



    ,






    http://ec.europa.eu/food/plant/pesticides/eu-pesticides-database/public/?event=activesubstance.selection&language=EN





  6. V. reg. EC 1881/06, ‘Defining maximum levels of certain contaminants in food products‘. Consolidated text on https://eur-lex.europa.eu/search.html?DTN=1881&SUBDOM_INIT=CONSLEG&DTS_DOM=EU_LAW&type=advanced&DTS_SUBDOM=CONSLEG&lang=en&qid=1541865890139&DTA=2006&locale=it

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Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.