Maximum Residue Limit (MRL) requirements across the European market are undergoing significant changes, requiring Vietnamese enterprises—particularly within the fruit export sector—to proactively track evolving regulations and enforce strict controls right from cultivation zones.

The insights were shared by experts during an online workshop updating European Union policies and regulations on imports of plant- and animal-origin food and agricultural products, jointly organized on the afternoon of September 24 by the Embassy of Vietnam in Belgium / the Vietnamese Mission to the EU and the EU's AGRINFO Programme.

The EU reviews changes to MRL regulations

Speaking at the workshop, Chris Down, policy and legal expert at AGRINFO/EU, noted that the EU is deliberating potential shifts in its MRL framework, including narrowing or revoking import tolerances for certain active pesticide substances.

The EU currently maintains two distinct regulatory frameworks for plant protection products. One framework governs which active substances are approved for domestic use within the EU; the other establishes MRL thresholds on food and feed. Consequently, an active substance not authorized for use within the EU may still be utilized in a third country if the resulting product complies with an established EU import tolerance.

However, the EU is considering changing this approach for active substances identified as presenting high hazard profiles. Under proposals being debated, MRLs for certain active substances could be slashed to 0.01 mg/kg or the lowest analytically detectable level.

The final policy scope remains under discussion. The European Commission is focusing on high-hazard substance classes; several member states wish to broaden the scope to include substances presenting hazards to bees and groundwater resources; while the European Parliament is deliberating the potential application across all active substances not authorized within the EU.

According to Chris Down, the proposal remains in consultations among EU institutions. The European Commission plans to conduct an impact assessment, with a final regulation potentially adopted in 2027.

This development necessitates early preparation across Vietnam’s export sectors. According to the AGRINFO expert, over 90 active substances see MRL revisions annually, while standard transition periods span roughly six months. For perennial fruit crops or industries requiring substantial time to adjust agronomic protocols, this transition window is not always sufficient.

Consequently, enterprises cannot focus solely on whether a consignment exceeds thresholds at the time of export clearance, but must track anticipated changes in active substances, revised MRL thresholds, and enforcement timelines well ahead of implementation.

For Vietnam, it is imperative to audit the active substances currently used across core export sectors, especially those vulnerable to new policy directions. Alongside this, the industry must assess available alternatives, quantify pest management impacts, and evaluate the feasibility of sustaining production and export viability if specific active substances are phased out.

Dragon fruit and key fruit sectors under watch

Vietnam remains among the countries facing challenges in meeting EU MRL thresholds. Several Vietnamese commodities are already subject to enhanced official border controls. Among them, durian is placed under scrutiny for pesticide residues, while okra, dragon fruit, and peppers face heightened inspection frequency bands.

For product groups carrying assigned risk profiles, the EU may increase border inspection frequencies, physical sampling, and laboratory testing prior to customs clearance. This means residue control imperatives cannot fall solely on exporters at the shipment stage, but must be embedded directly in cultivation zones.

Notably, dragon fruit was spotlighted by experts during the session. Although Vietnam ranks as a leading dragon fruit exporter, risks tied to non-compliance with import mandates could drive the EU to diversify procurement toward alternative suppliers such as Ecuador, Mexico, and Thailand.

During the panel discussion, delegates raised specific inquiries regarding red-fleshed dragon fruit and whether Spanish authorities might treat this variety differently from dragon fruit historically exported to Europe.

According to experts, for novel products or commodities lacking export precedent into the European market, competent authorities may conduct pre-market safety reviews before access is granted. This represents an important consideration for distinctive Vietnamese agricultural specialties that lack documented export histories into the EU.

For distinctive varieties or specialties not exported to the EU prior to 1997 and not historically marketed there, businesses must determine whether the crop is explicitly scheduled under Annex I of Regulation (EC) No 396/2005. If omitted, standalone safety review or annex listing requests may arise.

In light of this, fruit sectors must track developments not only for dragon fruit, but across other specialized horticultural items, particularly those currently seeking to expand into the EU. Conducting early technical reviews will enable enterprises to avoid being caught unprepared when regulations adjust.

Experts recommend that industry bodies regularly monitor the Rapid Alert System for Food and Feed (RASFF), track MRL revisions, share sectoral intelligence, and liaise closely with regulatory authorities whenever risk indicators emerge.

More critically, residue governance must be shifted back to primary production rather than relying on testing right before shipping. For active substances vital to key export crops, stakeholders must determine degrees of chemical dependency, assess substitute feasibility, and model agronomic impacts should an ingredient lose its approval.

According to Chris Down, export enterprises should establish systematic monitoring protocols, swiftly capture regulatory updates, and configure early-warning mechanisms against emerging risks.

Adding to the discussion, Tran Van Cong, Agricultural Counselor at the Vietnamese Mission to the EU, underscored that market headroom remains immense. Citing trade data, he noted that the EU imports roughly USD 65 billion worth of fruits and vegetables annually—including about USD 35 billion from extra-EU sources—yet Vietnam currently accounts for only around USD 500 million in produce shipments to the bloc.

While the EU–Vietnam Free Trade Agreement (EVFTA) confers substantial tariff preferences, preferential duties serve merely as an initial entry facilitator. To defend market share, Cong emphasized that enterprises must satisfy escalating technical sanitary and phytosanitary hurdles. Among these, MRL compliance has evolved into a structural challenge that cannot be resolved through a single pre-export testing step.

Source: Vnbusiness