On January 15, 2025, Thailand launched a public consultation for the draft of MOPH Notification Food with Toxic Residues (No. 5), which aims to amend MOPH Notification (No. 387) B.E.2560 (2017) Re: Food Containing Pesticide Residues. Feedbacks can be sent to [email protected] before March 17, 2025.
Background
Since the release of MOPH Regulation No. 387 in 2017, three subsequent amendments have been issued, each introducing various piecemeal changes. The current draft establishes new and more comprehensive regulations to replace the three core annexes of MOPH Regulation No. 387, namely Annexes 2, 3, and 4.
Proposed Changes
Annex 2 Maximum Residue Limit (MRL)
The latest revised Annex 2 sets the MRLs for 55 pesticides in multiple food commodities such as fruits, vegetables, meat and milk. The new proposed Annex 2 contains the MRLs for 88 pesticides in food commodities. Additionally, under the current regulations, for MRLs not specified in Annex 2, compliance with international standards such as Codex is required. The draft further stipulates that for MRLs not covered by Codex, adherence to ASEAN standards is necessary.
Annex 3 Default Limits
The proposed Annex 3 sets default limits for 17 pesticides in plant products, same as the current version. However, item (3) carbosulfan from the current version was removed, and item (7) tradimenol or triadimefon was split into two items in the draft. Besides, the draft newly adds the limits for four pesticides in animal products.
Annex 4 Extraneous Maximum Residue Limit (EMRL)
The major change in Annex 4 is the layout of EMRL table. In the original table, the focus was on the food commodities, listing the residue levels of five chemical substances in each commodity. The new table, however, centers on six chemical substances (with the addition of lindane), detailing the residue levels of each substance across different commodities. Additionally, similar to Annex 2, in the absence of Codex standards, compliance with ASEAN standards is also required.
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