Dithiocarbamate MRL's - EU plan for review

26 Jul 2022

Mancozeb is a no longer authorised active substance in the EU. Mancozeb MRLs are covered under the established dithiocarbamates MRLs, which also include other active substances under renewal review. The group of active substances of dithiocarbamates comprises of: maneb, mancozeb, metiram, propineb, thiram and ziram. Dithiocarbamates have also a common residue definition expressed as carbon disulphide.

As stated by the European Commission, the MRLs cannot be lowered individually for mancozeb without impacting the other substances comprised in the group of dithiocarbamates. The group needs to be reviewed as a whole considering that some substances are still approved, other are no longer approved and there may be additional sources of carbon disulphide (i.e. natural occurrence for instance in broccoli). The process will be taking a bit longer than expected due to its complexity. Therefore the European Commission intends to initiate a collective review of dithiocarbamates MRLs based on procedure set under Article 12 of Regulation (EC) No 396/2005.

The latest overview (21 July 2022) of the MRL review progress under Article 12 of Regulation (EC) No 396/2005: https://www.efsa.europa.eu/sites/default/files/pesticides-MRL-review-progress-report.pdf.

According to this overview the launching date for the Article 12 for the group of dithiocarbamates will be initiated as follows:

Maneb:

• Start of data collection: 15/12/2020
• Adoption of Reason Opinion (expected date): 15/12/2022

Mancozeb:

• Start of data collection: 15/12/2020
• Adoption of Reason Opinion (expected date): 15/12/2022

Metiram:

• Start of data collection: 15/11/2020
• Adoption of Reason Opinion (expected date): 15/12/2022

Thiram:

• Publication of EFSA Opinion: HERE

Ziram:

• Start of data collection: 15/11/2020
• Adoption of Reason Opinion (expected date): 15/12/2022

The approximate timeframe between the start of data collection and expected date of adoption of Reasoned Opinion (RO) is 12 months, however the process for dithiacarbamate substances has been delayed. Once EFSA´s Opinions are published (The publication of an output is expected generally within 4 weeks from its adoption), this will be followed by a standard process which includes: discussions with the EU Member States, notification to the WTO, vote by the EU Member States, publication in the OJ of the EU and a grace period.