Banned in Europe, allowed in imports. Can lower pesticide residue limits close the gap?

Key messages:

• Lowering Maximum Residue Levels (MRL) to the Limit of Quantification (LOQ) targets a subset of substances whose MRL is still above the LOQ. In 2019, these uses accounted for between 3 and 6.5% of the pesticide footprint of EU consumption of maize, soybean and wheat, and for 12% of pesticide spending on these crops in Mercosur and about 3% in other exporting regions.
• Many banned substances used on crops imported into the EU feature an MRL already at the LOQ, but they are still used. A maximum residue level does not contain the upstream use of phytosanitary products.
• The Omnibus proposal targets a subset of banned substances meeting the hazard cut-off criteria. Substances banned only for their acute toxicity or their harm to pollinators fall outside its scope.
• In our simulations, the measure has small effects on trade and raises EU consumer prices by at most 0.5% (for soybean; about 0.1% for maize and wheat). Larger effects arise only in a stress test in which the measure cuts the use of hard-to-replace substances by 90%. Exporters then use more of the other pesticides, and the pesticide footprint of EU consumption rises by 7 to 8% under the acute oral LD50 for mammals and the Harmonised Pesticide Load Indicator weights.
• At best, bringing MRLs to the LOQ has a modest impact on trade and on the footprint of these crops. At worst, when it does constrain application rates abroad, it comes at important inefficiency costs, increasing the use of non-targeted substances, potentially increasing the toxicity footprint it was meant to reduce. An instrument based on the overall pesticide load of imports would not face this trade-off (Gaigné et al., 2026).