Northwest Horticultural Council
Thailand Implements New Rules to Test Imported Fresh Produce For Pesticide Residues
June 11, 2020
Current Situation: The Thai Food and Drug Administration (FDA) has issued new guidelines to test imported fresh produce for pesticide residues. The measures that were to be implanted on June 15 have been postponed until August 1, 2020, in part to the efforts of the Northwest Horticultural Council (NHC). The Thai FDA classifies imported produce based on their risk levels into three classifications: Very High Risk; High Risk; and Low Risk.
The Thai FDA considers cherries to be “High-Risk*”; there is a focus on residues of fenpropathrin (Danitol 2.4EC) due to prior non-compliance findings. If the shipment is found to be noncompliant with the regulation, the Thai FDA will place the exporter’s name, and type of product (for example sweet cherry), on a “Very High Risk” list. To learn more see the U.S. Department of Agriculture (USDA) Foreign Agriculture Service (FAS) GAIN report here.
- Exporters whose names are on the “Very High Risk” list will have cherry shipments held and tested by the Thai FDA, using a default value of 0.05 ppm for fenpropathrin.
Apples and pears are classified as Low Risk.
- Thai FDA announced the new maximum residue limit (MRL) testing guideline on May 20, 2020, and revised the implementation date on June 2.
- A Thai FDA officer at the port of entry will take a sample from every shipment in the “High-Risk” group (sweet cherry) to be tested at a government laboratory. The Thai FDA will be responsible for the lab testing expense.
- If the importer does not want the shipment to be tested in Thailand, the importer must present a Certificate of Analysis (COA) for every shipment. The COA must be issued by a government laboratory of the exporting country, a government-assigned lab, or a private laboratory complying with ISO/IEC 17025 can be used (see footnote).
- A COA is required for 134 pesticide substances for any non-compliant exporter with the specific products listed in the GAIN report. (see footnote)
- A non-compliant sample will place the exporter on the “Very High Risk” list.
- If three consecutive shipments are compliant with the regulation, then the product from the specific exporter will be removed from the close monitoring list. The exporter, or importer, must notify the Thai FDA that they wish to be delisted before testing of the three consecutive shipments to qualify. To learn more, see the USDA FAS Gain report here.
- Shipments received from an exporter listed as “Very High Risk,” face greater scrutiny for testing of their product, e.g., fenpropathrin residues:
- The importers are responsible for the lab testing expense.
- The shipment will be detained while waiting for the test results.
- The Thai FDA will consider whether the shipment must be kept at the port or can be moved to the importers’ warehouse with the importer’s signed letter of intent.
- If the result is negative, the shipment will be released. Otherwise, the shipment will not be allowed to enter the country.
- Exporters on the “Very High Risk” list can keep exporting fresh produce to Thailand by supplying a COA for each shipment with the understanding it will be tested and detained upon arrival. This method does not delist the exporter’s name.
*High-Risk fresh fruits are cherries, oranges, strawberry, grapes, and dragon fruit.
Note: The USDA FAS is in discussions with the Thai FDA about the pesticide list and the need for all 134 to be tested for each shipment.