The negotiating mandate could lower limits for selected hazardous substances to laboratory quantification levels. No new bloc-wide limit has taken effect, but African export sectors may face increased testing, traceability and crop-protection demands.
EU – European Union member states have agreed a negotiating position that would allow pesticide residue limits for some imported food and feed products to be lowered to “technical zero”.
The Council adopted its mandate on 30 September 2026 as part of the EU’s Food and Feed Safety Simplification Package, known as Omnibus X. It covers pesticides that are not approved for use in the EU because of specified health or environmental hazards.
Under the mandate, maximum residue levels established using Codex limits or good agricultural practices in exporting countries could be withdrawn and replaced with the applicable limit of quantification after an impact assessment.
The Council also widened the proposed scope. In addition to substances with carcinogenic, mutagenic, reproductive, endocrine-disrupting, persistent or bioaccumulative properties, it would cover substances whose conditions of use create unacceptable risks for honeybees or groundwater.
What “technical zero” means
A maximum residue level, or MRL, is the highest concentration of a pesticide residue legally permitted in or on a food or feed product.
Technical zero does not mean that every molecule must be absent. The Council text defines the limit of quantification as the lowest residue concentration that can be reliably quantified and reported through routine monitoring using a validated method.
The practical result is that a residue which complies with an existing MRL could become non-compliant if the limit for that pesticide and commodity is lowered to the quantification threshold.
This is also an important food-safety distinction. The proposal is not a response to an outbreak, recall or finding that every product complying with existing MRLs is unsafe. It would add hazard, environmental protection and production-standard considerations to decisions that currently place strong emphasis on consumer exposure and risk.
The rules have not changed yet
The Council decision is a negotiating mandate, not final legislation.
As of 2 October, the European Parliament’s procedure file remained at the “awaiting committee decision” stage. Parliament must adopt its position before negotiations with the Council can begin, and the final wording may change during those talks. The Council presidency wants a provisional agreement before the end of 2026.
If the Council approach survives, individual MRL changes would still require prior assessment and a separate regulatory decision. The mandate would require the European Commission to submit the assessment results and, where appropriate, a draft regulation within six months of the relevant substance evaluation or expiry of its regulatory grace period.
The text also allows transitional provisions for products that complied with the earlier MRL when they were placed on the market or put into storage, including storage outside the EU for sale into the bloc. Operators would carry the burden of proving when the products entered storage.
The import-residue provision applies to food and feed. It should not be presented as a ban on African cut flowers, although separate provisions in the wider Omnibus package concern approvals for plant-protection products.
What the JRC study says about exporter exposure
An analysis published by the European Commission’s Joint Research Centre on 11 August examined 18 active substances with existing MRLs above the quantification limit. It mapped 235 commodities and 86 exporting countries.
The study modelled a 41 per cent reduction in total EU agricultural imports under an extreme scenario in which all affected trade stopped and exporters made no adjustments. The decline fell to 8 per cent under an intermediate scenario and 0.4 per cent where exposure and adaptation costs were lower.
These figures are not forecasts. The JRC described them as bounds around possible outcomes and said results depend heavily on whether exporters use the substances, have suitable alternatives and can change production practices. It also stressed that its work was not a complete impact assessment and did not cover social or environmental effects.
For commodities not fully represented in its economic model, the study identified Morocco, Benin, Cameroon and Senegal among countries with substantial dependence on the EU for affected exports. South Africa, Côte d’Ivoire and Tunisia were among African countries with significant export value potentially exposed.
The underlying screening also referred to Egypt, Kenya and Uganda among African countries for which the researchers found combinations of residue detections and pesticide-authorisation information.
That does not establish that all listed substances are currently used on EU-bound crops. A pesticide registration does not prove use on a particular commodity, while a detected residue is not necessarily an MRL violation. The JRC also cautioned that part of its authorisation dataset was extracted in February 2026 and might not reflect the current regulatory position.
The 18 substances examined by the JRC should therefore not be treated as a final compliance list. Its analysis preceded the Council’s expansion of the proposed rules to include certain honeybee and groundwater risks.
Kenya’s control system is already under scrutiny
Kenya underwent a European Commission audit from 15 to 23 June 2026 covering official controls on pesticide residues in foods of plant origin exported to the EU.
KEPHIS said the audit examined legislation, coordination between authorities, residue-monitoring programmes, laboratory capability, traceability, enforcement, training and engagement with food businesses. Its public notice did not provide the audit’s final findings, and KEPHIS has since told TPI that it has not yet received the audit report.
However, a separate domestic audit has already identified weaknesses in parts of Kenya’s pesticide-control system. The Office of the Auditor-General’s Performance Audit Report on Regulation of Pesticides in Kenya, examined the Pest Control Products Board’s operations from the 2021/22 financial year to March 2026.
The report found that PCPB’s residue testing covered only kales, onions, tomatoes and potatoes across 12 of Kenya’s 47 counties. It conducted no pesticide-residue analysis on water or soil. One onion sample exceeded the applicable Codex maximum residue limit, but the absence of a formal traceability system meant that the supplier or farmer could not be identified and the consignment could not be recalled.
As of March 2026, PCPB’s residue laboratory was still pursuing ISO/IEC 17025 accreditation. The audit also found that monitoring data collected by KEPHIS under its National Pesticide Residue Monitoring Programme had not been shared with PCPB despite requests, limiting the Board’s access to evidence for regulatory decisions.
PCPB responded that KEPHIS regularly communicates information about individual export interceptions and that a National Pesticide Residue Monitoring Framework was being developed. The Auditor-General maintained that the framework remained a draft and recommended a formal data-sharing mechanism between the two agencies.
These domestic findings should not be presented as conclusions from the European Commission audit. PCPB’s mandate covers pesticide products and domestic post-registration surveillance, while KEPHIS oversees export certification and related residue controls. The findings nevertheless point to monitoring, laboratory, traceability and coordination gaps that could become more consequential under stricter EU residue requirements.
Earlier in the year, ACTESA, through the COMESA–EAC Horticulture Accelerator, advised regional exporters to maintain crop-specific pesticide lists, verifiable spray records, risk-based sampling, laboratory testing and shipment-level traceability files as EU import controls intensified.
The Council mandate makes those controls more significant, particularly if laboratories must demonstrate compliance at very low, substance-specific quantification limits.