4 July 2012
Mr. Michael Flüh
Head of Unit Chemicals, contaminants, pesticides – E3
EU Commission DG SANCO
B-1049 Brussels
Request EU temporary MRL for Quaternary Ammonium Compounds
Dear Mr. Flüh,
In recent weeks an issue regarding the presence of quaternary ammonium compounds (QAC)
on fruit and vegetables has emerged and led to considerable disruptions in the trade.
Labs have detected Didecyl Dimethyl Ammonium Chloride (DDAC) and Alkyl Dimethyl
Benzalkonium Chloride (ADBAC) in various fruit and vegetables both from third countries and
Europe, as well as on organic products. These compounds are mainly used as biocides
(disinfectant/cleaning agent) but in some countries also as pesticides (foliar spray, dip
application), in certain cases they are also used as co-formulants.
Whereas the strict regulatory status regarding residues is clear, Regulation (EC) No 396/2005
EU provides the default MRLs of 0,01 ppm for both DDAC and the QAC-family in general, the
extensive presence of unintentional residues on a variety of foodstuffs requires an urgent
temporary solution pending the investigation of the exact causes for the contamination
sources.
Monitoring data from our members, which are enclosed, suggest residues up to 0,5 ppm both
for DDAC and ADBAC which cannot be linked to the direct use of QACs as pesticides. Crosscontamination from the use of biocides in food areas and washing water as well as from the
use of co-formulants in biostimulants have thus far been identified as major causes for the
unintentional QAC residues. Based on the toxicological information available in the registration
reports from the US Environmental Protection Agency (ADBAC, DDAC) and a preliminary risk
assessment by the German institute for risk assessment BfR, the observed residue levels are
not likely to represent any danger to consumer health.
Our members have been extensively informed on the issue and were asked to investigate the
use of QACs in their supply chain and where possible immediately discontinue any further use
of products containing QACs. The results from these actions will however take time and
meanwhile produce will continue to be harvested or delivered. Furthermore cost-effective and
efficient alternatives need to be available to ensure continued good hygiene practices.
In this light, we request an action limit of 0,5 ppm to replace the present default MRL of 0,01
ppm for both DDAC and QAC pending the setting of a temporary MRL. Such a level would only
cover unintentional QAC residues and would exclude post-harvest treatments which result in
higher residue levels. This solution would provide the industry enough time to further
investigate the exact causes of cross-contamination and discontinue any non-essential uses
throughout the supply chain. Monitoring data would be assembled to assess the required level
of a temporary MRL. Given cross-contamination was identified as a major cause, the
temporary MRL would need to apply for all fresh fruit and vegetables.
Rue de Trèves 49-51, bte 8 - 1040 Brussels - Belgium Tel: +32 (0)2 777 15 80 Fax: +32 (0)2 777 15 81
e-mail: [email protected] - www.freshfel.org - www.freshquality.org - www.freshcongress.com - www.enjoyfresh.eu
Considering the ongoing trade disruptions accompanied with the destruction of perfectly safe
food, we request the Standing Committee on the Food Chain and Animal Health to take action
at the earliest.
With best regards,
Frédéric Rosseneu
Director Food Quality & Sustainability
Rue de Trèves 49-51, bte 8 - 1040 Brussels - Belgium Tel: +32 (0)2 777 15 80 Fax: +32 (0)2 777 15 81
e-mail: [email protected] - www.freshfel.org - www.freshquality.org - www.freshcongress.com - www.enjoyfresh.eu
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