August 17, 2004

1. All Grape Exporters/Farmers
2. All Grape Growers’ Federations
3. Maharashtra Rajya Draksha Bagaitdar Sangh, Pune
4. Fruit & Vegetable Association, Mumbai
5. All nominated laboratories
6. Director, National Research Centre for Grapes, Pune
7. All concerned Agriculture/Horticulture Officers – AP, Karnataka & Maharashtra
8. All PSC issuing Authorities – AP, Karnataka & Maharashtra
9. Commissioner, Horticulture, Govt. of Andhra Pradesh
10. Secretary, Agriculture, Govt. of Karnataka
11. Commissioner, Agriculture, Govt. of Maharashtra
12. Director, Agriculture – Andhra Pradesh, Karnataka & Maharashtra
13. Agriculture Marketing Adviser, DMI, New Delhi
14. All regional Agmark offices – AP, Karnataka, Maharashtra
15. APEDA Regional offices – Bangalore, Hyderabad & Mumbai

Sub: “Regulation of export of fresh grapes to the European Union through control of pesticide residues” for the year 2004 – 05

Dear Sirs,

You might recall that the 2003 grape season saw a number of rapid alert notifications from the European Commission on account of pesticide residues in excess of the MRLs prescribed by them. This led to a complete modification of the residue monitoring document in the form of a regulation to control pesticide residues in grapes exported to the European Union. A number of other steps were also taken, such as, upgradation of laboratories, setting up of the National Referral Laboratory, training of farmers/exporters/analysts etc. Resultantly, during the 2004 grape season, no rapid alert notifications were received from the European Commission (except one, which was also a wrong notification). This was possible essentially because of seriousness shown by all the exporters, farmers, laboratories and State Govt. officials and a lot of teamwork that was put in by all concerned, all of whom deserve to be complimented and congratulated for the excellent performance. However, while there were no EU complaints about residues, there were a number of quality complaints, which were received from importers.

With a view to further improve upon the residue monitoring regulation and to ensure that during the 2005 grape season, India is able to assure supply of MRL complaint good quality and properly graded grapes, meetings were held with all the stakeholders on 17th May and 29th July, 2004 at Pune. Minutes of both the meetings were circulated to all concerned. As discussed in both these meetings and after giving due consideration to the views of all the exporters, importers, farmers, laboratories, State Govt. officials, NRC – Pune as well as the requirements specified by the European Commission team that visited India in February, 2004, APEDA has revised the residue monitoring regulation and a copy of the same as it stands revised on 16th August, 2004 is enclosed herewith for strict compliance.

Since, there are a number of changes under each section of the main write-up of the regulation as well as the annexures, it is recommended that you must go through the document carefully for compliance. With a view to explain the document further, it is proposed to organize awareness meetings with all concerned at Pune, Nasik, Sangli, Sholapur, Bangalore, Belgaum, Hyderabad, etc. It is also proposed to have separate meetings with concerned officials of the Govts. of Andhra Pradesh, Karnataka and Maharashtra to discuss the role of the agriculture/horticulture officers and the phyto-sanitary certificate issuing authorities.

The following decisions taken during the last grape season would continue :

1. In respect of export of fresh grapes to non-EU countries, phyto sanitary certificates can be issued by all PSC authorities designated by Ministry of Agriculture, Govt. of India as well as the State Govts. However, in such cases, it would be necessary for the PSC issuing authorities to make an endorsement on the certificate and certificate of origin that the consignment for which the PSC has been issued will not be re-exported to the European Union. To enable the PSC issuing authorities to make the necessary endorsement on the PSC and certificate of origin, the exporters should submit a declaration as may be required by the PSC issuing authorities.

2. In case, an exporter or farmer wishes to send grape samples to a laboratory abroad for the purposes of additional testing, the PSC issuing authorities listed in Annexure – 16 may issue the phyto sanitary certificate without the need for production of the documents listed in para 7.1 of the regulation, provided the quantity of the grape sample does not exceed 10 kg per plot per farm registration, and, further provided that the exporter/farmer submits a declaration stating the following :

a) The sample(s) is/are for the purposes of pesticide residue analysis,
b) The sample(s) is/are `not for human consumption’, and
c) The sample(s) is/are of no commercial value.

This relaxation for residue analysis abroad is made without prejudice to the procedure, stated in the said document, required to be followed for commercial consignments of grapes to the EU countries.

Yours faithfully,

S. Dave

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