Residues and Trade
Risk Assessment Capability
Australian Pesticides and Veterinary Medicines Authority
Via email: ua.vog.amvpa@seiriuqne
RE: Trade Advice Notice on glyphosate in the product Roundup Ultra Max
Herbicide for use on barley
To Whom it May Concern,
Grain Growers Limited (GrainGrowers) welcomes the opportunity to provide
comment on the proposed use of glyphosate in the product Roundup Ultra Max
Herbicide for use on barley (except malting barley).
GrainGrowers is a leading voice for Australian grain farmers, representing their interests at a national and international level. Our vision is a more efficient, sustainable and profitable grains industry for all Australian grain farmers. Working with the grains sector and broader agricultural community, GrainGrowers aims to set a progressive agenda to drive positive change for Australian grain farmers across the national and global landscape.
GrainGrowers supports the application to register the use of Roundup Ultra Max Herbicide on barley (except malting barley), including the proposed use pattern equivalent to that permitted under the existing permit (PER82594) 1 and as per the APVMA Trade Advice Notice (TAN)2 published 28 February 2020.
GrainGrowers also supports the increase of the current maximum residue limit (MRL) for GC 065 Barley from 10 mg/kg to 20 mg/kg, in conjunction with a seven-day withholding period (WHP).
GrainGrowers does not support any current or future proposals that may exist
regarding extending the registration of glyphosate for use on malting barley.
Trade implications of extended use
GrainGrowers recognises the potential trade implications of produce detected to contain residues where (i) no MRL or import tolerance is established in the importing country; or (ii) where residues in Australian produce are likely to exceed the MRL
established in the importing country.
However, we acknowledge that existing monitoring and quality assurance programs and the processes that the barley industry, including growers, bulk handlers and traders utilise to effectively manage risk, mean that actual risk and non-compliance is low. The Australian barley industry has successfully managed the trade risk resulting from use of glyphosate on barley under the existing permit which commenced in November 2016 and is strongly positioned to continue doing so.
With respect to the major export markets for Australian barley, GrainGrowers acknowledges that China, Taiwan and Kuwait do not have MRLs for glyphosate in barley. China is Australia’s largest barley market, importing 4.6 million tonnes of Australian barley in 2017-18, worth over $1 billion and equivalent to 70% of total Australian barley exports. Given the significance of Australian barley trade with China and industry’s successful management of glyphosate residue in barley, the registration of Roundup Ultra Max Herbicide for use on barley (except malting barley) and the proposed increase of the Australian MRL from 10 mg/kg to 20 mg/kg is not likely to prejudice trade.
Conclusion
GrainGrowers supports the application to register the use of Roundup Ultra Max Herbicide on barley (except malting barley), including the proposed use pattern equivalent to that permitted under the existing permit (PER82594) and as per the APVMA TAN.
GrainGrowers supports the increase of the current MRL for GC 065 Barley from 10 mg/kg to 20 mg/kg, in conjunction with a seven-day WHP.
GrainGrowers does not support any current or future proposals that may exist regarding extending the registration of glyphosate for use on malting barley.
We thank the APVMA for the opportunity to provide comment on the proposed use of glyphosate in the product Roundup Ultra Max Herbicide for use on barley (except malting barley).
Should you require further information regarding this submission, please contact Lucy Darragh, Policy Officer, on (02) 9286 2000 or ua.moc.sreworgniarg@hgarrad.ycul
Sincerely,
David McKeon
Chief Executive Officer