Month: March 2016

MRLs and China: Real Or Imagined

MRL Myths

Uncertainty about how China deals with pesticide and herbicide residues has become an important marketing issue in the Canadian canola industry. Farmers have been warned that there could be “significant risk” to Canadian canola exports to China, allegedly caused by residues of the herbicide quinclorac – specifically the “generic” product Clever™, which contains the active ingredient, quinclorac.

But there also exists “inside the industry” mythology which could be equally puzzling for both the non-farming public and some farm operators.

Often acronyms are attached – such as “MRLs” – maximum residue levels. And these days, MRL comes up often in news reports or other discussions about marketing grain internationally – especially to China – and especially with canola.

Maximum residue limit is simply the amount of any non-food residue permitted on a food commodity. Countries set their own MRLs. In Canada the process is overseen by Health Canada, but the actual allowable levels are established by a group with another acronym – PMRA –the Pest Management Regulatory Agency. (For quinclorac, both the US and Canadian MRL standard for canola is 1.5ppm.)

Once known residue levels are established for a pesticide, PMRA calculates an additional safety factor and sets a “safe-for-humans” residue limit for a harvested crop. In Canada, 53 canola-use pesticides have been given an MRL rating – ranging from the base, .01, to 25 parts per million. China’s own MRL system meets Canadian standards on only six of the 53 MRLs. It should also be noted that China has not set MRLs for any of the commonly used canola–related weed control systems, including glyphosate-based RoundUp, Liberty (glufosinate), Ares (imacapyr), Pursuit and Odyssey (imazethapyr).

On its web page Saskatchewan Canola/Canola Council of Canada states that residues of quinclorac were found “most of the time” when Clever™ was applied, but without explaining the connection, the web page links quinclorac to Chinese exports. So, what are the facts about quinclorac and the Chinese market?

Real or Imagined?

China often has refused shiploads for a host of reasons, but they have yet to reject a canola shipment based on an MRL issue.*

China tests for MRLs only when the safe levels have been established for their own domestic food use, or if an importing Chinese company requests it. If China does not have its own MRL, officials may refer to the country of product origin, or they may consult what the industry knows as Codex Alimentarius (an internationally recognized “agreement” on food safety standards, which is co coordinated by the United Nations).

More than 70% of Canadian  2015 barley exports were to China, but so far, it appears the Chinese have no problem with Canadian use of quinclorac in barley (or in wheat) and they have set no MRL for either wheat or barley. In fact, China has established no MRL for many of the other grains it imports from Canada, especially those known as “minor use grains”.

2015 tests of canola exports by the Canadian Grain Commission were negative for quinclorac, as were “composite samples”. (See test Results)


Although MRLs are a different topic, the matter of “dockage’ recently became part of the over all export discussion.

A Chinese government ruling mandates that as of April 1, 2016 allowable limits for canola imports into China are reduced from 2.5% to one percent and notice is given that the level may be dropped further to 0.25%.

These new dockage provisions imply that Canadian canola growers will need to employ all of their available tools to ensure our exports comply. One of those tools could well be Clever™ herbicide, which in fact has several modes of action, to eliminate one of the biggest canola enemies ( and potential source of dockage)  – cleavers. (See ‘Epidemic Spread of Cleavers’ article).

*Source – Agriculture and Agri-Food Canada; legal insight from an article by US pesticide legal expert, John D. Connor; China’s own Ag ministry; and former Canadian Ag Minister Gerry Ritz.

Ritz baffled by Canola Council’s policy on quinclorac

MP Gerry Ritz (former Agriculture Minister and current Opposition Trade Critic) has taken issue with the Canola Council of Canada’s policy on quinclorac. In his February 19th  interview with Real Agriculture he takes the Council to task over their targeting of Clever® and questions why quinclorac is being treated differently than other actives currently used on canola in Canada that lack Chinese MRLs.

Listen to the full interview here:

Source: Real Agriculture – February 19, 2016

Maximum Residue Levels (MRLs), Quinclorac and China

It is very important for farmers to understand MRLs so that this issue of MRLs cannot be used as a false basis for anti-competitive actions or unfair profit taking. Let us look at our understanding of the basic facts:

What are MRLs & how are they established.

A Maximum Residue Limit (MRL) is the maximum amount of residue legally permitted on a food commodity. MRLs are established by the Pest Management Regulatory Agency “PMRA” under Health Canada to ensure that when pesticides are used according to label they are not a safety issue for the people of Canada.

MRLs are established by using the pesticide at maximum label rates and latest label application times to establish a worst case residue level.  The seed is then tested for the pesticide residue, a safety factor is applied, and if that level falls below a deemed safe level an MRL (in parts per million) is established for that pesticide on that commodity. (An MRL of .01 ppm is used as a default).

Global Pesticide MRLs

  • Canada has established MRLs for 53 pesticides used on canola, with limits ranging from .01 to 25 ppm
    • The majority of these 53 pesticides test positive for residue in Canola, quinclorac is no different
  • Canada and the USA have an established MRL of 1.5 ppm for quinclorac in canola.
  • Japan has an established MRL of 2 ppm for quinclorac in canola.
  • China has established MRLs to meet or exceed only 6 of the 53 pesticides used on Canola in Canada (i.e. pesticides with established MRLs in Canada). See attached MRL Comparison Table
    • Note that China has no MRLs to allow for any of the popular Canadian canola systems including: glyphosate, glufosinate, imazapyr, or imazethapyr
    • China has no established MRLs for many of the common pesticides used on other commodities imported from Canada, especially minor use grains.
    • China has no MRL established for quinclorac used on wheat and barley, yet China made up more than 70% of our barley exports in 2015 and quinclorac is regularly used in barley

The Chinese Market

If MRLs are so important, how then does Canada, or the rest of the world, market any grains into China?

Based on information from Agriculture and Agri-Food Canada, the Hon. Gerry Ritz (MP and former Agriculture Minister),  legal insight from an article by John D. Connor, Jr. (a pesticide regulatory expert in the USA) and conversations with the Chinese Ag Minister’s office we understand the following:

  • China does not test for MRLs except when established for domestic use or if requested by an importing company. (See Footnote 1)
  • If an MRL is required and a domestic MRL is not established, then China can look to the county of origin or Codex Alimentarius for an acceptable safe MRL level. (See Footnotes 1 & 2)
    • This policy of adopting the Codex MRL or the MRL of another country is undocumented and exists only by convention.
  • It is important to note that no ship load has ever been refused by China due to MRL issues.  China has refused many shiploads due to a host of other suspect reasons, but never because of MRLs.
  • China does, however, take serious issue with foreign matter in canola imports.  China recently demonstrated this by announcing that, effective April 1st, 2016, the allowable dockage is to be lowered from 2.5% to 1%.  China has indicated plans to further lower allowable dockage levels to 0.25%.  Since cleavers (form of dockage) are difficult and costly to clean out of canola Canada (farmers) should be minimizing cleavers in canola.

Quinclorac in Canadian Canola

The Canadian Grain Commission (CGC) tested canola for quinclorac residue in 2015 and found the following:

  • All cargos tested were negative for quinclorac. (See Footnote 3)
  • 25 regional composite samples of #1 canola in Western Canada all tested negative for quinclorac.
  • 3 prairie province composite samples of #2 canola tested negative for quinclorac.
  • 1 composite Western Canadian #3 canola sample tested negative for quinclorac.
  • Testing immediately after harvest of 110 samples of canola sprayed with quinclorac found a median residue of only .007 ppm. 30% of samples tested negative for quinclorac residue (limit of detection was .005 ppm or 5 parts per billion); remember that Canada has an established MRL of 1.5 ppm for quinclorac residue, which is more than 200 times the median found in the CGC tests.


  1. Agriculture and Agri-Food Canada, Setting Maximum Residue Limits (MRLs) of Pesticides in China, AgriDoc# 101866048 (PPT Slide 27), Jan 2016.
  2. John D. Connor, Jr & Jeffrey Li, China’s Regulation of Pesticides, The Metropolitan Corporate Counsel, Dec 2005
  3. Sherry Tittlemier, Canadian Grain Commission, Summary of recent quinclorac work in the Grain Research Laboratory, Feb 2, 2016

Epidemic Spread of Cleavers


These maps show the epidemic spread of cleavers in Saskatchewan from 1986 to 2015. Similar spread has occurred across Western Canada. On our read these maps indicate:

  • That the cleaver frequency closely parallels canola production; that the geographic presence of cleavers is very similar to the geographic production of canola (i.e. spread relatively equal to canola production).
  • That the existing methods suggested for controlling cleavers simply are not working and, as a result, cleavers are the fastest spreading weed in terms of frequency in canola.(see Footnote 1)

The cost to growers is staggering.

It is estimated that more than 50% of the canola acres have cleavers and the problem is spreading rapidly. A minor infestation will reduce yields by 5%, a major infestation by more than 20%. Let’s look at the costs:

Yield Loss

The canola production estimate for 2016 is 20 million tonnes. Assuming half the production acres are affected by cleavers, a price of $440 per tonne, and a minor infestation causing 5% yield loss.

That’s a whopping $200 million dollar loss to farmers – not accounting for serious infestations.

Downgrading of Canola

#1 Canola allows < 1% cleavers ($30/mt discount), 1.5% for #2 ($125/mt discount), and 2% for #3 ($150 to $400/mt discount).

Herbicide Costs

Current suggested methods for controlling cleavers too often cost $20 to $30 per acre (addition of Ethalfluralin alone can run $20/ac plus $6/ac application cost) over and above usual weed control costs.

That’s a $200 to $300 million dollar cost for solutions that haven’t controlled the epidemic.

Rotation Crop Losses

Cleavers that aren’t controlled in Canola wreak havoc in rotation crops, like peas, as resistance issues make them nearly impossible to control in pulses with current herbicides.

China has announced, effective April 1st, 2016, a maximum dockage allowed on imported canola of 1%. This allowable dockage will potentially be even lower in the future.  Given the difficulty of cleaning out cleavers due to similar shape and size as canola, it will be all the more important that growers control their cleavers.

The solution is simple.

Clever® is a Group 4 herbicide that both controls cleavers on contact and continues to control them throughout the year through residual action in the soil.  At less than $7 per acre, tank mixable and usable in all canola solutions Clever® stands as the most cost effective solution to the cleaver epidemic.



  1. I.G. Epp, C.J. Willenborg, U of S, Evaluating the response of Galium species and populations to herbicides, 2014