Zero pesticide detection is not a long-term solution for organic farming. How do countries around the world regulate it?

By Guo Huaren (Emeritus Professor, Department of Agronomy, National Taiwan University)

Organic products occasionally test positive for pesticide residues. Recently, Taoyuan found a detection rate of 3.3%, but all were below the permitted pesticide residue limits for conventional vegetables and did not exceed the standard. However, according to regulations, the organic certification of the farmers whose products tested positive is revoked.

The organic guideline adopting a zero-detection rule for pesticides is unique to our country; no advanced nation has such a rule.

Several years ago, in response to this issue, the Agriculture and Food Agency had intended to adopt the US approach, using 5% of the permitted pesticide residue limit for conventional agricultural products as the threshold for whether a product could still be considered organic, but this was abandoned due to strong resistance from consumer groups and consumers.

Consumers generally think that since organic products are expensive, zero detection should naturally be required. However, this thinking ultimately works against consumers themselves and may even plunge the country into a situation where there is no food to eat.

How so? First, let us explain why pesticide residues are found in organic products. The pesticides in these detected samples come from roughly two sources. One is the covert use of pesticides, which leaves residues. The other is contamination. The former must of course be prohibited; the latter is actually difficult to avoid. No matter how well immediate isolation measures are taken, occasional contamination opportunities still exist.

How do other countries handle such situations?

(1) United States:

US organic regulations contain no zero-detection rule. Only if the detected pesticide residue amount is 5% or more of the permitted residue limit (for example, if the original regulation prohibits exceeding 10 ppm, then if an organic product tests higher than 0.5 ppm) may it not be marketed as an organic product. The competent authority or certification body may investigate the producer to identify the contaminating substance and its cause.

The "5% of the permitted residue standard" is a tolerance set in consideration of the many unavoidable accidental contamination sources present in the general environment, rather than a looser standard set for the organic production requirement of "prohibiting the use of any prohibited substance." Producers may still not use any prohibited substance in the production process.

Therefore, not all products whose residues of prohibited substances are below the 5% tolerance standard can be regarded as qualified organic products; the competent authority or certification body must conduct follow-up investigations of the producer and make a determination on a case-by-case basis.

(2) How do the EU, Japan and the UK regulate?

Although the organic regulations of the EU and Japan stipulate that chemical pesticides may not be used, they also have no zero-detection rule.

European countries handle pesticide residues detected in organic products in somewhat different ways. In the UK, as long as the level does not exceed the permitted residue limit for conventional products, it is acceptable (because organic regulations only govern the production process, not the final product).

Although the regulations of the EU and Japan contain explicit provisions that "the use of prohibited substances is forbidden in the production process," neither explicitly sets a "tolerance standard for residues of prohibited substances in organic products," nor contains any explicit provision that "residues of prohibited substances in organic products must be zero."

Under a textual interpretation of the provisions, "prohibiting the use of prohibited substances in the production process" is not equivalent to "no residues of any prohibited substance may be detected in organic products." Therefore, from a legal standpoint, the residue standard for organic products should not be directly inferred from the provision "prohibited substances may not be used in the production process" to mean "no residues may be detected."

In the absence of explicit provisions, organic products should be subject to the general product residue provisions set out in other food-related laws; for example, the official website of the UK Food Standards Agency states in its explanation of organic products that "organic and conventional products should both meet the same legal food standards," and does not mention that organic products must legally be subject to stricter standards.

(3) Germany's CERES four-level reference

Germany's well-known organic certification body CERES has relatively clear provisions: it first divides pesticide residue values from "zero detection" to the "permitted pesticide residue limit" into four levels, and formulates handling procedures corresponding to each level according to the severity of the residue.

Level four is high residue. In addition to prohibiting the batch of products from being sold as organic and conducting an investigation, the certification body must also investigate and test all other products at the production site to ascertain the contamination status of other products.

Level three is moderate residue. There may be a suspicion that prohibited substances have already been used in the production process, or that pollution prevention measures have clearly not been properly implemented. The certification body should first temporarily suspend the certification qualification of the batch of products, also temporarily prohibit their sale as organic, and conduct further testing and investigation of the batch, then make a final decision based on the investigation results.

Level two is trace residue. The producer must, together with the reviewer, submit a report on possible contamination sources and adopt improvement measures to the certification body, but the product may still continue to be sold as organic.

Level one, closest to zero residue, although still having extremely tiny residues, is still regarded as a qualified organic product.

Why is nationwide organic conversion so important?

The reason is simple: the excessive use of pesticides has reached an extremely serious level, and groundwater, tap water, and rainwater from the sky have all been contaminated. When the environment is unhealthy, it is hard for the human body to be well either. This is the "shared karma" of our generation or two after decades of widespread pesticide use and pesticide-derived products.

For the well-being of future generations, we need to give them back a healthy environment, so nationwide organic conversion is necessary. The necessity of nationwide organic conversion is not only for health but also for the survival of the nation and society.

Healthy soil is the most favorable condition for crop growth. Good farmers take care of the soil and let the soil take care of the crops. Research in recent years has confirmed that various organisms above and below farmland can not only make fertilizer for us, but some can also help crops absorb fertilizer, and some can help crops resist pests and diseases. They can be called the farmers' free long-term laborers.

But these long-term laborers have long been wiped out by pesticides and chemical fertilizers. Without these organisms on the farm, the result is what everyone says now: without pesticides and chemical fertilizers, there can be no production.

In other words, our agriculture needs two tubes, one tube for chemical fertilizer and one tube for pesticides. If either tube is gone, production becomes difficult. Such agriculture is exactly like a person in an intensive care unit who needs two tubes inserted.

With agriculture stuck in the intensive care unit, not only does environmental pollution continue to worsen, but the most likely crisis is that in the future era of high oil prices, the cost of pesticides and chemical fertilizers will be so high that farmers will not dare to buy them, and then production will become difficult.

Do not think that if the country cannot produce, it will be enough to buy imports. By then imported grain will of course be quite expensive, and may even be unavailable.
This is not alarmist. The United States produces oil, but in recent years it has required that gasoline contain 10% alcohol. The source of that alcohol is corn. The US used to rank first in corn exports, but now 40% of corn is used to make alcohol, so export volume has of course declined severely.

In the post-oil era, if corn-producing countries all use it to make alcohol, will we still be able to buy imported corn?

So in order to improve our environment, to protect health, and even for the survival rights of future generations, accelerating nationwide organic conversion is something that must be done.

Our country's unique zero-detection rule for pesticides will hinder organic transformation and seriously obstruct the achievement of nationwide organic conversion. Is this not terrifying?

Consumers need to recognize this and think carefully, so that the government can establish a more reasonable and more detailed management approach for pesticide detection in organic products, allowing organic conversion to accelerate and pesticides to withdraw from farms as soon as possible. Only this is the once-and-for-all solution.

Organic farmers bear responsibility for neighboring field contamination. Farmers say: one positive test means a death sentence, who would dare do organic?

Research on organic agriculture laws and policies

Guo Huaren: The true essence of organic agriculture lies in being friendly to the land, not zero pesticide detection

The best and worst eras of organic agriculture: Europe reviews its certification system to rediscover its original purpose