This summer, the European Commission’s Joint Research Centre (JRC) published a study on the proposal to ban residues of some of the most dangerous pesticides in imported products, a measure currently discussed as part of the “food and feed” omnibus regulation. Several press articles noted that lowering maximum residue levels (MRLs) to the limit of quantification (LOQ) for certain substances banned in the EU would significantly raise the prices of certain products, specifically, a 332% increase in the price of coffee.

However, that is not what the JRC report says. That is why the Veblen Institute - together with CNCD-11.11.11, Humundi, Slow Food, and the FNH - is publishing an analysis of the JRC report on mirror measures on pesticides.

The JRC report represents a considerable and meticulous body of work. However, it focuses strictly on economic feasibility, commercial impacts, prices, and competitiveness associated with tightening import rules, while setting aside environmental and public health factors. Mirror measures should not be reduced to a mere instrument of agricultural protection or competitiveness: their environmental and public-health objectives - which fall outside the scope of the JRC’s economic assessment - must be brought back to the centre of the debate. All the more so since, under WTO law, only environmental and public-health grounds can be invoked as justification — concerns about a level playing field in production conditions are not accepted.

Our analysis examines and challenges some assumptions and findings of the JRC report to provide evidence and arguments in favour of adopting more ambitious import requirements.

Main messages :

• The study covers 18 active substances classified among the most hazardous under the EU criteria used in the Food and Feed Omnibus proposal, and the impact of MRLs set at the limit of quantification. It therefore assesses the least ambitious demand level, and it does not examine the effects of the broader measure proposed in the latest compromise.

• The assumption of an abrupt halt in exports to the EU, resulting in a major inflationary economic shock—as modelled in the JRC’s first scenario (S1)—is not only unrealistic: legitimising excessively high impact assumptions (S1 and S2) also undermines the prospects for more ambitious policy action.

• S1 should not be used as a central forecast, but only as an upper bound. For country–commodity pairs involving a targeted substance with an EU MRL above the LOQ and evidence of authorisation or residue detection, it applies the shock to the entire trade flow, without scaling exposure to actual use or detection rates. It also assumes exporters do not adapt at all, which is unrealistic given historical examples (chlorpyrifos (2020), tricyclazole in rice exported from India and Pakistan (2018), or the neonicotinoids clothianidin and thiamethoxam (2026)).

• The assumptions underpinning S3—which produces a limited inflationary impact—appear more relevant than those used in S2 and more consistent with the initial request to assess the effects of lowering MRLs to the limit of quantification for a small list of substances. S2 appears to overestimate both the share of trade flows potentially affected and the associated adaptation costs.

• The significant impacts on the European livestock sector are not a robust finding. They occur mainly under S1, while becoming negligible in the two scenarios that allow exporters to adapt.

• Additional historical case studies documenting how exporters have adapted, including potential spillover effects, would help provide a stronger evidence base on adaptation in exporting countries.