China Guomen Times: Challenges and Responses to Technical Trade Measures Faced by Tea Exports to the European Union

The European Union is one of the main target markets for China's tea exports, as well as a region with a high level of food safety protection and strict pesticide management policies. At present, tea exported to the European Union is facing technical trade challenges such as strict pesticide residue limit standards, high attention to certain new pollutants, and an increase in the number of sampling samples. To address these challenges, it is necessary for relevant enterprises to further strengthen cooperation, accelerate the green transformation and upgrading of China's tea industry, and enhance the forward-looking and proactive nature of trade compliance.
Technical trade measures challenges faced by tea exports to the European Union
The limit standards are quite strict. According to regulations such as the Maximum Residue Limits (EC) No. 396/2005 for pesticides, there are currently 562 pesticide residue testing items for tea in the European Union, most of which are set at quantitative limits (0.02 or 0.05mg/kg), which are stricter than the relevant requirements in China. Taking imidacloprid as an example, the limit in China is 0.5mg/kg, while the limit in the European Union is only 0.05mg/kg. At the same time, the EU has implemented a "uniform limit" of 0.01mg/kg for some pesticides that have been deregistered in recent years or for pesticides that do not have a maximum residue limit. For example, in recent years, substances such as imidacloprid and fipronil, which have been widely reported by the EU in China's exported tea, have not been registered for use in the EU.
New types of pollution are receiving attention. Some chemical substances that are not used as pesticides in exporting countries may cause pollution to agricultural products through non-agricultural means. The European Union has established strict residue limit standards for these substances, which has led to a large number of reported incidents of agricultural products. Among them, anthraquinone has been reported as the most prominent. The EU has set a residue limit of 0.02mg/kg based on the assessment conclusion of the potential carcinogenic risk of anthraquinone proposed by the European Food Safety Authority (EFSA), which poses a significant challenge to Chinese enterprises. Research has found that the smoke generated from burning coal and firewood during tea processing may be the main source of anthraquinone pollution in Chinese tea.
The monitoring of imports has been strengthened. In 2023, tea will be included in the EU's official temporary strengthened monitoring plan, with a sampling rate increased to 20%.
Suggestions for Enterprises to Address Technical Trade Measures
Firstly, enterprises should closely track the changes in EU pesticide residue limit regulations and standards, prepare in advance, comprehensively grasp the use of pesticides in tea plantations and the pesticide residue status of tea raw materials, improve the quality and safety level of tea exported to Europe, and avoid export risks such as notification and return.
Secondly, industry associations should fully leverage their role as a link and strengthen the collection, interpretation, and analysis of information on technical trade measures. Through the promotion, management, and standardization of industry associations, guide enterprises to play their main role in response and avoid trade losses caused by information asymmetry.
Finally, we need to promote the joint efforts of customs and enterprises to break through barriers and go global. When the technical trade measures of the importing country have an impact on China's tea exports, enterprises can contact the local customs and provide feedback to the foreign party through the customs' external cooperation and consultation mechanism in multiple bilateral occasions, actively reducing the adverse effects of unreasonable technical trade measures and safeguarding their own legal rights and interests.