Tea and EU’s pesticide logistics

The European Union’s increasingly strict pesticide regulations are reshaping the rules for imported tea. As more active substances are banned for agricultural use within the EU, maximum residue levels (MRLs) for those same substances in imported foods are being lowered – often to the limit of detection (LOD). This logic aims to ensure consumer protection but creates challenges for producers and traders outside the EU.

Tea production encompasses a wide range of traditional techniques, many of which involve high heat. Pan-fried green teas and smoked black teas, such as Lapsang Souchong, rely on thermal treatments essential to their sensory profile. However, these methods can also lead to the formation or accumulation of chemical residues that are not the result of pesticide use.

Two substances in particular – anthraquinone and polycyclic aromatic hydrocarbons (PAHs) – have become focal points in regulatory discussions. According to recent studies, anthraquinone can be introduced into tea through atmospheric deposition or combustion-related contamination during processing. Meanwhile, PAHs are formed during smoking or when organic material is exposed to incomplete combustion. Both should be considered process-related contaminants.

While the EU regulatory framework does distinguish between contaminants and pesticide residues, there are recurring cases where the classification of specific substances does not align with production realities. This disconnect can lead to disproportionate compliance burdens and unintended barriers to marketaccess – particularly for traditionally processed teas.

The legal framework governing chemical residues in tea within the EU is split between two core regulatory paths. This distinction determines not only the applicable limits but also the flexibility of enforcement. 

Anthraquinone, although its use as a pesticide was banned in the EU in 2008, and its MRLs were subsequently tightened, it continues to be regulated as a pesticide residue.  This classification persists even when the compound is demonstrably not applied agriculturally.For tea producers and importers, this rigidity creates compliance hurdles.

By contrast, when process-related contaminants are misclassified as pesticide residues, the consequences can be severe. Even trace amounts may lead to non-compliance, and for traditionally produced teas, this can result in de facto import bans.

Source: STiR Coffee & Tea (Extracts), Courtesy: Tea Exporters’ Association Sri Lanka