May 3, 2006

Japanese Regulations on Residual Limits for Agriculture Chemicals

On May 29, 2006, Japan will implement new regulations for residues of agricultural chemicals in food. Japan’s Ministry of Health, Labor and Welfare (MHLW) established provisional Maximum Residue Levels (MRLs) for 758 agricultural chemicals, in addition to existing MRLs, and a uniform limit of 0.01 ppm for residues not on the list.

After the implementation of the positive list regulation, foods containing residues exceeding the MRLs on the list, or 0.01 ppm in cases where there are no MRLs established, will be prohibited in Japan. With these new regulations, MHLW will not change its monitoring plan for imported foods, except that each sample will be tested for more residues. The same number of samples will be taken and there will be no new documentation or data requirements from MHLW after the implementation, however some importers are asking for additional information.

For more information about these new regulations, please read the report from the USDA office in Japan.

Requests from Importers

Some importers in Japan have begun to ask US wineries to verify the residual levels of many agriculture chemicals. The Japanese law does not require certification or testing but some retailers or importers have requested this information. To test for trace elements of all of these pesticides, or even the ones that the winery has used, is very expensive and becomes an endless process as new wines and vintages are introduced.

Compliance with MRLs

Please note that the MRLs established by the Japanese government are based on the residual level in the grapes not in wine. Therefore it is unlikely that any wine would exceed the stated limit.

In addition, Wine Institute’s Technical Committee reviewed the list of MRLs several months ago and concluded that our industry faced no threat from the limits, even though some limits are tighter in Japan than for the same chemical in the US.

Conclusion

As the Japanese law does not require that MRLs for wine or any other product be certified prior to import, we recommend discussing this issue with your importer should they request that you verify the agriculture chemical limits in your wines. If you have any further questions or need more information, please contact Jim Clawson, Chief Executive Officer at 202.463.8493 or via e-mail.