One Egyptian Pepper, Two Limits: GB vs EU MRLs Since 2021
Last updated: 19 October 2026 · By the FoodGate Audit inspection team (ISO 17020 accredited) · Get a free quote in 24h →
Great Britain and the European Union keep separate pesticide residue registers, and since the first GB amendment on 23 April 2021 they have moved apart in both directions. HSE has adopted five rounds of Codex limits, from June 2022 to February 2026, that the EU has matched on some substances, on its own dates, and never set on others; the EU has lowered acetamiprid and the neonicotinoids to levels GB did not follow. On sweet peppers, the acetamiprid limit rose to 0.4 mg/kg in GB on 28 April 2025 and fell to 0.09 mg/kg in the EU on 19 August 2025. For Egyptian produce the working limit is the lower of the two wherever a lot can reach Belfast or Dublin, and on cyfluthrin, the substance GB monitoring found on Egyptian oranges this year, GB is fifteen times stricter than the EU.
Key Takeaways
Five points from the HSE decision documents, the EU database entries read on 19 September 2026 and EU RASFF Window data, 22 September 2026 snapshot.
| Point | Details |
|---|---|
| Specify the register, not just the limit | "MRL compliant" means nothing on a UK contract since 2021. Write "GB MRL Statutory Register" or "Regulation (EC) 396/2005 as applied in the EU", and date it. |
| Route the container before you brief the laboratory | A lot that may be split between Liverpool and Belfast or Dublin is judged on the lower of the two limits. HSE's own page says EU MRLs apply in Northern Ireland. Ireland took 10,224 t of Egyptian oranges in 2025, 31.5 % of its orange imports (Eurostat Comext). |
| The entry-into-force date decides, not the value | Every GB decision carries one. The chlorpropham review applied to all goods on the market from 10 April 2024, whatever their production date. |
| The split runs both ways | GB holds cyfluthrin on citrus at 0.02 mg/kg, the EU at 0.3; the EU holds clothianidin at 0.01, GB at 0.05 on peppers. Neither side is the lenient one. |
| GB findings live in Defra's quarterly reports, not in RASFF | Not one of the 541 RASFF notifications on Egyptian produce (2019 to 22 September 2026) was raised by the United Kingdom. GB findings are in Defra's quarterly monitoring reports. |
Table of Contents
- Five Codex decisions, and the rule that made them matter
- The same pepper, two directions in four months
- What the GB programme found on Egyptian produce
- Where an inspection fits
- The higher limit is the wrong number to plan on
- Recommended
- Frequently Asked Questions
- Sources
Five Codex decisions, and the rule that made them matter
When the transition period ended, every EU maximum residue level in force became a GB limit and stayed valid, in HSE's words, "until amended". The amending began on 23 April 2021, and the largest moves since have been the Codex rounds: after each session of the Codex Committee on Pesticide Residues, HSE adopts the international limits that pass three tests, a GB limit exists for the commodity, it is lower than the Codex one, and no consumer health concern is found. The EU runs its own procedure, so a Codex value reaches the registers on different dates, or only one.
| GB decision | Codex session | In force | One Egyptian crop it touched, mg/kg |
|---|---|---|---|
| GB MRL 2022/005 | CCPR 2021 | 14 June 2022 | Fluxapyroxad, oranges, 0.3 to 1.5 |
| GB MRL 2023/019 | CCPR 2022 | 8 December 2023 | Spiropidion, potatoes, 0.01 to 1.5 |
| GB MRL 2024/007 | CCPR 2023 | 19 March 2024 | Tetraniliprole, table grapes, 0.01 to 1.5 |
| GB MRL 2025/001 | CCPR 2024 | 17 January 2025 | Isocycloseram, sweet peppers, 0.01 to 0.6 |
| GB MRL 2026/005 | CCPR 2025 | 13 February 2026 | Fipronil, onions, 0.005 to 0.03 |
Source: HSE, GB MRL publications spreadsheet, June 2026 update, and the five decision documents. The second table sets each GB value against the EU entry applicable on 19 September 2026.
| Substance | Crop | GB limit (since) | EU limit (since) |
|---|---|---|---|
| Acetamiprid | Sweet peppers | 0.4 (28 Apr 2025) | 0.09 (19 Aug 2025) |
| Clothianidin | Tomatoes, sweet peppers | 0.05 (17 Jan 2025) | 0.01 (7 Mar 2026) |
| Isocycloseram | Oranges | 0.4 (17 Jan 2025) | No entry: default 0.01 |
| Tetraniliprole | Table grapes | 1.5 (19 Mar 2024) | No entry: default 0.01 |
| Fenpyroximate | Oranges | 0.7 (8 Dec 2023) | 0.5 (unchanged since 2008) |
| Bifenthrin | Pomegranates | 0.5 (19 Mar 2024) | 0.01 (since 2017) |
| Fipronil | Onions | 0.03 (13 Feb 2026) | 0.005 (since 2020) |
| Cyfluthrin | Oranges, all citrus | 0.02 (unchanged) | 0.3 (16 Aug 2023) |
| Chlorpropham | Potatoes | 0.35 temporary (10 Apr 2024) | 0.2 temporary (6 Jan 2026) |
| Mandipropamid | Oranges | 0.4 (8 Dec 2023) | 0.4 (22 Jun 2023) |
Read the last row first: on mandipropamid the EU got there six months before GB, and on fluxapyroxad it matched GB two months after. Convergence is the common case; the rows above are the exceptions, on crops Egypt ships.
The same pepper, two directions in four months
Pesticide residues dominate the Egyptian record: 458 of the 541 RASFF notifications on Egyptian fruit, vegetables, herbs and spices (85 %), and 252 of the 271 border rejections (93 %), 2019 to 22 September 2026. Acetamiprid is named in 30 of the 541 in the structured hazard field, joint seventh among substances, 16 of them border rejections. The 2026 count, eight, already exceeds the whole of 2025, seven. By product it is 17 on vine leaves, 4 on mangoes, 3 on peppers (two of them named sweet peppers) and 2 on grapes.
In 2025 the two registers changed the pepper limit in opposite directions. HSE raised it from 0.3 to 0.4 mg/kg on 28 April, under GB MRL 2025/009, to support a domestic use against aphids. The Commission lowered it from 0.3 to 0.09 mg/kg from 19 August, under Regulation (EU) 2025/158. A pepper at 0.2 mg/kg is legal in Liverpool and illegal in Dublin, Belfast and Rotterdam. Of the five notifications on peppers or grapes, four were raised after the EU cut took effect: grapes from the Netherlands (20 October 2025) and Denmark (26 August 2026), peppers from France (8 December 2025 and 21 January 2026). Strawberries followed: GB to 0.7 on 28 May 2025 under GB MRL 2025/011, the EU holding 0.5.
The neonicotinoids run the other way round in time. HSE adopted the Codex values for clothianidin and thiamethoxam on fruiting vegetables in January 2025; the EU had already decided, in Regulation (EU) 2023/334, to take both to 0.01 mg/kg from 7 March 2026 on tomatoes, peppers, mangoes and every other Egyptian crop checked. Clothianidin is the fastest-rising name on the Egyptian record: 18 notifications in the structured field, none in 2024, seven in 2025 and nine in 2026, 12 of them on mangoes, 11 of those border rejections. The Irish border rejection of 31 August 2026, reference 2026.7662, names acetamiprid and clothianidin on Egyptian mangoes together. The mango trade is not small on the GB side: HMRC records 4,484 t of guavas, mangoes and mangosteens (HS 080450) from Egypt in 2025, 4.2 % of UK imports of that heading, against 2,770 t into the whole EU27 (Eurostat Comext).
Pro Tip: brief the laboratory with two columns per substance, GB value and EU value, each with its date and the residue definition copied from the register that sets it, and mark the lower one as the pass line. A result reported against a single unnamed "MRL" cannot be defended at either border, and the definitions differ: the EU fipronil entry is the sum of fipronil and its sulfone metabolite, and the GB register lists its limits under the residue definition, not the trade name.
What the GB programme found on Egyptian produce
Great Britain publishes its own residue results quarter by quarter, through the HSE monitoring programme run for Defra and the devolved governments. Origin appears only in the exceedance tables, so the reports say which Egyptian samples failed, not how many were drawn. From Q1 2025 to Q1 2026, these did; Q4 2025 lists none.
| Report | Sample | Substance | Found | GB MRL | Stands after uncertainty | EU MRL then |
|---|---|---|---|---|---|---|
| Q2 2025 | Spunta potatoes, 5510/2025 | Fluazifop-P (sum) | 0.4 | 0.15 | Yes | 0.15 |
| Q2 2025 | Spunta potatoes, 5511/2025 | Fosthiazate | 0.1 | 0.02 | Yes, referred to FSA | 0.02 |
| Q2 2025 | Santana potatoes, 5514/2025 | Fluazifop-P (sum) | 0.3 | 0.15 | No | 0.15 |
| Q3 2025 | Figs, 5619/2025 | Cyfluthrin (sum); dithiocarbamates; fludioxonil | 0.05; 0.6; 0.02 | 0.02; 0.05; 0.01 | Yes, all three | 0.01; 0.05; 0.01 |
| Q1 2026 | Navel oranges, 5059/2026 | Cyfluthrin (sum) | 0.03 | 0.02 | No | 0.3 |
| Q1 2026 | Navel oranges, 5119/2026 | Cyfluthrin (sum) | 0.04 | 0.02 | Yes | 0.3 |
| Q1 2026 | Jumbo salad onions, 3205/2026 | Carbofuran (sum) | 0.009 | 0.002 | Yes, referred to FSA | 0.002 |
Source: Defra and HSE quarterly reports, Q1 2025 to Q1 2026, and the EU Pesticides Database. mg/kg.
On the potato, salad onion and two of the three fig findings, the GB and EU limits were the same number, most of them the limit of quantification: the divergence that fills briefings decided none of those cases. The one substance where the registers differ on oranges runs against the received idea. Cyfluthrin on citrus has been 0.3 mg/kg in the EU since Regulation (EU) 2023/173 took effect on 16 August 2023, while GB kept the inherited 0.02; both Egyptian navel samples of early 2026 sat between the two numbers. On the EU side, cyfluthrin appears in 20 of the 541 RASFF notifications, 11 of them border rejections, 7 of them in 2026 to 22 September; two are on oranges. The oranges themselves are a GB volume line: 71,126 t from Egypt in 2025, 30.8 % of UK orange imports, GBP 32.33 million (HMRC, HS 080510, down from 78,017 t in 2024).
Where an inspection fits
FoodGate Audit is an inspection body accredited to ISO/IEC 17020 by the Egyptian Accreditation Council, EGAC, working in Egyptian packhouses and fields. It does not set limits, does not represent either register, and does not certify; it samples and reports for the party that commissions it, and has no interest in the goods. Exporters as well as importers order that work.
For a lot bound for the United Kingdom the useful moment is before loading, with the two-column brief above. A pre-shipment inspection takes the samples against that brief, seals and photographs them, and sends them to an ISO/IEC 17025 laboratory whose scope names each substance and its reporting limit. The result comes back as a table against both registers, so the decision to ship, hold or divert the lot is taken in Egypt on a dated document, not at a border control post after freight has been paid. The EU column is on the EU MRL Checker; the GB column comes from the statutory register, entry by entry.
The higher limit is the wrong number to plan on
The divergence is usually told as a story about Great Britain relaxing, and the tables above show why that framing costs money. On the substances that failed on Egyptian potatoes, salad onions and two of three on figs, the registers agreed to the decimal; on oranges, GB stood fifteen times stricter. An importer who has read that GB is the lenient register tests navel oranges for cyfluthrin against 0.3, passes a lot at 0.04, and learns the GB figure from the quarterly report.
The reverse mistake is cheaper but not free. A pepper grower told that GB now allows 0.4 mg/kg of acetamiprid has been told something true and useless: the UK took only 432 t of Egyptian peppers and chillies (HS 070960) in 2025, 0.2 % of its imports of that heading (HMRC), while the EU27 took 10,440 t of the same heading, up from 4,581 t in 2023 (Eurostat Comext). The container is booked to Liverpool, the customer has a depot in Belfast, and the overflow goes to Dublin. HSE's guidance settles which limit governs goods marketed in Northern Ireland, and it is not the GB one unless they moved there from Great Britain under the retail movement scheme, which a container from Egypt did not. The number a buyer plans on is the lowest limit on any route the fruit can take, and it sits in two registers, under two dates, and on no headline.
Recommended
- Importing Egyptian produce into the UK: the plant health and food safety border regimes the same consignment must clear.
- EU MRL Checker for Egyptian produce: the EU column, substance by substance, for the products on the Egyptian record.
- EU MRL compliance guide: how an EU limit is set, read and enforced, the half of this comparison that has not changed.
- Tesco Nurture supplier guide: what a UK retailer's own standard asks for beyond the statutory register.
Shipping from Egypt this season? Put independent eyes at the packhouse.
Get a Free Quote →Frequently asked questions
Which register applies to Egyptian produce landed in Belfast?
The EU one. HSE states that EU MRLs apply to food produced in, imported into and marketed within Northern Ireland, with one exception: goods moved there from Great Britain under the Northern Ireland Retail Movement Scheme. A container arriving from Egypt is not moving under that scheme.
Can an importer ask HSE for a higher GB limit on an Egyptian crop?
Yes, through an import tolerance, applied for before import, with evidence of the authorisation in the exporting country and residue data. The isotianil limit of 0.4 mg/kg on citrus, GB MRL 2024/013 of 30 August 2024, was one, requested for treated citrus from Cambodia. It changes nothing at an EU border, where isotianil has no entry and the 0.01 default applies.
Does a new GB limit apply to fruit that was already at sea?
Read the decision document rather than the register line. The chlorpropham review, GB MRL 2023/018, gave six months' notice and then applied "to all goods on the market from 10 April 2024, irrespective of when they were first produced and/or placed on the market". Codex adoptions, which raise limits, apply from their entry-into-force date.
Is Great Britain always the more permissive register since Brexit?
No. For the crops above GB is higher on acetamiprid, the neonicotinoids, fenpyroximate, bifenthrin and fipronil, and lower on cyfluthrin across all citrus, where the EU moved to 0.3 mg/kg in August 2023 and GB stayed at 0.02. On the substances flagged on Egyptian potatoes and salad onions, the two limits were identical.
Where are GB residue findings on Egyptian produce published?
In the quarterly reports of the pesticide residues monitoring programme on GOV.UK, with sample number, food, country of origin, residue found, the GB MRL, and whether the exceedance stands after measurement uncertainty. None of the 541 RASFF notifications on Egyptian produce (2019 to 22 September 2026) was raised by the United Kingdom; four came from Ireland.
Sources
- HSE, GB MRL publications spreadsheet, June 2026 update: https://www.hse.gov.uk/pesticides/mrls/gb-pubs-spreadsheet.htm
- HSE, Codex adoption decisions GB MRL 2022/005, 2023/019, 2024/007, 2025/001, 2026/005: https://www.hse.gov.uk/pesticides/assets/docs/mrlcx-aatq-0245.pdf, mrlcx-aaoi-0375.pdf, mrlcx-aagv-0446.pdf, mrlcx-aavv-0834.pdf, mrlcx-abfd-1046.pdf
- HSE, GB MRL 2025/009 and 2025/011 (acetamiprid), 2023/018 (chlorpropham), 2024/013 (isotianil): https://www.hse.gov.uk/pesticides/assets/docs/mrln-aayl-0901.pdf, mrln-aazr-0933.pdf, mrlr-aant-0360.pdf, mrln-aasd-0729.pdf
- HSE, MRLs and import tolerances (overview, Northern Ireland, new MRLs, Codex MRLs), read 19 September 2026: https://www.hse.gov.uk/pesticides/mrls/index-overview.htm
- GB MRL Statutory Register: https://secure.pesticides.gov.uk/MRLs/Main
- Defra and HSE, Pesticide residues in food: quarterly monitoring results, Q1 2025 (published October 2025) to Q1 2026 (August 2026): https://www.gov.uk/government/collections/pesticide-residues-in-food-results-of-monitoring-programme
- European Commission, EU Pesticides Database, entries read 19 September 2026: https://ec.europa.eu/food/plant/pesticides/eu-pesticides-database/start/screen/mrls
- Regulation (EC) No 396/2005, Article 18(1)(b): http://data.europa.eu/eli/reg/2005/396/oj
- Commission Regulations (EU) 2025/158 (acetamiprid), 2023/334 (clothianidin, thiamethoxam), 2023/173 (cyfluthrin), 2025/1163 (chlorpropham): http://data.europa.eu/eli/reg/2025/158/oj, http://data.europa.eu/eli/reg/2023/334/oj, http://data.europa.eu/eli/reg/2023/173/oj, http://data.europa.eu/eli/reg/2025/1163/oj
- European Commission, RASFF Window, notifications on Egyptian fruit, vegetables, herbs and spices, EU RASFF Window data, 22 September 2026 snapshot (541 notifications, 28 November 2019 to 22 September 2026): https://webgate.ec.europa.eu/rasff-window/screen/search
- FoodGate Audit, RASFF notifications on Egyptian produce, same snapshot, structured hazard, classification and notifying-country fields, CC BY 4.0: /egyptian-produce-open-data.html
- Eurostat, Comext (DS-045409), imports from Egypt, 2025, accessed 19 October 2026: https://ec.europa.eu/eurostat/databrowser/view/DS-045409/
- HM Revenue and Customs, Overseas Trade in Goods Statistics, 2025, accessed 19 October 2026: https://www.uktradeinfo.com
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