eu amendments of mrls for imazalil in july 2019 colombia raised a concern regarding the draft eu commission regulation on maximum residue limits of imazalil notified in g sps n eu 319. colombia referred to documents g sps gen 1707 and g sps gen 1707 add.1 of colombia cote divoire dominican republic and ecuador. colombia explained that the draft regulation would lower the mrl of imazalil in bananas to a level which would make its use unfeasible despite being a substance that had been recently evaluated and approved at the european level. imazalil was a fungicide used by banana-producing countries for which there was no known phytosanitary alternative. the economic social and environmental impact would be irreversible for producing countries. colombia called on the european union to maintain its current mrl of 2 mg kg for imazalil in bananas in accordance with codex standards until the european union carried out a scientific risk assessment in accordance with the wto sps agreement. colombia also requested that the eu regulation take into account wto obligations under article 2 paragraph 2 article 3 paragraph 1 article 5 paragraphs 2 and 3 of the sps agreement. finally colombia requested that the concerns of a significant number of members who formally commented on the draft regulation be considered. costa rica referred to the european food safety authority efsa recognition that the mrls for imazalil in bananas should not be changed until there was more scientific evidence. costa rica added its concern that the draft regulation shifted the burden of proving the safety of imazalil to its users. in this case producers from developing and least developed countries in tropical regions countries whose institutional and budgetary constraints prevented them from commissioning their own scientific studies. costa rica urged the european union to ensure sufficiently long transition periods so that the necessary studies could be conducted and that exporting countries had the time to make those changes between cro harvests. ecuador highlighted that at the june 2019 meeting of the standing committee on plants animals food and feed of the european union scopaff eu member states and the eu commission had agreed to an mrl of 0.02 mg kg of imazalil for bananas. according to annex 3 of jmpr report 234 of 2018 the international estimated daily intake iedi of imazalil varied between 2 and 40 percent of the maximum acceptable daily intake adi for various products including bananas. this meant that consuming agricultural products with the maximum value of imazalil residue would not have a health impact since it would only amount to 40 percent of the maximum adi. the aforementioned jmpr report also recommended increasing the current limit to 3 mg kg. the report was recognized at the 51st annual meeting of ccpr held in april 2019 and put forward for adoption at the cac 42 meeting. ecuador further added that a number of eu member states had approved the mrl of 2 mg kg but that efsa had considered that the data contained in the jmpr report was not sufficient creating an uncertainty which led to the decision of lowering the mrl to 0.01 mg kg. finally ecuador stressed the need of a transition period to adjust to a new fungicide and of resources to conduct relevant scientific studies. the dominican republic joined this concern. imazalil was key to its banana mango and avocado exports which accounted for 20 percent of its annual food exports the main destination of which was the european union. the dominican republic drew members attention to the communication from india in document g sps w 284 of april 2015 which noted that the practice of adopting mrls for pesticides that were not registered or not used in the territory of the importing member had negative trade impacts. as a result of that communication the sps committee had held several technical workshops to discourage such practice. the dominican republic regretted that the europe