eu transitional periods for mrls and international consultations in march 2019 colombia raised a concern regarding eu transitional periods for mrls and international consultations addressed in document g sps gen 1697. as already raised in the tbt committee on 6 march 2019 colombia stated that in practice european regulations tended to include shorter transition periods for standards amending mrls. colombia explained that a six-month period was not enough to comply with new mrls given the harvesting periods and the stage at which agrochemicals were applied. for processed and or frozen products the situation could be even more problematic. colombia explained that the development of a new phytosanitary pest-control product took 36 months on average and therefore transition periods should exceed the general rule of a reasonable interval of six months under annex b.2 of the sps agreement and ministerial decision wt min 01 17. colombia referred to article 10.2 of the sps agreement as it provided for longer time frames for the compliance with sanitary and phytosanitary measures for products of interest to developing country members with a view to maintaining trade opportunities for their exports. colombia presented the example of the transition period for reducing mrls for buprofezin to a minimum detection limit 0.01 mg kg commission regulation eu 2019 91 of 18 january 2019 addressed in stc no. 448 and its effects on the marketing of bananas. colombia insisted that the deferred implementation date did not allow time to find effective alternatives for pest control that met the high-quality standards required by the european market. colombia suggested creating a forum at the wto for technical discussions to prevent mrl changes from restricting trade more than necessary. brazil chile china costa rica ecuador guatemala honduras panama paraguay peru turkey and the united states supported colombias concern emphasizing that the eu transition periods granted to implement modified mrls were insufficient to adapt to the new requirements and prepare dossiers for import tolerance requests. paraguay added that concerns and observations raised in international consultations did not seem to have been taken into account by eu authorities. an example of this was the non-renewal of picoxystrobin and the subsequent modification of the mrl by the european union in january 2019 notification g sps n eu 264 add.1 despite prior concerns raised in the sps and tbt committees. turkey called on the european union to take into consideration international standards on mrl levels in the type of circumstances at issue as they were facing trade disruptions as a result of the ongoing situation. turkey asked the european union to implement longer transitional periods for products with a longer shelf life. the united states recalled that many us growers had to make final cro decisions a year in advance of the final product reaching a foreign markets border which meant that the inconsistent timing of eu mrl review and the short transition periods created significant challenges for them. the problem was particularly acute for commodities with longer storage and distribution cycles e.g. dried fruits dried nuts canned products frozen products juices wines and spirits which had been produced in accordance with the eu standards in effect at the time of production but were no longer eligible for entry into the european union upon shipment. in addition the united states wished to know why eu domestic producers had been granted grace periods of u to 15 months to continue using the substances in question when products of other members had not and why the european union had determined that immediate action on mrls was not needed until these domestic grace periods ended. finally the united states wished to remind the european union of its obligations under the sps agreement to take into account the technical and economic feasibility for producers of complying with the timeframes provid