Residue Monitoring Plans explained
Giacomo Ciriello, Project Manager, Bees for Development
A Residue Monitoring Plan (RMP) is a risk assessment undertaken to assure that honey imported into the European Union (EU) will not contain harmful levels of chemical residues.
Residues may come from veterinary products used in bee hives, from pesticides and other pollutants bees encounter in the environment, or somehow contaminating honey during its processing and packing. Maximum Residue Limits (MRLs) for pharmacological substances are listed in Regulation (EU) No 37/2010, while those for pesticides are set in the framework of Regulation (EC) No 396/2005. A RMP is required for all animal products imported into the EU, and without it honey cannot legally be imported by any EU nation. Honey is the only bee product for which a RMP is necessary.
To comply, non-EU countries must submit a RMP to the Director General, Health and Food Safety of the European Commission. The plan must state the government department responsible for monitoring residues in honey, the description of the exporting country’s legislative framework covering the rules on the use of veterinary medicines, the sampling procedures and the laboratories approved to undertake residue analysis, as well as measures for noncompliance.
What a Residue Monitoring Plan contains
• Details of the non-EU nation’s competent authority
• Information about the legislative framework covering the use of veterinary medicines in the non-EU nation
• List of approved laboratories for residue testing and their accreditation status - these labs do not have to be in the exporting nation
• Details of actions to be taken in the event of a noncompliant result
Samples must be tested for residues in the following five sub-groups:
B1 Antibacterial substances, including sulphonamides and quinolones
B2c Carbamates and pyrethroids
B3a Organochlorine compounds including Polychlorinated biphenyls (PCBs)
B3b Organophosphorus compounds
B3c Chemical elements
Samples may be exempt from testing for a particular class of substances where producers can prove these are not being used. For example, the Zambian RMP does not test for B2c substances because exporters sell honey harvested by beekeepers who use fixed comb hives and do not treat their colonies against mite infestations.
Plans vary in complexity and cost depending on the size of exports and the beekeeping context.
The number of samples required depends on the size of exports: 10 per 300 tonnes of annual production for human consumption for the first 3,000 tonnes + one sample for every 300 tonnes thereafter. Tests can be expensive, so economies of scale are significant.
As a rule of thumb, around 100 tonnes are needed to sustain the costs of a simple RMP. When the RMP is approved by the European Standing Veterinary Committee, the country submitting it is added to the list of so-called third countries eligible for import. The RMP must be renewed yearly for honey exports to continue – testing new honey samples and documenting any changes to the plan.
When is an RMP needed?
It only becomes worthwhile to export honey to buyers within the EU, when you are confident that they will purchase larger volumes and/or at higher prices than buyers elsewhere. You should start looking into setting up, or joining an existing RMP, when you are in contact with serious buyers you know and trust. Towards building such relationships, it may be a good idea to discuss with prospective buyers whether they can support you with some of the costs associated to participating in an RMP.
If your country is not already on the list of those eligible to export honey to the EU, it may be difficult to approach and gain interest from buyers within the EU. However if you have the capacity to trade large volumes of high-quality honey, it is worth seeking funding to develop an RMP in your country. Depending on where you are, there may be grant opportunities for enterprise and trade development – and since the RMP benefits all current and potential honey exporters in your country, it is possible to make a strong case for seeking financial support.
What if my country already has an RMP in place?
You can find the list of countries eligible to export honey to the EU by searching for Document 32021D0800 on eur-lex.europa.eu. If your country is already on the list, you can join the RMP. To do so you will need to contact the authority responsible for accrediting honey exporters and be able to comply with the requirements set out in the RMP, as well as provide an estimate of how much honey you are seeking to export. RMPs must be renewed by 31 March every year, and this is the only time when new exporters can be added. Something to bear in mind for your business planning.
What if my country does not have an RMP yet?
The RMP is shared by all honey exporters in the country. As it is approved at country level and needs to be supported by a legal framework, government authorities must endorse it and officials must be designated to act as mediators between exporters and the EU. The development of a RMP is therefore a collaborative effort in which potential honey exporters to the EU team up with relevant governmental agencies.
The first step towards developing the RMP is to forge alliances. If there are any, you should try reaching out to other wholesale honey businesses in your country who stand to benefit from access to EU markets. Expressions of interest from buyers in the EU will boost your cause. While it may be a struggle at first to get someone’s attention in government, getting the RMP for honey approved can be a major political win for export promotion, livestock or agricultural development ministries. Being proactive generates momentum!
Once the key stakeholders are committed, the process is not difficult. You will have to identify the agencies responsible for accrediting honey exporters and the laboratories where samples will be tested. These testing laboratories do not have to be in the exporting country, it is quite usual for samples to be sent to laboratories in the EU with the means to test samples against the EU standards. Samples can be collected at random by the accredited laboratory personnel at the listed exporters’ warehouses. The RMP will also need to specify what records exporters and their suppliers must keep to ensure that the honey consignments are traceable back to producers.
If you are in the process of developing an RMP and need any advice or guidance, do reach out to Bees for Development, at email@example.com
We can help you find the information you need.
If a non-EU nation plans to develop a RMP for honey – it can be useful to check if the country already has a RMP for another animal product such as milk or eggs. If so, liaise with the authority that developed that RMP and seek their advice. For example, Bangladesh already has a RMP for aquaculture but not honey. The principles and processes will be similar for both.