Pesticide Tolerance Levels - United States

We want to import a frozen avocado product. The manufacturer uses the pesticide Prochloraz, which is not registered in the United States. There is not a set tolerance level (MRL) for this pesticide in the United States.

However, the Prochloraz is not detectable in the finished product, i.e. zero MRL. The cleaning process eliminates all traces of Prochloraz. What is the EPA’s stance on unregistered pesticides? Is it that the pesticide must not be detectable, or is it that the pesticide must not be used at any point in the production process?

I understand that shipments of imported food found to have pesticide residues for which a tolerance or exemption from a tolerance has not been issued will be held up. As the importer I can file a petition for a tolerance or exemption from a tolerance. However, I am hoping a petition is not necessary because the Prochloraz is not detectable in the finished product.

Thoughts?

It would appear you simply cannot import this product without at least trying to get a letter.............it would appear it's on the radar for checking.  It will be that you cannot USE that product

https://www.accessda...talert_259.html

If it's not approved for us in the USA (and BTW banned in canada as well) then you at real risk of the attached  link happening to you (product rejected and denied entry)

Have your test been done on just the skin, or has the flesh been sampled as well

For an item to be banned in Canada and the US, is must be pretty toxic