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MRL Oil olive USA


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#1 EL BATTAH Bilal

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Posted 22 March 2019 - 08:31 AM

Hello,

My company want to export oil olive to USA, and I want some advice about the exportation procedure, also I was trying to find the MRL Databases regulation for olive oil but I didn't find something interesting, can you help in this issues??

 

Waiting for your advice and response

 

 

Best regards



#2 pHruit

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Posted 22 March 2019 - 09:31 AM

These guys have a useful database and the basic subscription is free: https://bcglobal.bry...ie.com/db#login

MRLs will almost certainly be set for the agricultural commodity (olives) rather than the processed oil.

 

This link may also be useful for the import requirements: https://www.fda.gov/...orts/importing/



#3 EL BATTAH Bilal

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Posted 28 March 2019 - 10:06 AM

Hi, 

Thanks for your reply I really I really appreciat it but the problème that the list don't include the olive oil.



#4 pHruit

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Posted 28 March 2019 - 10:21 AM

Hmm, yes, it doesn't appear to list olive oil, but there are clearly at least a few specific MRLs set for olive oil that are different to those for olives (the EU has a different approach to this, and I'm much better versed in those regs than I am with the US!).
You may find it useful to search though the Electronic Code of Federal Regulations (eCFR) portal here:

https://www.ecfr.gov...CFR?page=browse

 

For example, searching "olive oil" you can readily find that the MRL for Buprofezin is 3.5ppm in olives and 4.8ppm in olive oil: https://www.ecfr.gov...e40.26.180_1511



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#5 EL BATTAH Bilal

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Posted 28 March 2019 - 11:33 AM

thanks a lot it's better now, i think the list covers only 4 active subtances (In Olive Oil case) and for the others substances a tolerance of 0.01 part per million is established.

 

Is that right ??



#6 Scampi

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Posted 28 March 2019 - 12:28 PM

http://www.internationaloliveoil.org/

 

This may be of help.......Canada requires importers to comply with the standards of the above organization..........it will hopefully give you some more specific details


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#7 pHruit

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Posted 28 March 2019 - 01:00 PM

thanks a lot it's better now, i think the list covers only 4 active subtances (In Olive Oil case) and for the others substances a tolerance of 0.01 part per million is established.

 

Is that right ??

My expertise is Europe I'm afraid, so can't comment more specifically on the number of substances for which tolerances are established - all I can really do is point you to where I'd be looking if I need to try to find this sort of thing out.

I'd be extremely wary of assuming a default 0.01mg/kg limit where no specific tolerance is established, though. This is the approach used in the EU, but my understanding is that the US would generally consider a food to be adulterated if there is detectable (≥0.01mg/kg) presence of a pesticide for which no tolerance has been set, unless there is a specific exemption in place - i.e. in the absence of a tolerance there should be no detectable residue levels.

 

I recall a fairly significant case a few years ago with orange juice / concentrate being imported from Brazil that was found to contain low levels of the fungicide Carbendazim - the FDA acknowledged there was no food safety risk, but as no tolerance was established the product was deemed to be unsuitable for import and from memory there were quite large volumes blocked/rejected at the border. It created quite a headache for the Brazilian processors at the time!



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#8 Scampi

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Posted 28 March 2019 - 01:05 PM

When in doubt, email the FDA and wait on an answer, that's cheaper than having your product rejected at the border


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#9 pHruit

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Posted 28 March 2019 - 01:14 PM

When in doubt, email the FDA and wait on an answer, that's cheaper than having your product rejected at the border

Yes, 100% do this - been very responsive the few times I've had to contact them. Faster than getting info from my local regulators in the UK at times...



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#10 EL BATTAH Bilal

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Posted 01 April 2019 - 10:49 AM

Thanks guys for help, I really appreciate the information and the advices you have provided to me, I think I' will mail the FDA to clarify te situation .

 

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