  
  
G/C/W/807   
12 May 2022 
(22-3721) Page: 1/1 
Council for Trade in Goods  Original: Spanish  
 
  
COUNCIL FOR TRADE IN GOODS  
EUROPEA N UNION  – IMPLEMENTATION OF NON -TARIFF BARRIERS ON  
AGRICULTURAL PRODUCTS1 
Communica tion from Peru 
The following communication , dated 25 April 2022, is being circulated at the request of the 
delega tion of Peru. 
 
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1. Peru wishes to support this trade concern regarding the implementation of non -tariff barriers 
by the EU, which in practice are unjustified barriers restricting trade in agr icultural products.  
 
2. As has been mentioned on a number of occasions in the SPS Committee, the hazard -based 
approach used by the EU for assessing any maximum limit for pesticide residues results in such 
limits being more restrictive than necessary and at  the same time does not take into account the 
provisions of the SPS Agreement, which establishes the need for measures to be based on a risk 
analysis.  
 
3. This situation would be even more concerning, given the EU's moves to take into consideration 
environmental aspects as a factor for future pesticide risk assessments, despite the fact that there 
is no technical basis for such policy.  
 
4. We note that non -tariff barriers do not only refer to maximum residue limits for pesticides, 
since the EU is also establishing maximum levels for contaminants that deviate from those 
established under the Codex Alimentarius and are substantially lower, as in the case of cocoa 
derivatives. Regarding other foods, Peru has also approached  the EU bilaterally to request 
information on the process for the adoption of new maximum levels for contaminants and for it to 
provide adequate time frames for their implementation, given that mitigation measures vary and 
are effective after a subsequent extended period of implementation.  
 
5. Peru requests the EU to take into consideration the concerns raised in this Council and the 
SPS Committee, to ensure that its policies are aligned with the provisions of the SPS Agreement and 
avoid any further unneces sary disruptions to trade.  
 
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1 This statement was made by the delegation of Peru under agenda item 6 during the meeting of the 
Council for Trade in Goods that took place on 21-22 April 2022.  