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?