Agriculture & Fishing

New MRL-exempt substances in EU food: what changes in 2026

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Equipo Editorial CambiosLegales
01 Apr 2026 7 min 39 views

Key data

RegulationCommission Regulation (EU) 2026/752 of 31 March 2026
Amended legislationAnnex IV of Regulation (EC) No 396/2005 of the European Parliament and of the Council
Publication1 April 2026
Entry into force20 April 2026
Affected partiesFarmers, agri-food industry, food importers and exporters in the EU
CategoryAgriculture and Fisheries / Food Safety
Substances added5 new naturally occurring substances to Annex IV
Key impact: From 20 April 2026, five plant protection substances of natural origin are exempt from maximum residue limits (MRLs) in food upon inclusion in Annex IV of Regulation EC 396/2005. Farmers, the agri-food industry and importers must update their compliance controls before that date to avoid border rejections and non-conformities in audits.

Five plant protection products of natural origin will be exempt from maximum residue limits (MRLs) in food throughout the European Union from 20 April 2026. Regulation (EU) 2026/752, published on 1 April 2026, amends Annex IV of Regulation (EC) No 396/2005, which is the European framework governing MRLs for pesticides in food and feed.

Inclusion in Annex IV is not a minor technical detail: it means these substances are officially considered low risk and are no longer subject to the obligation to comply with a specific MRL. For companies in the sector, this opens a window of regulatory simplification, but also requires updating documentation, control protocols and compliance records before the entry into force date.

5
New natural substances added to Annex IV of Regulation EC 396/2005
20 Apr 2026
Deadline to adapt compliance controls

What does this regulation establish?

Regulation (EU) 2026/752 amends Annex IV of Regulation (EC) No 396/2005, which contains the list of active substances for which no specific MRLs are set because their presence in food is not considered to pose an unacceptable risk to consumers.

The five substances added are:

Common nameTechnical designation
Processed spring onionProcessed Allium fistulosum
Willaertia magna lysateWillaertia magna lysate
Magnesium hydroxideMagnesium hydroxide E 528
Sainfoin in dehydrated pelletsOnobrychis viciifolia in the form of dehydrated pellets
Grape seed extractVitis vinifera L. seed extract

By being included in Annex IV, these substances do not require a specific MRL in order to be used as plant protection products. This simplifies regulatory compliance for those who already used them or plan to incorporate them into their agricultural treatments.

The regulation directly amends Regulation EC 396/2005, which is the reference text throughout the EU for the control of pesticide residues in food of plant and animal origin. Any company operating under that framework must incorporate these changes into its internal procedures.

Economic and operational impact

The main impact is not one of direct cost, but rather operational and compliance-related. Companies that already used any of these five substances in their agricultural processes or included them in their compliance analyses must update their records to reflect the new regulatory status.

The specific effects by type of operator are:

  • Farmers: Those using these plant protection products must verify that their application records and traceability documentation reflect the new framework. The MRL exemption simplifies justification during inspections, but use must still comply with the approved parameters.
  • Agri-food industry: Companies that process or market food to which these substances have been applied must update their product technical specifications and analytical control plans. Failure to do so may generate non-conformities in client audits or certifications (IFS, BRC, etc.).
  • Importers and exporters: This is the group with the greatest immediate risk. Border controls are based on current legislation. If compliance documents do not reflect the new status of these substances, border rejections may occur. The update must be completed before 20 April 2026.

Who is affected?

  • Farmers and agricultural cooperatives that use any of the five substances as a plant protection product.
  • Companies in the agri-food industry that process, package or market food to which these substances have been applied.
  • Food importers from third countries that must demonstrate compliance with European MRL regulations.
  • Food exporters from the EU operating under certifications or contracts requiring compliance with Regulation EC 396/2005.
  • Laboratories and quality control companies that carry out residue analyses in food and must update their regulatory reference panels.
  • Technical advisors and food safety consultants who manage compliance documentation for their clients.

Practical example

A fruit and vegetable exporting company that applies grape seed extract (Vitis vinifera L.) as a plant protection treatment to its crops currently has in its compliance documents a reference to the applicable MRL under Regulation EC 396/2005.

From 20 April 2026, this substance is included in Annex IV, meaning there is no longer a specific MRL to justify: the substance is exempt as it is considered low risk. If the company does not update its technical data sheets, certificates of analysis and declarations of conformity before that date, its shipments may be subject to review at the border by the control authorities of the destination country, who will detect a discrepancy between the documentation submitted and the applicable legislation. The result may be a delay in customs clearance or, in the worst case, rejection of the consignment.

The solution is straightforward: update the compliance documentation to reflect that the substance is listed in Annex IV of Regulation EC 396/2005 as amended by Regulation (EU) 2026/752, with entry into force on 20 April 2026.

Do you need to track this and other regulations?

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What should companies do now?

  1. Identify whether you use any of the five substances: Review your records of plant protection products applied or the ingredients from your agricultural suppliers. The affected substances are processed spring onion, Willaertia magna lysate, magnesium hydroxide E 528, sainfoin in dehydrated pellets and grape seed extract.
  2. Update compliance documentation: Amend technical data sheets, product specifications and declarations of conformity to reflect the new status of these substances in Annex IV of Regulation EC 396/2005, with express reference to Regulation (EU) 2026/752.
  3. Review analytical controls: If your control plans included MRL analyses for these substances, update your regulatory reference panels. The MRL exemption does not remove the traceability obligation, but it does change the evaluation criteria.
  4. Communicate the change to the supply chain: Inform customers, distributors and commercial partners operating under contracts or certifications that reference Regulation EC 396/2005, especially if you export outside the EU.
  5. Complete the adaptation before 20 April 2026: This is the entry into force date. Any shipment or inspection after that date will be assessed under the new regulation. Do not wait until the last week to update your documentation.

Frequently asked questions

Which substances are exempt from MRLs under Regulation EU 2026/752?

The five substances added to Annex IV of Regulation EC 396/2005 are: processed spring onion (processed Allium fistulosum), Willaertia magna lysate, magnesium hydroxide E 528, sainfoin in dehydrated pellets (Onobrychis viciifolia) and grape seed extract (Vitis vinifera L. seed extract). By being included in Annex IV they are exempt from specific maximum residue limits as they are considered low risk.

When does Regulation EU 2026/752 on MRLs enter into force?

The Regulation was published on 1 April 2026 and enters into force on 20 April 2026. Affected companies must have their compliance controls updated before that date.

What must food importers and exporters do in response to this change?

Import and export operators must update their compliance controls to include the five newly exempt substances. Failure to do so may result in border rejections if the new regulatory status of these substances is not correctly reflected in the control documents.

What does it mean for a substance to be listed in Annex IV of Regulation EC 396/2005?

Annex IV of Regulation EC 396/2005 lists substances considered low risk for which no specific maximum residue limits are set. Companies using these plant protection products are not required to comply with a specific MRL, but must verify that the use of these substances is in line with the newly established parameters.

Which sectors does Regulation EU 2026/752 affect?

It directly affects farmers using these plant protection products, the agri-food industry that processes or markets food to which these substances have been applied, and food importers and exporters in the EU that must update their compliance controls to avoid border rejections.

Official source

View full regulation at the official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, please consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32026R0752



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