Pesticide Residues 2026: What Changes for Importers and Producers

Key data

Importers and producers of plant-based foods operating in the EU have a new technical obligation from April 14, 2026: to adapt their control protocols to the corrected definitions of two key compounds. The Implementing Regulation (EU) 2026/824 corrects technical errors in the Implementing Regulation (EU) 2025/854 on two specific points that directly affect residue analysis in plant products.

This is not a minor wording change. An incorrect residue definition can make a batch pass or fail an official control analysis. And an incorrect list of goods can leave products unanalyzed that should be analyzed, or vice versa. Both scenarios have real economic and legal consequences.

What does this regulation establish?

Regulation 2026/824 introduces two technical corrections to Regulation (EU) 2025/854:

Aluminum fosetyl is a fungicide widely used in horticultural crops. Its residue definition determines which chemical forms are measured in the analysis and, therefore, whether a product exceeds or not the maximum residue limit (MRL) established.

The trimethylsulfonium cation is a metabolite of glyphosate, the most widely used herbicide in the world. The list of goods that must be analyzed for this compound defines which plant products are subject to specific control for this metabolite.

Economic and operational impact

The corrections have direct consequences in three operational areas:

• Official control laboratories: Must update their analytical methods and result interpretation criteria for fosetyl-Al and trimethylsulfonium in accordance with the new definitions.
• Importers in the EU: Batches of plant products from third countries will be evaluated with the new definitions from April 14, 2026. Certifications issued under the previous criteria of Regulation 2025/854 may not be valid to pass border controls.
• Exporters from third countries: Must adapt their certifications and prior analyses to the corrected definitions to avoid border rejections.

The most immediate economic risk is batch rejection at the border, with associated costs of storage, reshipment or destruction of goods. This is added to the risk of market withdrawal if products have already been marketed and do not meet the new criteria, as well as possible administrative sanctions.

Who does it affect?

• Agricultural producers who use aluminum fosetyl as a fungicide in their crops and market in the EU.
• Importers of plant-based foods in the EU, especially those working with products from third countries where fosetyl-Al or glyphosate are in common use.
• Exporters from third countries that certify their products for the European market.
• Official control laboratories responsible for residue analysis at the border and in the market.
• Agri-food companies with pesticide residue self-control programs in raw materials or finished products.

Practical example

A Spanish importer bringing table grapes from a third country where aluminum fosetyl is routinely applied as a fungicide has residue analyses performed under the criteria of Regulation (EU) 2025/854.

From April 14, 2026, official border control applies the corrected definition of Regulation 2026/824. If the previous definition of fosetyl-Al residue measured a different set of metabolites than what the correction establishes, the same batch may obtain a different result: a product that previously passed control could exceed it or not under the new criteria, depending on the direction of the correction.

To avoid this risk, the importer must request updated analyses from their supplier in accordance with the new definition before batches reach the border. The cost of a border rejection—storage, document management, possible destruction—far exceeds the cost of a preventive analysis.

The same reasoning applies to an operator working with plant products where glyphosate is a common herbicide: if their product now appears on the corrected list of analyzable goods for the trimethylsulfonium cation, it will be subject to controls that were not previously applied to it.

What should companies do now?

1. Identify if your products are affected: Review whether you work with plant products where aluminum fosetyl is applied as a fungicide or glyphosate as an herbicide. If so, this correction directly affects you.
2. Review self-control protocols: Update the definitions of fosetyl-Al residue and the list of analyzable goods for trimethylsulfonium in your internal procedures, aligning them with Regulation 2026/824.
3. Communicate the change to suppliers and laboratories: Inform your third-country suppliers and the laboratories that perform your analyses that they must apply the corrected definitions. Request updated analyses for pending import batches.
4. Review current certifications: Check whether your batch certifications in transit or pending dispatch were issued under the criteria of Regulation 2025/854. If so, assess whether it is necessary to obtain complementary analyses before border control.
5. Consult with a residue regulation specialist: If you have doubts about how the technical correction affects your specific products, consult with an advisor specializing in pesticide legislation and MRL before batches reach official control.