2.10. Pesticide Residues

Despite the protective barrier of the cacao pods and shells (if undamaged), the use of pesticides, and other plant protection products, on cacao trees and in cocoa stores can lead to the presence of residues in cocoa products. There is a growing body of knowledge and increasing public awareness of this subject which have led to limits being set for the maximum level of pesticide residues in raw materials including cocoa beans. The cocoa industry requires that all supplies of cocoa beans and products comply with these limits and will monitor closely the levels of pesticide residues on all cocoa raw materials.

In Europe, all cocoa and cocoa products must comply with EU Regulation 396/2005 and its amendments, which set out Maximum Residue Levels (MRLs) of pesticides in or on food or feed of plant and animal origin. Where no specific MRL for a particular pesticide has been established, or in the case of pesticides that are banned in Europe, the default level of 0.010mg/kg is applied. Note that the methods of sampling and analysis, and the interpretation of the results, for official control in the EU are established in Regulation (EU) 2026/765 which will come into force 1st January 2027 (repealing Directive 2002/63/EC)

For residues of pesticides which are carcinogenic, mutagenic and reprotoxic (CMR), measurement uncertainty cannot be taken into consideration, in many European member states, when assessing compliance of a result. For cocoa, the MRLs are determined on “beans after removal of shells”, as referred to in Regulation EC 178/2006.

However, in some other countries MRLs are determined on whole beans (i.e. prior to removal of the shell or seed coat). Lists of the strategic pesticides used on cocoa, with their current MRLs, and also those pesticides that MUST NOT be used on cocoa can be found in the Pesticide Use in Cocoa: Practical Manual (Bateman and Crozier, 2023) available from https://www.icco.org/icco-documentation/pesticide-use-in-cocoa-practial-manual-fourth-edition/. Note that updates to the approval status and changes to MRLs since 2023 have been made to the knowledgebase version of this publication available from https://pm.cocoaquality.eu/

What are MRLs?

The Maximum Residue Level (MRL) is the highest amount of a pesticide residue that is legally tolerated in or on food when pesticides are applied correctly. The amounts of residues found in food must be safe for consumers and must be as low as reasonably achievable (ALARA).

The MRL for a given crop/active ingredient combination is usually determined by measurement during a number of field trials, where the crop has been treated according to Good Agricultural Practice (GAP) and an appropriate pre-harvest interval (ie the time between the last pesticide application and harvest) has elapsed.

For many pesticides, however, this is set at the lowest limit of analytical determination (Limit of Determination, LOD) – since only major crops have been evaluated and understanding of the Acceptable Daily Intake (ADI) is incomplete (i.e. producers or public bodies have not submitted MRL data – often because these were not required in the past).

In Europe, the default lowest limit (LOD) is 0,01 mg/kg and this MRL applies for any active ingredient/crop combinations unless they are specified in an annex of EU Reg. 396/2005 (see the EU Pesticides Database)

Figure 9. 2023 Edition Pesticides Use In Cocoa

The issue of pesticide residues is kept under constant review by food safety and environmental protection agencies.

Information on active compounds that are under review, and newly introduced maximum levels and restrictions can be found on various websites including:

Pesticides can have an important role in controlling the pests and diseases that would otherwise lead to high percentage loss of the cocoa crop, or adversely affect its quality.

However, they must be used appropriately (the right pesticide at the right time at the right dosage), safely and responsibly, as part of an Integrated Crop and Pest Management (ICPM) strategy, which minimises risks to the operator, the farmer and his community, the environment and the consumer.

Pesticides can also be used as fumigants to control storage pests and prevent deterioration of quality during transportation and storage.

See sections Part III Pest and Disease Control and Storage.

COCOA GAP - MITIGATION OF PESTICIDE RESIDUES IN COCOA PRODUCTION

Usage must comply with all national and international regulations
Spraying as part of Integrated Crop and Pest Management (IPM)
Manage tree architecture to allow for air circulation and easy access to pods when applying pesticides
Correct equipment, timing (respecting any pre-harvest interval) and target.
Recommended pesticide
Even application
Personal protective equipment
Correct disposal of containers
Avoid pesticide cross-contamination (drying tables, storage areas, etc.)

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COCOA GAP - MITIGATION OF PESTICIDE RESIDUES DURING FUMIGATION, STORAGE & TRANSPORT

Usage must comply with all national and international regulations
Cocoa stored according to Good Warehousing Practice
Correct equipment, timing and target
Recommended pesticide
Personal protective equipment
Correct disposal of containers
Monitoring and assessment to ensure effectiveness
Prevent cross-contamination from pesticides used on other crops or to control termites, for example on pallets

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