The Ministry of Agriculture and Rural Affairs issued a reply emphasizing that the detection of pesticide residues in fertilizer products shall be treated as counterfeit pesticides.

On August 18, the General Office of the Ministry of Agriculture and Rural Affairs stated in its “Reply on Legal Issues Concerning the Detection of Pesticide Ingredients in Fertilizer Products” (No. 14 [2020] of the General Office of the Ministry of Agriculture and Rural Affairs) that “Mixtures of fertilizers and pesticides, including fertilizer products containing pesticide ingredients, shall be regulated as pesticides. In accordance with Article 44, Paragraph 2 of the Regulations on the Administration of Pesticides, any pesticide produced without a valid pesticide registration certificate shall be treated as a counterfeit pesticide.”

According to industry analysts, this means that any product registered solely as a fertilizer found to contain pesticide ingredients should be classified as a counterfeit. Meanwhile, the emerging category of “pesticide‑fertilizer” products must be regulated in accordance with the Regulations on the Administration of Pesticides.

Over 40% of pesticides failed to meet standards due to the presence of hidden ingredients. 　 

In recent years, there have been frequent instances of pesticide residues being detected in fertilizers, adjuvants, and other agricultural, forestry, and horticultural products manufactured by non‑pesticide producers, as well as illegal addition of hidden ingredients to formulated pesticide products. According to the results of the first batch of pesticide supervision and sampling inspections released in 2019 by the Shandong Provincial Department of Agriculture and Rural Affairs, among the 415 pesticide samples tested, the failure rate was 4.5%, with counterfeit pesticides—comprising four cases where the labeled active ingredient was not detected and 14 cases involving the unauthorized addition of other pesticide ingredients—accounting for 94.79% of the non‑conforming products. Meanwhile, the Ministry of Agriculture and Rural Affairs’ 2018 pesticide supervision and sampling inspection revealed a failure rate of 6.8%, with 222 samples found to contain unauthorized, concealed additives, representing 40.3% of all non‑compliant samples.

According to the list of illegally added hidden ingredients, it includes prohibited highly toxic pesticides, restricted-use pesticides, highly active products whose patent protection has expired, and certain low‑cost pesticides. At present, common illegal additions include the presence of paraquat in diquat formulations and the inclusion of plant growth regulators—among other pesticide ingredients—in fertilizers.

According to Article 44 of the Regulations on the Administration of Pesticides, a pesticide is deemed counterfeit if the types of active ingredients it contains do not match those listed on its label and in its instructions. In recent years, the Ministry of Agriculture and Rural Affairs has launched and coordinated nationwide special campaigns to combat counterfeit agricultural inputs, conducting targeted inspections of pesticides, fertilizers, seeds, and other products, with particular emphasis on investigating and prosecuting illegal practices such as the unauthorized addition of pesticides.

In practice, during the manufacturing process, most producers use a single production line to process multiple products. If the line is not thoroughly cleaned between batches, residues from the previous product can contaminate the subsequent batch, leading to the detection of foreign pesticide ingredients in the finished formulation—resulting in the product being classified as counterfeit. For example, chlorothalonil has been detected in rodenticide formulations containing tripterygium wilfordii; dichlorvos has been found in trichlorfon; lambda‑cyhalothrin has been identified in cypermethrin; phoxim has been detected in parathion; and acetamiprid has been found in imidacloprid, among other instances.

The current standard is only a group standard.

So, at what level of detection does a product qualify as a counterfeit pesticide? On this issue, mainland China has yet to conduct systematic research or enact relevant legislation, and no national or industry standards exist. However, in Taiwan, the United States, and Europe, maximum residue limits for trace amounts of other pesticide ingredients in formulated pesticide products have been promulgated and enforced for many years.

To standardize the maximum residue limits for trace amounts of other pesticide ingredients in China’s pesticide formulation products and to supplement and refine the impurity‑content requirements in pesticide quality standards, a group standard titled “Maximum Residue Limits for Trace Other Pesticide Ingredients in Pesticide Formulation Products,” jointly proposed and developed by the China Crop Protection Industry Association and the Pesticide Inspection Institute of the Ministry of Agriculture and Rural Affairs, was released in April 2019 and officially came into effect in October 2019.

The promulgation and implementation of this standard provide a practical, actionable criterion for determining whether the impurity pesticide residues in various products meet regulatory requirements; they furnish a basis for both internal quality control within enterprises and market supervision, and offer operational design standards and requirements to help pesticide formulation manufacturers manage cross-contamination during production. This effectively helps prevent the unintended risks posed by trace amounts of other pesticide residues that may inadvertently contaminate pesticide products, thereby safeguarding agricultural production safety, the quality and safety of agricultural products, and ultimately, food safety.

Source: AgroPages World Agrochemical Network