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Multiple Source Substances - Regulation (EC) No 396/2005 and its Limitations

Birgit Christall, Monika Beutgen, Martin Einig, Marcus Girnau, Tobias Teufer

Substances for which different sources of entry in food exist, the so-called “multiple source substances”, repeatedly lead to problems in the control of food by authorities and food business operators. One reason is that for these substances it is often not clear to which legal area they belong, e.g. either to the pesticide or the contaminant legislation. The current approach to categorize findings of each substance which is listed in EU Pesticides Database of EU harmonized active substances of plant protection products always as pesticide residue – without considering the concrete source of entry in the concrete product -, does not seem to be justified. In the article, proposals are given how to deal with multiple source substances in food in a more appropriate way.

Birgit Christall, Lebensmittelverband Deutschland e.V., Monika Beutgen, Deutscher Tee und Kräutertee Verband e.V., Martin Einig, Fachverband der Gewürzindustrie e.V., Marcus Girnau, Lebensmittelverband Deutschland e.V., Tobias Teufer, KROHN Rechtsanwälte PartGmbB. English version of a paper that was published in German in ZLR 2022, 569.


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