Report on the Organic Monitoring Program of Baden-Württemberg 2019

The Federal State of Baden-Württemberg has been conducting a special monitoring program on organically produced foods since 2002. This monitoring is associated with Baden-Württemberg’s overall concept of promoting organic farming. Organic products are systematically tested for residues and contaminants, as well as other relevant issues. The goal of the organic monitoring program is to prevent fraud by better tracking down cases of improper labeling in this fast expanding market and to strengthen consumers’ confidence in the quality of organically produced foods.

 

Analytical Results from Organic Food Investigations

Detailed information (including results tables) can be found in the German version of the monitoring report.

 

Following is a translation of the topic “Residues from pesticides and specific contaminants in plant-based-foods”.

 

Cover image.

 

Residues from Pesticides and Specific Contaminants in Plant-Based Foods

Introduction

In 2019 a total of 358 samples of plant-based foods from organic cultivation were analyzed for residues of plant-protection substances and specific contaminants. The underlying spectrum of substances routinely analyzed for every sample comprised more than 750 components (active substances and metabolites or degradation products, as well as specific contaminants such as perchlorate, melamine and cyanuric acid).

 

Info Box

Expansion of the Investigative Spectrum and Evaluation of the Data

This year, as in the previous five years, the QuPPe method was routinely used on all samples in order to detect very polar substances that the QuEChERS multi-method cannot capture (see, in German, http://quppe.eu). Representatives of this group include, among others, fosetyl, phosphonic acid, chlorate and perchlorate, but also trimesium (trimethlysulfonium).

To enable the comparison of investigative results for individual years in the future, only specifically chosen, purely chemical/synthetic pesticides, not contaminants, will be included in the evaluation.

 

The following substances were listed separately:

  • Substances authorized for use in organic farming: azadirachtin, piperonyl butoxide, pyrethrum, spinosad (see Excursus)
  • Nicotine: different modes of entry possible (see Info Box)
  • Trimethylsulfonium cation: different modes of entry possible or possible formation by processing
  • Fosetyl/phosphonic acid: found in fertilizers and fungicides, long retention time of phosphonic acid in plants/shrubs (see Info Box)
  • Chlorate, perchlorate: different modes of entry possible (see Info Box).
  • Melamine (contaminant): found in fertilizers and as a degradation product of cyromazine
  • Morpholine: additive (used as a carrier substance or emulsifying agent)

 

The following substances will not be considered:

  • Substances occurring naturally in plants: gibberellic acid and other plant hormones (abscisic acid, jasmonic acid, etc.)
  • Bromide: can originate geogenically; amounts < 5 mg/kg assessed as „natural“ amount

 

Fresh Foods

As in previous years, fresh organic fruit and vegetables performed significantly better in 2019 than conventionally produced products. There were no detectable pesticide residues in about 77 % of the organically grown samples (in 2018, approx. 60 %; 2017, 50 %; 2016, 65 %; 2015, approx. 60 %; 2014, 52 %; 2013 and earlier: 60 to 77 %). The findings for this reporting year correspond to the situation in individual years before 2013.

 

The percentage of samples containing residues of multiple pesticides was 6.4 %, again significantly lower than that of previous years (10.5 % in 2018; 15 % in 2017; 19 % in 2016 and 2015; 21 % in 2014; 12 % in 2013; and 10 % in 2012). After a large spike in 2014, in part contingent on the expansion of the depth of investigations (the analytical spectrum), the numbers over the last five years have dropped significantly, returning to earlier rates.

The detected residues were mostly in trace amounts (< 0.01 mg/kg), considerably lower than the concentrations usually found in a harvest where pesticides were used. All in all, the rate of violations in fresh, organically produced foods has stabilized at a low level over the last few years, and has dropped significantly since the beginning of the organic monitoring program more than 18 years ago.

 

In 2019 two fruit samples (lemons from Italy and pears from the Netherlands) and one vegetable sample (curled lettuce from Germany) were judged to have been falsely labeled organic, due to the detection of increased levels of pesticide residues.

 

The rate of violations in this reporting year was 2.4 % for organic fruit and 1.0 % for organic vegetables. The rate of violations for all organic fresh foods in the years from 2011 to 2018 was always well under 5 %, while the rates before 2010 were significantly higher, with numbers as high as 8.5 %. In this reporting year (overall rate of 1.5 %), as in past years, there were neither any accumulation of violations for organic fruits, nor any other irregularities in single cultures detected. In the years before 2009 there were intermittent anomalies found: herbicides in broccoli and carrots from Italy, the fungicidal substance fosetyl in cucumbers from different countries, surface treatment substances and acaricides in citrus fruits, and sprout inhibitors in potatoes.

 

Average Pesticide Amounts in Fresh Foods

Average pesticide amounts found in the samples can be an indication of the presence of plant protection substances, as the following tables show.

 

Average pesticide residues per sample (in mg/kg)

Fruit
2013
2014
2015
2016
2017
2018
2019
Organically produced samples
0.008
0.005
0.002
0.001
0.002
0.004
0.003
Conventionally produced samples (excluding surface treatment substances or preservatives, phosphonic acid and bromide)
0.32
0.42
0.35
0.43
0.45
0.40
0.45

 

Vegetables
2013
2014
2015
2016
2017
2018
2019
Organically produced samples
0.004
0.001
0.002
0.003
0.003
0.008
0.002
Conventionally produced samples (excluding phosphonic acid and bromide)
0.38
0.32
0.49
0.46
0.36
0.46
0.41

 

The average amount of pesticide residues detected in all analyzed organic fruit and vegetable samples this reporting year was 0.003 and 0.002 mg/kg, respectively, when all organically labeled samples (including those with false labeling) are included in the calculation. Exclusion of the samples that were in violation, suspected of being conventionally produced or cross-bred with conventional products, yielded averages of 0.002 and 0.001 mg/kg respectively. These average sum amounts have remained low over the last years (see table).

 

The averages for conventionally produced fruit lay at 0.45 mg/kg (excluding surface treatment substances, phosphonic acid and bromide) and for vegetables at 0.41 mg/kg (excluding phosphonic acid and bromide). The reason for the higher amount of pesticide is due to the application of chemical plant protection substances that are authorized for conventional cultivation, the residues of which are often unavoidable in the treated plant cultures. A detailed body of regulations provides consumers with a measure of safety, however, as long as the maximum residue levels are not exceeded.

 

Since the use of chemical synthetic pesticides is not permitted in organic cultivation, very few samples, if any, tend to have residues over 0.01 mg/kg. The organic products differ significantly from conventional goods in terms of contamination from pesticide residues, which the organic monitoring program has clearly demonstrated over the past 18 years.

 

Processed Foods

The rate of violations (due to false organic labeling) among processed foods in this reporting year was 2.6 %, about twice as high as the rate for fresh fruit and vegetables (1.5 %). This is similar to the rate from last year (2018: 2.2 %), thus continuing the positive low trend compared to previous years; over the past seven years the rate ranged from 2.6 % to 7.0 % and before 2011 it was > 8 %.

 

It must be considered, however, that the focus on particular processed organic products changes from year to year and that short-term projects are carried out on this product group, which has only recently come into sharper focus. Therefore, the comparability of violation rates from year to year and over the entire course of the organic monitoring program is limited.

 

Individual anomalies (in single food groups) among the processed foods analyzed in 2019 were found in frozen herbs and dried herbs/spices. These involved one sample each of frozen dill and chives due to an elevated quantity of chloridazon (herbicide) and/or its degradation product chloridazon-desphenyl, as well as one sample each of dried bay leaves and oregano containing residues of an insecticide and fungicide. As in 2018, this year presented no accumulation of violations (from false organic labeling) in a particular food category.

 

One can also refer to the chapter on “Special Findings”, where results and data on special substances or projects and food groups are handled that are excluded from the explanations. These require a separate observation, either due to their particularities in occurrence, application, possible modes of entry and analytics, or because they present new or separate problems.

 

When making a judgment regarding the amounts of residues in processed foods, valid drying and processing factors for the specific substances must be considered, because the processing of the original product can lead to an increase or decrease of residues (see Info Box regarding processing factors).

 

Info Box

Consideration of Processing Factors

As a rule, Regulation (EC) No. 396/2005 stipulates the maximum levels of plant protection substance residues allowed for unprocessed foods. The amount of pesticide residues in and on unprocessed foods can be affected by processing factors, however. This regulation mandates, therefore, that legal judgments regarding the determined quantities of pesticide residues in processed food take into account such processing factors (e. g. the production of dried fruit and herbs, canned products, wine, flour or bread). In a few cases it is impossible to make a final judgment because processing factors for certain substances or matrices are not always known. When there are low levels of substances in the product, there is also a greater degree of computational uncertainty. These drying and processing factors are not legally binding, however, because no pertinent conclusive legal ordinance exists, nor is there any chart in which they are listed.

 

Overview of Violations

The following table gives an overview of all organic samples analyzed in 2019 for residues of pesticides and their rate of violations, itemized by food group.

 

Overview of organic samples analyzed in 2019
Type of Sample
No. of Samples
Samples with residues > 0.01 mg/kg ²
Average amount per sample, in mg/kg ²
No. samples falsely labeled as „organic“
Samples > MRL³
Vegetables
120
3 (2.5 %)
0.002
1 (1.0 %)
Curled lettuce from Germany (Pendimethalin)
-
-
Vegetable products
16
3 (19 %)
(fresh products)
0.024
(processed)
0.013
(fresh products)
2 (13 %)
Frozen dill and frozen chives from unknown origin (both with Chloridazon, sum, or degradation product Chloridazon-desphenyl)
-
-
Fruit
83
5 (6.0 %)
0.003
2 (2.4 %)
Lemons from Spain (Pyriproxyfen); Pears from the Netherlands (Chlormequat-chloride, sum)
-
-
Fruit products
14
-
(fresh products)
0.011
(processed)
0.003
(fresh products)
-
-
-
-
Fresh mushrooms and their products  
9
-
(fresh products)
0.005
(processed)
0.002
(fresh products)
-
-
-
-
Potatoes and Starchy Plant Parts
10
-
0.001
-
-
-
-
Legumes (dried), oil seeds, nuts, soy products
17
-
0.002
-
-
-
-
Cereals
27
2 (7.4 %)
0.002
-
-
2 (7.4 %)
2x Barley corns from Germany (Dikegulac)
Cereal products
6
-
0.001
-
-
-
-
Fats & Oils
13
-
0
-
-
-
-
Spices
8
4 (50 %)
(fresh products)
0.12
(processed)
0.025
(fresh products)
2 (25 %)
Bay leaves from France (Acetamiprid); Oregano, rubbed from Peru (Tebuconanzole)
1 (13 %)
Paprika powder from Spain (Biphenyl)
Baby food
5
-
0.001
-
-
-
-

1) No calculated percentages for sample sizes < 5

2) With consideration of processing factors for the respective processed products and without consideration of the separately listed substances found in the section „Special Findings“

3) MRL = Maximum residue level established by Regulation (EC) No. 396/2005 and the Dietary Regulation (for baby food); formal objections due to chlorate and perchlorate not included – see separate section on this topic.

 

Excursus

Detected Substances Authorized for Organic Farming in 2019

Among the substances that are authorized under European Organic Regulations (EC) No.s 834/2007 and 889/2007 (see positive list in Annex II) and that are tested and detected regularly are the insecticides Azadirachtin A, Pyrethrum (Pyrethrins), Spinosad and the synergist Piperonyl butoxide. Piperonyl butoxide strengthens the insecticide effect of, e. g. pyrethrins, but has no insecticidal effect itself.

The substance Rotenone is meantime no longer authorized for use in ecological farming, but was not found in any of the analyzed samples.

 

The following table shows the substances authorized for organic farming that were found in the samples analyzed in 2019:

 

Substance
Frequency
Product
Amount [mg/kg]
Azadirachtin A
5
Basil
Strawberry
Bell pepper
Tomato (2 samples)
0.011
0.007
0.007
0.005/ 0.020
Pyrethrum
3
Bell pepper
Coriander (fresh)
Parsley
0.017
0. 27
0.076
Piperonyl butoxide
2
Fig, dried
Coriander (fresh)
0. 012
0.007
Spinosad
13
Aubergine
Pear
Blackberry
Bell pepper
Cucumber (2 samples)
Paprika powder
Table grapes (2 samples)
Smoothie (Pear-Orange)
Tomato (3 samples)
0.002
0.004
0.18
0.015
0.007/ 0.026
0.008
0.004/ 0.008
0.003
0.004/ 0.008/ 0.011

 

The frequency of detection for these substances was 9.9 % of the total 445 analyzed samples (8.6 % in 2015; 10.4 % in 2014). Other substances permitted in organic farming such as natural oils, sulphur, copper or iron salts were not included within the scope of these analyses.

 

Special Findings

In the following section residue data and results for special substances or projects/food groups are presented that were excluded from the observations made thus far. They require individual consideration, either due to unique characteristics regarding their existence, applications, possible modes of entry and analysis, or because they present new or special problems.

 

Nicotine

Info Box

Nicotine

Nicotine is a neurotoxin that is harmful to humans and, in higher amounts, to insects (insecticide). It can occur naturally in plants of, e. g. the nightshade family (solanaceae); however, except for tobacco plants, the amount is low. This substance is among the most poisonous pesticides ever authorized for use in Europe. Although nicotine is still used to some extent in third countries (as an active ingredient in pesticides or for the preparation of tobacco), it has been banned in Europe from use in pesticides since 2010, as a result of its high toxicity (acute reference dose: 0.0008 mg/kg bodyweight). Exposure to nicotine can still come from contact with smokers, however. Regardless of its path of entry, nicotine falls under the area of applications in Regulation (EC) No. 396/2005.

 

CVUA Stuttgart published the report “Nicotine from tobacco – a ‚natural‘ substance against plant pests?“ on the topic of tobacco brew.

At the beginning of 2019 CVUA Stuttgart published another report on this topic, entitled “Nicotine in Food: What Does Smoking Have To Do With It?“. The content was two-fold, including analytical results as well as model trials that showed to what extent relevant amounts of nicotine can end up on food when a person smokes and then comes into contact with food.

 

The Chemical and Veterinary Investigations Office (CVUA) Stuttgart established a refined method with preliminary screening for analyzing the parameters of nicotine in fruits and vegetables. In this reporting year a total of 358 samples from organic cultivation were analyzed for nicotine. Of these, 13 samples (3.6 %) contained nicotine > 0.01 mg/kg, compared to 9 of 355 samples in 2018 (2.5 %) and 19 of 324 samples in 2017 (5.7 %). None of the samples was in violation due to an exceedance of the maximum residue level. In 2018 one sample (0.3 %) was in violation, and in 2017, four samples (1.2 %).

 

Two samples (0.6 %) exceeded the limit, albeit without verification within the measurement uncertainty (iceberg lettuce and fresh spinach leaves, both from Germany). These cases were highlighted in a report drawing attention to the increased residue levels. In 2018 there were also two samples (0.6 %) that were reported for violation.

It is important to note here that nicotine residues can have various paths of entry (see Info Box) that are to be considered and discussed. An overview of the analyzed samples containing detectable amounts of nicotine, itemized by matrix, is presented in the following table.

 

Residues of Nicotine in Samples from Organic Farming (2019)
Matrix / Type of Food
Amount of Nicotine [mg/kg]
Coriander (fresh)
Iceberg lettuce
Spinach
0.016
0.016
0.013
Moringa oleifera powder (4x)
0.052/ 0.054/ 0.080/ 0.23
Apricot, dried
Fig, dried
0.024
0.012
Wild mushrooms, dried (mixed forest mushrooms)
0.34
Bay leaf
Pepper, black
0.029
0.024
Moringa tea
0.13

 

In 2017, due to conspicuous, low-level findings (< 0.01 mg/kg) of nicotine in plant-based foods, we carried out model trials to determine to what extent the consumption of tobacco could lead to the transfer of nicotine from a smoker’s hands to food (see the 2017 organic monitoring report). The experiments showed that, shortly after having smoked a cigarette, measurable amounts of nicotine could be transferred from the smoker’s hands onto fruits and vegetables. The transfer of nicotine to moist foods was even higher, reaching the low-set, legal maximum residue levels in some cases.

 

CVUA Stuttgart reports on possible contaminants and sources of contamination; however, since the modes of entry and/or the cause of detected residues are normally not known, the labeling of such foods as „organic“ are not judged to be fraudulent in these cases.

 

Regardless of its mode of entry, however, nicotine is subject to the MRL established by Regulation (EC) No. 396/2005. Analyses of nicotine residues will continue in 2020.

 

Trimethylsulfonium cation (Trimesium)

In 2019 all 358 samples of organic produce were analyzed for residues of the substance trimethlysulfonium cation (trimesium).

 

Trimethlysulfonium cation is listed in Regulation (EC) No. 396/2005 as a substance that forms as a result of the use of glyphosate. Trimesium is not formed as a result of the usage, however, but rather exists in plant-protection substances as a counterion to glyphosate; it is already in the completed formulation. Such types of pesticides are still authorized for use in non-EU states, but no longer within the EU. Due to its particular properties, this substance cannot be integrated into the investigative spectrum of the QuEChERS multi-method; it requires its own processing and analytical method.

 

In 2019 residues of trimethlysulfonium cation were detected in 11 (3.1 %) samples ((6 of 355 (1.7 %) in 2018; 28 of 324 (8.6 %) in 2017): None of these were verified to be over the maximum residue level (with consideration of drying factors), and therefore none were formally objected to. One sample of moringa oleifera powder was nominally over the MRL, but this was unverified. There were also no anomalies for this substance in the previous year, while in 2017 there were still 10 of 324 analyzed samples (3.1 %) in violation.

 

The following table shows an overview of the analyzed samples with determinable residue amounts, itemized by matrix.

 

Residues of Trimethlysulfonium Cation in Samples from Organic Cultivation (2019)
Matrix / Type of Sample
Amount of
Trimethlysulfonium Cation [mg/kg]
Moringa oleifera powder (4x)
0.015/ 0.025/ 0.040/ 0.061
Moringa tea
Herbal tea (mixed)
Fruit tea (mixed, flavored)
0.025
0.030
0.12
Paprika powder (2x)
0.028/ 0.066
Tomato (strained, canned)
0.005
Smoothie
0.008

 

There are indications, however, that trimethlysulfonium (trimesium) occurs as a contaminant in tea and dried (processed) foods as a result of processing methods. Further research into the causes is necessary, in order to account for this situation in any likely judgments that may be made regarding these residues in organic foods.

 

Reports on such findings point to possible paths of entry and formation in the particular matrix in question. Regardless of its paths of entry, trimethlysulfonium cation, as well as the aforementioned nicotine, falls under the applications area in Regulation (EC) No. 396/2005 and is subject to the maximum residue limits provided therein. Trimesium will be further analyzed in 2020.

 

Phosphonic Acid / Phosphonates / Fosetyl

In this reporting year a total of 358 samples from organic culture were analyzed especially for the fungicidal substances fosetyl and phosphonic acid. Regulation (EC) No. 396/2005 lists the substances as sum parameters of fosetyl (sum of fosetyl and phosphonic acid and their salts, expressed as fosetyl).

 

It is important to note that residues from phosphonic acid can have various causes and therewith various (possible) paths of entry (see Info Box on phosphonic acid and fosetyl). Residues can thus stem from applications that don’t serve as plant protection.

 

Neither of these substances is integrated into the investigative spectrum of the QuEChERS multi-method due to their particular properties; they require their own processing and analytical methods.

 

Info Box

Phosphonic Acid and Fosetyl

Both fosetyl and phosphonic acid are fungicides that are permitted for use in the EU and fall under the applications area of Reg. (EC) No. 396/2005, regardless of their path of entry. Neither of these substances is authorized for use in organic farming, but there are current discussions regarding the future inclusion of phosphonic acid in the positive list of substances authorized for use in organic farming in Annex II of the EU Organic Ordinance.

 

Phosphonic acid can be detected as a result of the use of a fungicide that contains potassium phosphonate or fosetyl aluminum. It can also result from the use of a phosphonate-containing fertilizer. This application is no longer possible, however, because phosphonate was classified as a fungicide (pesticide substance) in the harvest year of 2014. High levels of phosphonic acid could also stem from an earlier application, because plants tend to retain this substance for a long time, possibly even years. There is evidence that plants store phosphonic acid and only gradually release it over a period of time.

 

The following table shows an overview of the samples with detectable residues, itemized by individual product groups or matrices.

 

Residues from phosphonic acid and/or fosetyl in samples from organic production (2019)
Matrix / Type of Sample
Amount of
Phosphonic Acid [mg/kg]
Sum Fosetyl [mg/kg]
(Sum of Fosetyl and Phosphonic Acid, expressed as Fosetyl)
Clementine
0.17
0.23
Ginger, fresh (5x)
0.065/ 0.16/ 0.18/ 0.24/ 0.32
0.087/ 0.21/ 0.24/ 0.32/ 0.43
Apricot, dried
Fig, dried
Plum, dried
0.18
0.50
0.18
0.24
0.67
0.24
Basmati rice
0.14
0.19
Soy flakes
0.12
0.16
Pepper, black
12.5
16.8
Smoothie (Mango-Banana)
0.22
0.30
Pear juice (fruit orchard)
Pomegranate juice
Orange juice
0.29
0.32
0.39
0,.39
0.43
0.52
White wine (Riesling, 2x)
Red wine (table wine)
0.050/ 0.16
1.5
0.067/ 0.21
2.0
Baby food (Fruit preparation; Fruit cereal preparation in jar)
0.030/ 0.16
0.040/ 0.21

 

In 2019 a total of 21 of the 358 samples (5.9 %) contained residues, whereby a significant decrease can be seen over the past few years (8.7 % in 2018; 8.3 % in 2017; 14 % in 2016; 15 % in 2015; 19 % in 2014; and 24 % in 2013).

 

These residues occurred in a variety of different matrices, from diverse countries of origin, and thus cannot be limited to single types of food or individual countries. There was a very wide range of detectable levels of phosphonic acid, from trace amounts of less than 0.03 mg/kg to a peak value of 12.5 mg/kg in a black pepper sample and 1.5 mg/kg in a sample of red wine.

 

Also of interest is the fact that only residues from phosphonic acid were found in all of the analyzed samples, whereas no residues of fosetyl per se were detectable. This points to the likelihood of a fertilizer application, as was also the case in previous years.

 

Because the source of the phosphonic acid residues can‘t be determined in the laboratory (see Info Box on phosphonic acid and fosetyl), 13 samples with residue amounts > 0.1 mg/kg (compared with 22 cases in 2018, 21 in 2017 and 43 in 2016) were highlighted in a report with the goal of raising awareness among the producers, so that they would attempt to identify the possible paths of entry.

 

In this reporting year the maximum residue levels for fosetyl (sum of fosetyl and phosphonic acid and their salts, expressed as fosetyl) stipulated by Regulation (EC) No. 396/2005 and the dietary regulation (for baby food) was exceeded in two of the 358 (0.6 %) analyzed samples. These were samples of fruit preparations for babies and young children, for which the dietary regulation issued a maximum of 0.01 mg/kg.

 

It is also known, however, that the residue situation for phosphonic acid in raw materials used in the production of food for babies and young children is still problematic, and that a substitute, non-contaminated raw material (even in organic products) is not necessarily available. So far, however, there have been no exceptional or transitional provisions for this issue.

 

Chlorate and Perchlorate

In 2019 all 358 samples from organic cultivation were analyzed for chlorate and for the environmental contaminant perchlorate (see Info Boxes).

 

The following table presents an overview of the analyzed samples with detectable amounts, itemized by matrix. For reasons of clarity, only samples containing chlorate in amounts > 0.01 mg/kg (formal MRL) and perchlorate > 0.05 mg/kg (lowest EU reference value) are included in the chart. An explanation of the results follows.

 

Quantities of Chlorate and Perchlorate in Organic Samples (2019)
Matrix / Type of Sample Quantity of
Chlorate [mg/kg]
Quantity of
Perchlorate [mg/kg]

Basil, fresh
Mangold
Rosemary, fresh
Spinach
Coriander
Tomato
Ginger, fresh
Melon (Honey melon)
Aubergine
Endive lettuce
Tablegrape, white
Lemon
Shiitake mushroom, fresh
Sultana
Plum, dried
Dill (frozen)
Tomato (preserved, canned)
Bay leaf (spice)
Cumin
Oregano (dried, rubbed)
Paprika powder
Moringa oleifera powder
Moringa tea
Herbal tea (Mixed)
Fennel-caraway-anise tea
Rooibos tea
Pomegranate juice
Vegetable juice (carrot, ginger, lemon)
Smoothie

0.023/ 0.030/ 0.046
0.014
-
-
0.019
0.011
0.15
0.057
0.018
0.012
0.013
0.012
0.022
0.017
0.039
0.025
0.021
-
-
-
0.084/ 0.34
0.016/ 0.11/ 2.6
-
-
-

-
0.14
0.030
0.048

2.1
0.078
0.058
0.096
-

-
-
-
-
-
-
-
-
-
-
-
-
0.11
0.18
0.083/ 0.32
-
0.081/ 0.18/ 0.36/ 0.60/ 0.73/ 1.4/ 1.5
0.70
0.055
0.099
0.35
-
-
-

 

Perchlorate residues were detected in 60 of the 358 (17 %) organic samples (22 % in 2018; 23 % in 2017; 17 % in 2016; 20 % in 2015; 31 % in 2014; 19 % in 2013) and chlorate was found in 46 (13 %) samples (11 % in 2018; 16 % in 2017; 12 % in 2016; 16 % in 2015; 20 % in 2014; and 26 % in 2013). As was the case with phosphonic acid, these findings were also dispersed over a wide variety of matrices and countries of origin, and could not, therefore, be reduced to individual types of food or countries.

 

Similar to fosetyl and phosphonic acid, the properties of these two substances prevent them from being integrated into the investigative spectrum of the QuEChERS multi-method; they require their own processing and analytical method. Chlorate and perchlorate have been routinely analyzed within the scope of the organic monitoring program since 2013. These substances will also play an important role in investigations in 2020.

 

Perchlorate

In line with the European Contamination Regulation (EEC) No. 315/93, reports on organic samples with elevated levels of perchlorate (> 0.1 mg/kg, based on the fresh product) were submitted, in order to promote investigations into their causation and to encourage measures to minimize the amounts. In 2019 there were 11 (3.1 %) such cases from organic cultivation (1.0 % in 2018; 2.5 % in 2017; 2.4 % in 2016; 2.0 % in 2015; 2.2 % in 2014). These included one sample each of fresh basil, bay leaf, cumin, moringa tea and rooibos tea, as well as six samples of moringa oleifera powder. The basil sample exceeded, with verification, the reference value for perchlo rate of 0.2 mg/kg (for open air cultivation) and 1.0 mg/kg (for greenhouse cultivation), and two of the six samples of Moringa oleifera powder exceeded, without verification, the reference value of 0.75 mg/kg.

 

CVUA Stuttgart addressed the issue of perchlorate seven years ago. With the reduction of fertilizer use, the amounts found in plant-based foods have sunk in the meantime. Nevertheless, the Federal Institute for Risk Assessment (BfR) has recommended a further reduction due to toxicological concerns. Furthermore, the EU Commission plans to establish MRLs under the EU regulation for maximum contaminant levels (Regulation (EC) No. 1881/2006) with a recommendation that was approved with a majority of votes at the end of November, 2019 but which, as of yet (12 May, 2020), has not been published in the EU Official Journal. These maximum levels are therefore not yet valid. These newly established EU-wide MRLs are an important step and represent a major success for consumer and health protection, for which CVUA Stuttgart has played a meaningful role.

 

Info Box

Perchlorate

Perchlorates are the salts of perchloric acid. They are generally soluble in water, and exist permanently in the environment. The industrial use of perchlorates is extensive and diverse: they are used in the metal processing industry, in paper finishing, as a diuretic and oxidant, and as explosive and incendiary devices. According to a report by the Federal Environment Agency, this widespread industrial use of perchlorate could be a cause of food contamination. Perchlorate finds its way into the food chain via, e. g. contaminated sludge that is used in agriculture (not, however, in organic agriculture) or by other components from such processes. It can also be assumed that these substances are found ubiquitously in small concentrations in rain water and contaminated environmental compartments such as in the water cycle and soil. It is also known that perchlorates occur from fertilizers and artificial irrigation. Analyses conducted on fertilizer based on chile saltpeter revealed high levels of perchlorate. Particular fertilizers used especially in greenhouse cultivation cause the enrichment of perchlorate in soil.

 

Because perchlorate is a contaminant, not a plant protection substance, there was and is no legal maximum residue level established for it. Based on recommendations by the EU Commission in March and June of 2015, however, the Standing Committee for Plants, Animals, Food & Feed (SCPAFF) set temporary reference values for perchlorate in food (between 0.02 and 1.0 mg/kg), in order to ensure the marketability of food products. Foods containing residues of perchlorate under these reference values are therewith marketable in all member states. These reference values are now losing their validity, however, given the above mentioned new legal maximum levels.

 

Chlorate

A total of 25 (7.0 %) of the 358 analyzed samples (3.9 % in 2018; 6.8 % in 2017; 6.2 % in 2016; 11 % in 2015; 16 % in 2014) contained chlorate residues > 0.01 mg/kg. Although there are known possible paths of entry, it cannot be said with absolute certainty where the amount in a particular sample came from (see Info Box on chlorate). Samples with verified MRL exceedances (chlorate values > 0.02 mg/kg with consideration of processing and drying factors) were officially reported to be in violation. In 2019, there were 13 (3.6 %) such cases (3.6 % in 2018; 3.1 % in 2017; 1.9 % in 2016; 3.3 % in 2015; 7.3 % in 2014). These included three cases of fresh basil, one each of honey melon, fresh ginger, shiitake mushroom, frozen dill, paprika powder, pomegranate juice, mixed vegetable juice and smoothie, as well as two cases of moringa oleifera powder.

 

In 2015 the European Food Safety Authority (EFSA) published new toxicological assessments regarding chlorate residues in food (acute reference dose of 0.036 mg/kg bodyweight and day). Based on these assessments, none of the analyzed samples exceeded these health-based reference values. That means none exhausted the values by more than 100 %, and posed thereby no chronic or acute health problems.

 

Info Box

Chlorate

Chlorates are effective as both herbicides and biocides. Since 2008, however, chlorate is no longer authorized for use as a pesticide* in the EU. Sodium chlorate may also no longer be used in biocide products.

 

The definition for „pesticide residues“ in Regulation (EC) No. 396/2005 also encompasses residues from pesticide substances in food (including substances no longer authorized) that have pathways other than from the use of plant protectant products (so-called dual-use substances), such as the case of chlorate in food. Chlorate is thereby covered by the EU-wide valid default MRL of 0.01 mg/kg, in accordance with Reg. (EC) No. 396/2005. In 2017 in Germany maximums of 70 µg/l chlorate for long-term use and 200 µg/l chlorate for short-term dosages were established for drinking water when the disinfection could not be otherwise guaranteed**.

 

The presence of chlorate in food can result not only from its use as a pesticide, but also due to environmental pollution (contaminated sprinkling- or irrigation water and soil), or as a residual of food production techniques, including methods used in farming, manufacturing, processing, preparation, or treatment. The application of biocides, from which chlorate can result, is another possible source of contamination. In general, chlorate can be formed as a by-product of the disinfection of drinking/ non-potable water with chloric gas, hypochlorite, or chlorine dioxide.

 

Chlorate inhibits, reversibly, the intake of iodine into the thyroid gland and can cause unwanted health effects, especially in sensitive people such as children, pregnant women, or people with thyroid dysfunction. In addition to affecting thyroid function, chlorate can also damage the erythrocytes (formation of methaemoglobin, haemolysis)***. An application of chlorate in the food chain should therefore be further reduced.

 

The EU member states carried out a several years long monitoring program to determine the degree of contamination in food and drinking water, in order to provide data for a toxicological evaluation by the European Food Safety Authority (EFSA). Specific MRLs were then to be established based on this information. New maximum levels for chlorate have meanwhile been adopted, and, after many years of discussion, will be legally valid in the EU in the spring of 2020. The new, specific maximum levels lie between 0.05 and 0.7 mg/kg, depending on the type of food.

 

Sources: Federal Institute for Risk Assessment (BfR)[1], European Commission[2]

* Commission Decision of 10 November 2008 concerning the non-inclusion of chlorate in Annex I to Council Directive 91/414/ECC and the withdrawal of authorizations for plant protection products containing that substance (OJ of the EU L307/7 of 18 November 2008)

** Chlorate in drinking water

*** Federal Institute for Risk Assessment (BfR), recommendations for the health assessment of chlorate residues in foods, from 12 May 2014 (accessed on 8 March 2019)  

 

Hydrogen Phosphide (Phosphine)

These days food is imported to Germany from all over the world. In some cases the goods will have traveled a very long way in ships or other transporters before they arrive. The fumigant hydrogen phosphide is often used in the form of its phosphide salts in sea containers in order to protect the goods from storage pests during transport. The salts applied as solids in dispensers react with moisture in the air, creating hydrogen phosphide which, when released, kills the pests. Phosphine is also used in storage rooms, where dry or dried goods are stored.

 

Phosphine is not authorized for use in organic cultivation, so residues are not to be expected. There are discussions, however, regarding the possibility of (cross) contamination from residual dust of previously stored treated or gassed goods that clings to the inner walls of containers or storage halls and which, when not properly cleaned, can be transferred to untreated goods.

 

In 2019 CVUA Stuttgart analyzed nine organic samples especially for residues of the fumigant hydrogen phosphide (phosphine). In 2017 and 2018 phosphine residues were found mainly in dried legumes (lentils), so this food group was again made a focus of this year’s analyses (see following tables). Phosphine residues were detected in three of the nine (33 %) analyzed samples (14 % in 2018; 12 % in 2017) all of which involved lentils. Two of these samples (22 %; one of unknown origin, one from Turkey) contained only trace amounts of < 3 µg/kg (0.003 mg/kg), whereas the third sample (unknown origin) contained high levels, at 237.3 µg/kg (0.24 mg/kg). This sample was reported for being in violation of regulation (EG) Nr. 396/2005 (MRL of 10 µg/kg; 0.01 mg/kg), due to the validated exceedance of the MRL. In addition, the sample was judged to be fraudulent due to its claim of having been organically produced. In 2019 the rate of violations was 11 % (3.4 % in 2018; 0 % in 2017). As mentioned above, these numbers are only minimally comparable or statistically meaningful, however, as they are limited to a small number of samples with a special annual focus.

 

As a comparison:

 

In 2019 analyses for phosphine residues were conducted on 15 samples from conventional cultivation (see table). Eleven samples (73 %) contained residues in detectable amounts between 10.5 µg/kg and 331.0 µg/kg (0.010 mg/kg – 0.33 mg/kg). Three samples of dried lentils exceeded the legally established MRL of 10 µg/kg (0.010 mg/kg) with verification, and were reported for violation. The MRL exceedance of a further sample was unverified, in consideration of the measurement uncertainty of 50 %. These samples came from Turkey (two), Russia and a country of unknown origin.

 

Compared to last year, there were significantly more residues detected. It is important to note, however, that the limit of detection was lowered in 2019 so that low levels could also be determined.

 

CVUA Stuttgart published a report (in German) on its internet website as early as 2012 on the subject of residues of the fumigant hydrogen phosphide in arid plant-based foods.

 

Residues of Hydrogen Phosphide in Samples from Organic Cultivation (2019)
Matrix / Type of Sample
No. of Samples
No. Samples > Maximum Level
No. Samples with Residues
Lentils, dried
7
1*
3
Cereals and cereal products
2
-
-

*Amount at level of 237.3 µg/kg (MRL: 10 µg/kg )

 

Residues of Hydrogen Phosphide in Samples from Conventional Cultivation (2019)
Matrix / Type of Sample
No. of Samples
No. Samples > Maximum Level
No. Samples with Residues
Lentils, dried
9
4*
9
Cereals and cereal products
6
-
2

* Amount at levels of 10.5 µg/kg; 37.8 µg/kg; 72.5 µg/kg and 331.0 µg/kg (MRL: 10 µg/kg )

 

Interesting Findings from Reporting Year 2019

Dikegulac in Organic Barley

Three samples of organic barley contained residues of dikegulac in amounts of 0.008 mg/kg, 0.011 mg/kg and 0.015 mg/kg. Two of these samples were slightly above, but unverified, the valid maximum level of 0.01 mg/kg. The amount in the third sample was slightly below the maximum level. The substance dikegulac is a growth regulator that minimizes, e. g. the length of grasses. It has not been authorized for use in the EU since the early 2000s, however. Between the years of 1960 and 1999 dikegulac ended up in the environment in the area “Hessisches Ried” via sewage water resulting from the industrial production of Vitamin C there. Dikegulac was detected in organic spinach grown in the area as recently as the end of 2018/beginning of 2019, according to local media reports (Wiesbadener Kurier on 07/12/2018): “Contaminated Water, Contaminated Vegetables: High Concentrations of Plant Protector Dikegulac Found in Groundwater of a Hessian Organic Farmer’s Field.” This problem continues to exist, obviously, as the samples analyzed by CVUA Stuttgart also came from this area.

 

Melamine in Organic Potatoes

Melamine is not a substance occurring in pesticides, but is rather a contaminant, for which a general maximum level in food of 2.5 mg/kg has been established in accordance with EU Contaminant Ordinance No. 1881/2006. Melamine is included in CVUA Stuttgart‘s analytical spectrum, so every sample is routinely examined for it. Melamine was detected in 34 of the 358 (9.5 %) organic samples analyzed in 2019, at levels above 0.01 mg/kg. The amounts found in 14 of these samples (3.9 %) were above 0.1 mg/kg and in three samples (0.8 %) even greater than 1 mg/kg. One sample (0.3 %) of organic potatoes was in violation, with a verified exceedance of the residue limit at 6.3 mg/kg.

 

Melamine can end up in food via fertilizers that release calcium cyanimide or that contain melamine themselves. It can also conceivably come from an application of the insecticide cyromazine, which forms melamine as a byproduct. Such fertilizers as well as cyromazine are not authorized for use in organic cultivation, however.

 

Desphenyl Chloridazon in Frozen Herbs from Organic Cultivation

The by-product of the herbicide chloridazon was detected in three samples of organically grown frozen herbs (2x chives, 1x dill). The MRL set by regulation (EC) No. 396/2005 was not exceeded. The residues detected in two of these samples were significantly and verifiably higher than the orientation value for organic goods of 0.01 mg/kg, however. Moreover, the application of chemical/synthetic plant protectors such as chloridazon is not permitted in organic farming in general. These two samples were therefore judged to be fraudulent due to their organic labeling. Chloridazon is no longer permitted for use in the EU, but since the country of origin is often not indicated on frozen goods it is possible that the herbs come from third countries.

 

Morpholine in Organic Smoothies

Two samples of organic smoothies contained the additive morpholine, a substance not permitted for use in the EU. In the past morpholine was used as a stabilizer and emulsifier in wax for the surface treatment of exotic, citrus and stone fruits from South America, South Africa and Southeast Asia. In the current case, follow-up research has revealed that the morpholine ended up in the drink via the chlorella-algae that was also used in the drink. Whether the chlorella algae naturally contained morpholine, whether it was treated with morpholine as part of its farming production, or whether it resulted from contamination must be further investigated.

 

Biphenyl and Anthraquinone in Organic Paprika Powder

The (active) substances biphenyl and anthraquinone were detected in a sample of organic paprika powder from Spain. The quantity of residues from biphenyl exceeded the MRL of 0.01 mg/kg for fresh paprika with verification, even considering a drying factor of 10; for anthraquinone the amount lay just under the MRL. It must be considered, however, that neither of these substances may have resulted from an application, but rather as a result of contamination occurring from the production of the paprika powder, such as drying or smoking. Included on the list of additives on the package was the additive „smoke“, which indicates a probable contamination during production.

 

Authors of the extended version of the Organic Monitoring Report for 2019

Marc Wieland, Hanna Marks (report on phosphine), Kathi Hacker and Ellen Scherbaum, CVUA Stuttgart

 

Note

Detailed information (including results tables) can be found in the German version of the monitoring report .
If you have any questions concerning the report on the Organic Monitoring Program of Baden-Württemberg, please don’t hesitate to contact us.

 

Translated by: Catherine Leiblein

 

Artikel erstmals erschienen am 01.02.2021