Pesticide Residue and MRL Compliance

Caliber and classification are destination-independent; pesticide-residue (MRL) compliance is not. The EU's current control regime for citrus and other produce, and who is actually responsible for spray records.

A Class I pepper is Class I whether the buyer is in Germany or Iraq — classification and caliber, as described in our quality control process, are destination-independent, universal rules. Pesticide-residue (MRL — Maximum Residue Level) compliance works the opposite way: the same fruit can be fully compliant for one market and problematic for another. This guide covers what that distinction means in practice for exporters.

The EU's two different control regimes

The European Union, under Regulation (EU) 2019/1793, lists certain country-product combinations under two different levels of scrutiny; the list is reviewed at least every six months. The most recent amendment, Regulation (EU) 2026/194, was adopted on 28 January 2026 and entered into force on 18 February 2026. Under this regulation, the items in our catalog that are of Turkish origin split as follows:

• Annex I (border checks — no pre-shipment document required): lemons at 20%, pomegranates at 30%, peppers at 20%, and tomatoes at 20% are sampled and tested at the EU border post at the stated rate. This is a check the EU performs at its own border — no laboratory certificate needs to be issued before the shipment leaves Turkey.
• Annex II (special conditions — mandatory before shipment): mandarins, clementines and similar citrus hybrids at 10% and oranges at 20% are also checked, but here the difference is that every consignment must be accompanied by an official certificate issued by the competent authority, plus the results of sampling and analysis, before it leaves Turkey.

Grapefruit was removed from the list entirely in the January 2026 update — the EU's own controls showed the previously identified risk no longer applies. It's a reminder that these lists aren't fixed; they can also shrink with sustained compliance.

Spray records and Turkey's monitoring system

"Spray records" — the log of what a grower applied, when, and at what dose — are maintained through two separate mechanisms. A prescription system for restricted-use products ties each purchase to the grower's national farmer-registry record, creating a digital trail; as of late 2025 this system is being rolled out province by province in Turkey's main fruit- and vegetable-growing regions, and is not yet nationwide. Separately, growers certified under Good Agricultural Practices (GAP) are required to keep a detailed logbook — date, dose, and pre-harvest interval for every application — but that certification is voluntary, not mandatory for every grower. On top of both, Turkey's Ministry of Agriculture and Forestry runs a National Residue Monitoring Plan that screens export produce at a program level, independent of any individual company's own testing.

See our caliber and packaging guide for more on shipping documentation and the phytosanitary certificate process, and our export page for our target markets.

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