Entry into Force of the Environmental Mirror Measure on Neonicotinoid Residues
Written by Stéphanie Kpenou on .
For the first time, the European Union adopted a mirror measure on environmental grounds in 2023. The measure entered into force on 7 March 2026.
As a result, certain products containing residues of two neonicotinoids that have been banned in the EU since 2018—thiamethoxam and clothianidin—can no longer be placed on the EU market.
These two substances, which were banned in the EU because of their high toxicity to insects, remain authorised in several countries around the world, notably Brazil, where they are used on soybean and maize crops.
By addressing this discrepancy in production standards between the EU and third countries, the measure represents an important step forward.
While this development is certainly welcome, a more ambitious approach could have been both legally more robust and more effective in protecting the environment, as highlighted by the Veblen Institute, the European Environmental Bureau (EEB), and the Foundation for Nature and Humankind (FNH) in a June 2023 study:
Imidacloprid and thiacloprid—two other neonicotinoids whose use is also banned in the EU—are not covered by the measure.
The measure does not apply to products used for animal feed, energy production, or processed food products.
The absence of detectable neonicotinoid residues in imported products does not guarantee that these substances were not used during production. Residues may simply be present at levels below the detection threshold. As a result, lowering maximum residue levels (MRLs) may not be the most effective way to protect the environment.
A complete prohibition on the use of these substances in the production of imported goods would likely deliver stronger environmental outcomes. Existing traceability and control systems in sectors such as livestock production and organic farming suggest that such an approach would be feasible. Ensuring the credibility of mirror measures on pesticides also requires greater policy coherence, including an end to the production, storage, and export from the EU of active substances and pesticides that are prohibited under EU law. The entry into force of this measure must also be accompanied by effective enforcement and controls to ensure that it is properly implemented.
Close attention should be paid to how the measure is received by the EU's trading partners. It has already attracted strong criticism within the multilateral framework of the World Trade Organization (WTO), and it could also be challenged under the EU–Mercosur Agreement through its rebalancing mechanism for concessions.
