Pesticide Regulation in Taiwan

Taiwan is a growing market for pesticide consumption, and is increasingly a major manufacturer, particularly of older, out-of-patent active ingredients.  The government has not yet decided to participate in the Prior Informed Consent procedure of the FAO’s International Code of Conduct on the Distribution and Use of Pesticides.  This paper prepared by the Taiwan Council of Agriculture provides valuable information on pesticide use, production, export, import and new government policies to regulate pesticides.

In Taiwan, most of the technical-grade pesticides are imported from abroad and then formulated into commercialised products.  Approximately 41,842 tons of finished products (with 10,436 tons of active ingredients), worth US$170 million were sold in 1991, of which imported finished products accounted for 23%.  Although the quantity and value of insecticides ranked top in the past decade, the use of herbicides has increased rapidly in recent years. In 1990, herbicides accounted for 42% of total sales, insecticides 37% and fungicides 17% respectively.

      The Council of Agriculture (COA) is responsible for regulating pesticides under the Pesticide Regulation Act. Approximately 511 active ingredients have been registered, and 324 active ingredients were sold in 1992.  To ensure that pesticide use will not present unreasonable risks to human health or the environment, complete toxicology data are required for review before new pesticide registration is granted. Also, for regulating existing pesticides, the pesticide quality, residue monitoring programme, farmers’ education and risk assessment of pesticides are implemented in accordance with the law.

Pesticide legislation

All pesticides imported or used in the country should be registered. Pesticide regulation dates back to 1959 when the Rules of Pesticide Control were promulgated by the Taiwan Provincial Government. In June 1972, the Pesticide Regulation Act was introduced by the Ministry of Economic Affairs and was amended and reissued by the COA in 1973, 1983 and 1986.  The Act regulates pesticide registration, import, export, manufacture, marketing, storage, labelling as well as pesticide field bioefficacy tests and use.  The Act makes provision for civil and criminal penalties against violation of pesticide regulation.

      In 1986, Standards for the Establishment of a Pesticide Factory were revised to specify requirements of pollution control in pesticide factories. Later, Standards for the Inspection of Pesticide Specification were amended to provide criteria for the sample inspection of pesticides. Requirements of toxicology data were revised in 1991. Recently, COA has set up pesticide sale record cards to enforce pesticide use regulation among farmers and pesticide sales agents.

Executive and supervisory agencies
Council of Agriculture: The COA is the prime authority for regulating pesticides under the Pesticide Regulation Act

Pesticide Advisory Committee (PAC): this committee was set up by the COA, and comprises plant pathologists, entomologists, pesticide chemists, toxicologists and representatives from the National Health Administration (NHA), the Environmental Protection Agency (EPA), and the Bureau of Commodity Inspection and Quarantine. Its responsibilities are to review both the toxicological and bioefficacy data of pesticides and give advice.

Bureau of Food and Sanitation, Department of Health (BFS): The BFS is the administrative authority promulgating tolerance levels of pesticides in foodstuffs.

Bureau of Commodity Inspection and Quarantine (BCIQ): is responsible for the sample analysis, checking for chemical and physical properties of pesticides.

Provincial Department of Agriculture and Forestry (PDAF): has responsibility for implementing pesticide regulation. It also coordinates with the city/county governments to monitor pesticide residues and provide guidance for the safe use of pesticides to farmers. The PDAF was authorised by the COA to perform local bioefficacy tests.

Taiwan Agricultural Chemical and Toxic Substances Research Institute (TACTRI): is the pesticide research institute assigned to perform the analysis of pesticide residues in food crops. It has concentrated most of its work on acute toxicity tests, pesticide analysis and residue monitoring in agricultural products.

Regulating products and the community

Pesticides as defined in the Act encompass insecticides, fungicides, herbicides, miticides, nematicides, rodenticides, plant growth regulators, algaecides and supplementary agents for use in agriculture. Of the 511 active ingredients (175 insecticides, 155 fungicides, 105 herbicides, 28 miticides, 21 plant growth regulators, 9 rodenticides, 5 nematicides and 13 others) registered, a total of 5,197 pesticide certificates have been issued by COA. There are 324 active ingredients currently on the market.

      Pesticide costs have been estimated to account for about 10-15% of the total crop production cost per hectare of cropland. Use increased rapidly from 1976 to 1983, then gradually decreased in 1984. Around 43,611 tonnes of finished products (11,405 tonnes active ingredient) worth US$202 million were sold in 1992. Before 1989, insecticides ranked top both in quantities consumed and value commercialised. But in 1989 herbicide consumption was greater, accounting for 42.7% of all usage, compared with 36.8% insecticides and 17% fungicides. In 1992, 18,000 tons (41.27%) of herbicides were sold.  In terms of value, insecticides account for 42%, herbicides 28% and fungicides 24% (see Table 1).

      Currently, there are 57 pesticide factories, 105 companies and 6,500 distributors subject to COA regulation in Taiwan. Two of the 57 factories belong to the government and the rest are private enterprises. Most of the local manufacturers are formulators. In 1992, 36,273 tonnes of pesticide products were formulated by local factories. Granule formulation with 51.7% production ranks the top.  Only 22 active ingredients amounting to 6,255 tonnes were manufactured locally in 1992, with the remainder being imported. The majority of products are formulated locally from imported active ingredients. Therefore, import of technical-grade and finished pesticides has increased from 1976 onwards.  In 1992, around 8,330 tons of technical grade and 7,342 tons of finished pesticides, worth US$1,140 million were imported  (Tables 1 and 2)  The United States is the major source of imports, followed by Japan (Table 3).

      The export of pesticides to other countries has steadily increased in recent years. Major items are technical-grade pesticides. The value of exports in 1992 amounted to  US$23 million. Hong Kong is the major market (21.4%) for export, followed by the United States (12%) (Tables 2 and 3).

Regulation of new pesticides

In order to prevent unreasonable adverse effects on human health or the environment, new applications for pesticide registration require more toxicology data on environmental fate, as well as on chronic effects like cancer risk, birth defects or reproductive system disorders. A full package of toxicology data should be submitted for review. The pesticide will be subjected to field bioefficacy tests, residue studies and sample analysis. The PAC evaluates efficacy data.  If it passes, COA issues a registration permit valid for four years.  Biochemical and microbial pesticides are subject to a different set of data requirements. 

      The COA has proposed tolerance levels for 127 pesticides under the Food and Health Act, and sets preharvest intervals. For vegetables, the interval is  between 2-14 days, and persistent pesticides will not be registered for use on vegetables. Organophosphate, carbamate and pyrethroid pesticides are normally registered for this purpose because they are considered by the COA to pose less chronic effects and residue problems.

Regulation of existing pesticides

Risk assessment:  On existing registrations, COA will initiate special reviews of risk and benefit if there is evidence of potential safety problems.  In recent years, if a registered pesticide has been banned or restricted for reasons of toxicology or environmental safety in developed countries, it is often subject to cancellation in Taiwan.  Since 1971, some persistent carcinogenic or otherwise highly toxic pesticides have been evaluated and so far 30 active ingredients have been revoked under the Pesticide Regulation Act. In 1989, the registration was cancelled for: pentachloronitrobenzene, daminozide, captan, folpet, cyhexatin and 35% EC endosulfan formulation.

Quality inspection: Pesticide quality and purity should be verified for each pesticide registered.  There is provision for a routine inspection headed by PDAF to inspect pesticide products in pesticide plants and retail stores and send them for formulation analysis.  In 1992, around 2,020 commercial products were sampled for     quality inspection. Penalties are imposed on producers whose product does not meet specifications.

Safe use, IPM and other alternatives

The COA has supported PDAF-educational programmes for farmers and pesticide sales agents in the safe and proper use of pesticides. In 1992, 205 pesticide sales agents were trained to give advice, and 1,854 farmers were trained in safe handling and effective use.

      Preventive technologies for plant protection were developed and improved to effectively reduce crop losses from being damaged by pests, while emphasising ecological protection.  In recent years, COA has promoted non-chemical pest control technology as a means of reducing the use of agricultural chemicals, lowering the cost of control and raising farmer’s incomes. Field demonstrations have covered:

Biological control of Asian corn borer with Trichogramma wasps over 14,500 ha. of corn field and 100 ha of tea;  spider mite control with predacious mites on over 450 ha. of strawberry, mulberry and tea.

Integrated pest management using the microbial pesticide, Bacillus thuringiensis, and sex pheromones on 3,600 ha. of vegetables and 1,200 ha. of peapod.

Sex pheromone for control of tobacco armyworm and beet armyworm on over 400 ha. of vegetables, 400 ha. of strawberries, and 800 ha. of floriculture.

Paper bag fruit-bagging on 100 ha. of cucurbits, 90 ha. of star fruits, 100 ha. of mangoes and 120 ha. of grapes.

S-H mixture to control vegetable root knot disease.

Biological control of diamond-back moth with green muscardine fungi in vegetables.

Pesticide residue monitoring programme

COA set up a “pesticide residue monitoring programme” in 1966 to enforce pesticide residue standards.  Under this programme, TACTRI and eight Pesticide Residue Monitoring Working Stations with 19 pesticide residue inspectors at various District Agricultural Improvement Stations were responsible for collecting vegetables and fruit samples from production sites and wholesale markets for analysis.  Sampling close to the point of production provides the best opportunity to identify the shipment of fresh vegetables and effectively regulate follow-up, if necessary.

      The field inspectors assist in educating farmers.  When a residue violation is discovered, they will follow up with the farmer.  If residue violations are detected frequently in the same vegetable area, or a high illegal residue found in a commodity, an administrative sanction will be issued.

      The total number of samples collected and analysed each year has averaged 15,000 for the past 10 years. In 1992, around 30,000 samples were analysed. No violations of residue levels were found in over 95% of samples examined.  The multi-residue analysis method used can determine more than 40 pesticides (mostly organophosphates and carbamates).  Single residue method is also used.

Future prospects

Like the rest of the world, Taiwan has changed a great deal, and the life style of farmers and the quality of the environment have changed with it. Farming has changed. More chemicals are used on more land to produce more food than ever before in the nation’s history. To balance the agricultural practices and environmental production, COA has paid more attention to implementation of the Pesticide Regulation Act.

      In the years ahead, COA will be more concerned about the kind of agrochemi-cals put into water or soil. COA is supporting research to define the environmental effects caused by agricultural chemicals.  Biological control will continuously play an important role in the IPM system.  Problems of pest resistance to will be studied.  There will be more educational information for farmers, and the pesticide residue monitoring programme in the fields will be further strengthened.  The government wishes to encourage industry to provide safe and effective pesticides, and work with COA on farmers’ education in the near future.

[This article first appeared in Pesticides News No. 22, December 1993, pages 14-15]