The Committee expresses its appreciation to the Ministry of Agriculture (MOA) for its engagement with industry over the past year and its collaborative approach in optimizing regulatory management. Building on this cooperation, we offer several recommendations to support continued modernization by aligning Taiwan’s pesticide management framework with international standards and promoting a transparent, efficient, and sustainable agricultural production system.

The agrochemical industry continues to face several regulatory bottlenecks, including administrative delays in the approval of maximum residue limits (MRLs), and recent changes in pesticide registration procedures that have reduced regulatory predictability and slowed the introduction of new technologies. Addressing these challenges is essential to maintaining Taiwan’s agricultural productivity and competitiveness. Equally important is the need for predictable registration procedures. Aligning Taiwan’s data requirements with internationally recognized hazard- and risk-based assessment principles would encourage investment in next-generation crop protection products with improved efficiency and lower toxicity profiles, and better aligned with sustainability objectives.

At the same time, enhancing the digitalization of regulatory management could improve administrative regulatory efficiency. Adopting e-labeling would not only reduce unnecessary and operational burdens associated with physical labeling change and product recalls while lowering carbon emissions. Thorough digital labels could also enable real-time verification of product information, helping authorities and farmers identify illegal pesticides more effectively.

Stronger and more coordinated enforcement against counterfeit and illegal pesticide products remains necessary to protect Taiwan farmers’ safety, ensure fair market competition, and safeguard consumer confidence in the safety and integrity of Taiwan’s agricultural products.

By advancing these measures, the Committee seeks to close the gap between regulatory policy and practical implementation while supporting a resilient, innovative, and sustainable agricultural sector in Taiwan.

Suggestion 1: Reduce unnecessary relabeling require-ments and promote the adoption of e-labels for pesticide products to protect farmers and consumer safety.

The Committee welcomes the amendments to Article 3 of the Regulations Governing Pesticide Labeling Management announced on September 18, 2025, by the Animal and Plant Health Inspection Agency (APHIA) under the MOA.

The revised article relaxes the six-month deadline for label changes in cases involving updates to factory information, while reinforcing requirements for labeling accuracy and consistency with actual conditions. This adjustment is a pragmatic regulatory improvement that reduces unnecessary administrative burdens and maintains the integrity of labeling standards. The Committee looks forward to the effective implementation of the revised provision through supporting measures and administrative guidance.

To build on this progress and further balance farmer safety, consumer rights, and practical industry operations, the Committee makes the following recommendations:

1.1   Waive product recall requirements for labeling changes that do not affect safety or public interest. When labeling updates involve only administrative information and do not affect instructions for use, warning statements, or safety information, companies should not be required to conduct full product recalls or reprinting after a six-month grace period. Allowing exemptions in such cases would reduce unnecessary waste and administrative costs while maintaining protection for farmers and consumers.

1.2   Facilitate the adoption of an e-label system for pesticide products. Allowing the use of digital labels would improve access to product information, increase regulatory efficiency, and strengthen supply chain transparency. E-labels would allow farmers to obtain the most up-to-date product information while enabling license holders to update labeling information more quickly in line with international practices. Digital labeling systems could also incorporate QR-code verification tools to help identify counterfeit products and reduce the circulation of illegal pesticides.
In addition, replacing physical labels with digital systems would reduce paper use, printing emissions, and label waste, supporting Taiwan’s sustainability and circular economy objectives. Integration of e-label systems with agricultural management platforms, such as electronic pesticide records and pesticide application history tracking, could further strengthen regulatory oversight and administrative efficiency.

The Committee recommends that APHIA establish a regulatory framework and support measures to enable the adoption of e-labels while allowing exemptions from recall and reprinting requirements when labeling changes do not affect product safety. This approach would enhance flexibility and efficiency in Taiwan’s labeling management system, supporting regulatory modernization and strengthening Taiwan’s agricultural competitiveness.

Suggestion 2: Ensure consistent and predictable pesticide registration and review management.

This issue was first raised in the 2023 White Paper and has since been discussed on several occasions between the Committee and the MOA. However, the Ministry has officially convened only two meetings on this issue: the consultation meeting on improving review mechanisms for new pesticide registration in October 2023 and the Consultation Meeting on the Draft Amendments to the Pesticide Management Act and Related Subordinate Regulations in August 2025.

In raising the issue once again in last year’s White Paper, the Committee stated: “In many developed countries, the information and standards required for pesticide management are clearly defined through laws, regulations, or published technical specifications, providing industry with a transparent and predictable compliance framework. In Taiwan, however, the absence of a consolidated and consistently published set of standards has resulted in persistent uncertainty for registrants.” It noted that “as a result, companies continue to operate without a stable regulatory reference, hindering planning and investment.”

Although the MOA responded in 2024 that revised regulations to remedy the problem would be completed before the end of that year, and repeated the pledge in 2025, the necessary revisions have yet to be finalized. Among the problems to be addressed is that the administrative and technical agencies under the MOA have not been applying a consistent interpretation of the data requirements for pesticide registration. As a result, the registration process lacks predictability. After initial submission, applicants are frequently required to provide repeated clarifications and supplementary submissions or incur additional investment to conduct tests. This wasteful situation creates uncertainty, increases compliance costs, and significantly delays the registration and market entry of new pesticide products.

To improve efficiency, the MOA in 2009 introduced a group registration system allowing data generated from trials on representative crops to be extended to similar crops or use against related pests. This approach was intended to address gaps in pesticide availability for minor crops and secondary pests, while supporting traceability and the principle of compliant pesticide use based on the approved application scope specified on pesticide labels.

In practice, however, current review procedures no longer reflect the original intent of the system. Even when applications fall within the scope of grouped registration, applicants are often required to submit additional field trial data, including studies on efficacy, phytotoxicity, and residue trials. The current framework has reverted to a pre-2009 model of single-crop, single-pest registration. Companies must conduct extensive additional trials to support expanded uses, significantly increasing time and financial burdens. At the same time, applicants are not granted a corresponding period of data protection for these additional studies. This imbalance reduces incentives for investment in expanded registrations and limits the availability of pesticide solutions for farmers, ultimately affecting the competitiveness of Taiwan’s agricultural sector.

The Committee recommends that the MOA:

2.1   Align pesticide data requirements with international hazard- and risk-based assessment principles. Data requirements under the “Guidelines for the Physicochemical and Toxicological Studies of Agro-Pesticides” (Article 3, Annexes 1 and 2) should be harmonized with international practices by allowing primary reliance on overseas test reports, rather than requiring additional local tests even when there are no domestic testing institutions able to conduct them. The current situation creates practical implementation difficulties and delays product registration.

2.2   Complete revisions to pesticide testing and registration regulations within one year. This should include revisions to the “Guidelines for Physicochemical and Toxicological Studies of Agro-Pesticides” and regulatory provisions governing grouped crops or pest species, representative use scopes, and implementation methods for extended uses under Article 4, Paragraph 1, Subparagraph 2 of the Guidelines for Pesticide Field Trials. Until these revisions are completed, applicants should not be required to submit data beyond what is required under existing regulations.

2.3   Provide data protection for additional trial data submitted to support extended-use registrations. When applicants are required to submit additional field trial data to support expanded uses, they should receive a corresponding period of data protection to prevent other parties from relying on that data. This structure would safeguard intellectual property and maintain incentives for continued investment in research and development.

2.4   Promote minor-crop registrations through flexible acceptance of scientifically valid trial data. Allowing the use of internal trial data that may not fully meet the formal requirements of the guidelines for pesticide field trials, but still demonstrate scientific validity, would increase industry willingness to pursue registrations and help address pesticide use gaps faced by farmers.

Suggestion 3: Optimize the review procedures for pesticide MRLs.

The Committee extends its appreciation to APHIA and the Agricultural Chemicals Research Institute under the MOA for their continued cooperation. In 2025, the Pesticide Review Committee convened monthly and worked to conclude application reviews within the same month. The Committee also acknowledges the efforts of the Taiwan Food and Drug Administration (TFDA) to improve transparency by regularly updating the status of pesticide MRL applications through the meeting minutes of the Food Sanitation, Safety, and Nutrition Advisory Committee.

Despite these improvements, delays remain in the overall review and approval process. In 2024 and 2025, the time taken by APHIA to forward approved cases to the TFDA frequently exceeded 60 days, compared with the originally planned 30-day timeframe. In addition, MRL review announcements were issued only twice in 2025, on March 11 and November 26. As multiple advisory committee review outcomes were consolidated into a single announcement, some cases took nearly one year to go from advisory committee review to official publication.

The establishment of pesticide MRLs is closely linked to national food security, the diversification of food import sources, and the introduction of high-efficiency, low-toxicity pesticides. The Committee therefore respectfully recommends that the MOA, in coordination with relevant agencies under the Ministry of Health and Welfare, continue to enhance the MRL review framework.

In particular, efforts should focus on strengthening alignment with international standards, improving review efficiency, and enhancing the transparency of decision-making processes. Advancing these measures would support timely access to safe agricultural inputs while safeguarding public health and food safety.

The Committee recommends that authorities prioritize the following actions:

3.1   Ensure that MRL cases approved by the advisory committee are submitted to the TFDA within 30 days. The MOA should strengthen internal coordination and administrative procedures to ensure timely case forwarding in line with the original review timeline.

3.2   Issue pesticide MRL announcements on a quarterly basis in accordance with advisory committee outcomes. Regular publication aligned with the meeting results of the Food Sanitation, Safety, and Nutrition Advisory Committee would improve transparency and reduce delays between review completion and official announcement.

Suggestion 4: Strengthen monitoring and enforcement against illegal pesticides to safeguard food safety and protect intellectual property rights.

The proliferation of illegal pesticides, including counterfeit and substandard products, continues to disrupt agricultural production and market order in Taiwan. These products are increasingly distributed through diverse and less regulated channels, further complicating detection and enforcement. From an economic perspective, illegal pesticides create unfair competition through lower pricing and informal distribution practices, eroding the market share and intellectual property of companies that have invested in research and development.

In some cases, counterfeit versions of innovative pesticide products have entered the market before the original products have received regulatory approval. This situation undermines the integrity of the registration system and weakens incentives for industry investment. If such practices persist, they may discourage the introduction of new technologies in Taiwan by international agrochemical companies and increase the risk of unauthorized use during the registration period.

Illegal pesticide products also pose significant risks to food safety and environmental sustainability. Because these products may contain unknown or unverified ingredients and have not undergone proper toxicological or environmental assessments, their use can result in excessive residues, soil degradation, and potential contamination. Detection of illegal pesticide residues in agricultural products may trigger trade restrictions and damage the international reputation and export competitiveness of Taiwan’s agricultural sector.

The Committee respectfully recommends the following actions:

4.1   Strengthen residue testing and enforcement mechanisms for unregistered pesticides. For pesticides not yet registered in Taiwan but already commercially available overseas, the MOA should enhance residue testing at major domestic fruit and vegetable wholesale markets and establish clear and enforceable penalties. Doing so would address the current gap in enforcement, under which residues of unregistered pesticides may go undetected or cannot be effectively penalized.

4.2   Strengthen source investigation and enforcement against illegal pesticides. The government should establish a dedicated enforcement mechanism to investigate the production and distribution of illegal pesticides. Regular training and policy guidance should be provided to police, prosecutors, investigators, and judicial personnel to strengthen understanding of the risks posed by counterfeit and substandard products. Enhanced investigative capacity and stronger source control would help curb the circulation of illegal pesticides and safeguard food safety.