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Pesticide MRL maturity · Regulation (EC) No 396/2005

Your MRL control, measured against Regulation 396/2005 and turned into a costed action plan.

10 themes, a 5-level scale. And the action that moves each level to the next.

The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.

Pesticide MRL maturity · Regulation (EC) No 396/2005

MRL regulatory monitoringN1 → N5
Residue risk analysisN1 → N5
Monitoring plan and samplingN1 → N5
Supplier and upstream agricultural controlN1 → N5

10 themes, 5-level scale.

Nordhavn Industries

53 / 100

MRL regulatory monitoring6484
Residue risk analysis5379
Monitoring plan and sampling6182
Supplier and upstream agricultural control3773
IAIndustrialised: your interview notes are enough, the AI fills in the audit.

They measure their maturity with Datamensio

  • Agri Sud-Ouest Innovation
  • ODA
  • Chambre de commerce et d'industrie
  • Eurobiomed
  • Enterprise Europe Network
  • HGK, Chambre de commerce croate

An example

This could be your situation.

Take one company as an example: three sites, three spreadsheets, no shared answer.

01

Nobody can consolidate.

Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.

02

Three weeks, a single base.

One Regulation (EC) No 396/2005 assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.

03

Two costs avoided before being committed.

A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.

What it saved them

  • 3sites measured on the same base, instead of three questionnaires to reconcile
  • 2duplicate actions caught before the spend
  • 1committee report, with no manual rework

These figures are an example. They could be yours.

The standard imposes processes. Datamensio says where you stand.

01

The framework is already written

Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.

02

The score lands the same day

Online, by self-assessment link or in interview. Theme by theme, comparable over time.

03

The gap becomes a costed plan

Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.

04

Progress can be demonstrated

Campaign after campaign, against your target and against your own past. That is what your board asks for.

The maturity scale

One level, the next, and the action that links the two.

This mechanism, a level, a level above, and the action that connects them, is what turns an observation into a trajectory.

Are MRL changes published in the Official Journal of the European Union reflected in your specifications and testing plans?

  1. N1

    No monitoring arrangement identified. MRL changes become known through a supplier, a customer or during an inspection.

  2. N2

    One person monitors changes informally. Amendments are picked up, but reflecting them in supplier specifications and testing plans is irregular and untracked.

  3. N3

    Monitoring is organised and assigned. Every amendment triggers a documented impact analysis and an update of the relevant specifications, within a defined timeframe.

  4. N4

    Updates are systematic and traced through to the supplier and the laboratory. Compliance with the timeframe is measured by an indicator tracked in quality review.

  5. N5

    The arrangement is periodically reviewed against observed gaps and sector developments, with documented tracking of revisions and anticipation of substances under re examination.

Action to move from L2 to L3

Formalise an impact analysis form triggered by every amending regulation to Annexes II and III, assign it by name to regulatory affairs, set a deadline for updating specifications and the testing plan, and check application at the monthly quality review.

« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Chambre de commerce et d'industrie

Director, CCI 94CCI Île-de-France

« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Interreg Danube Region

Maja SucekChief Operating Officer, Interreg Danube

Take your first measurement

What this framework covers

Regulation (EC) No 396/2005 harmonises across the European Union the maximum residue limits for pesticides applicable to products of plant and animal origin, listed in Annex I. MRLs appear in Annexes II and III, exempted substances in Annex IV. Where no value has been set, the default limit of 0.01 mg/kg applies. The regulation also governs import tolerances, processing factors and the obligation on every operator to place on the market food that complies with these values. Official control is carried out under Regulation (EU) 2017/625 and the Union’s coordinated multiannual control programme.

The difficulty is not knowing the values, it is holding them across a supply chain that keeps moving. MRLs change several times a year through amending regulations, substances lose approval, origins shift from one season to the next. A few questions come up time and again: who, in your organisation, checks that an amended MRL is reflected in the supplier specification, and within what timeframe? Is your testing plan built on a risk analysis by material and origin pair, or simply rolled over from year to year? What actually happens, in practice, between a non compliant laboratory result and the decision to block a batch?

Two points of context are worth setting out. First, measurement uncertainty: an MRL exceedance is not judged on the raw value but against the laboratory’s expanded uncertainty, following the rules of the SANTE document on analytical quality control. Many organisations release or block batches without ever having formalised this decision rule. Second, the frequent confusion between MRL compliance and consumer risk assessment: exceeding an MRL is a regulatory breach, it does not on its own constitute a hazard. The ARfD or ADI assessment is a separate exercise, one that determines RASFF notification and recall.

A compliance audit ends with a yes or no: the batch meets the MRL, the testing plan exists, the supplier is approved. A maturity assessment asks a different question: what level of control does the system actually operate at, and what precise action moves it to the next level. An organisation can be compliant on the batches it tests and still fragile on regulatory monitoring, sampling or non conformity management. The score by theme makes that gap visible, and the gap to target generates the action plan.

Within Datamensio, the framework is ready to use. You can adapt it to your sector, fresh fruit and vegetables, cereals, teas and spices, animal feed: the AI adjusts the themes, questions and levels according to the CMMI method, or builds a tailored version from your specifications and monitoring plans.

Reference standard: Regulation (EC) No 396/2005

The themes assessed

  • MRL regulatory monitoring

    Tracking amending regulations to Annexes II and III, substances losing approval, import tolerances, lead time to reflect changes in specifications, traceability of updates.

  • Residue risk analysis

    Prioritisation by raw material and origin pair, taking account of agricultural practices, non conformity history, RASFF alerts and the Union’s coordinated programmes.

  • Monitoring plan and sampling

    Sizing of the plan, sampling rules, frequencies, coverage of substances and matrices, share of release testing versus verification testing.

  • Supplier and upstream agricultural control

    Residue specifications, commitments on authorised substances, plant protection registers, compliance with pre harvest intervals, audits and origin evaluation.

  • Laboratories and analytical methods

    Accreditation, scope of multi residue methods, limits of quantification, participation in interlaboratory proficiency tests, quality control under the SANTE document.

  • Interpretation of results and decision rule

    Accounting for expanded uncertainty, application of processing factors, status of Annex IV substances, formalisation of the decision threshold.

  • Managing exceedances and batches

    Blocking, investigation of causes, extension to related batches, consumer risk assessment against ARfD and ADI, withdrawal or recall, notification to authorities and RASFF.

  • Import tolerances and third countries

    Identification of substances not approved in the Union, verification of applicable tolerances, documentary requirements on import, reinforced controls at entry.

  • Traceability and documentation

    Link between batch, origin, plot or supplier and test result, retention of test reports, time needed to reconstruct a history in the event of an official inspection.

  • Governance, indicators and improvement

    Detection and exceedance rate indicators, management review, lessons learned, annual review of the plan, comparison across sites and over time.

A short version of the framework is available for the online self-assessment.

Frequently asked questions

Can Regulation 396/2005 be certified?

No. It is a directly applicable EU regulation, enforced by competent authorities under Regulation (EU) 2017/625. The assessment measures the maturity of your control system and prepares you for official controls or a private standard audit, it does not issue any certificate.

What is the difference between this assessment and a residue compliance audit?

An audit checks for the presence of requirements and concludes with a gap or a compliance finding over a given scope. The assessment places your practices on a progressive scale, theme by theme, and points to the action that moves you to the next level. The two complement each other: the assessment prepares, the audit validates.

How long does the assessment take?

The short version can be completed in a single working session. The full version, run collaboratively with quality, regulatory, procurement and the laboratory, typically takes one to two weeks, most of the time being spent gathering evidence.

Can the framework be adapted to our sector?

Yes. The questions, levels and themes can all be modified, and you can add the specifics of your materials, fresh fruit and vegetables, cereals, spices or animal feed. The AI generates the tailored version from your specifications and monitoring plans.

Does the assessment cover import tolerances?

Yes, one theme is dedicated to this: identification of substances not approved in the Union, verification of tolerances applicable to imported products, documentary requirements and the link with reinforced controls at entry.

How does it connect with contaminants and veterinary residues?

These frameworks share the same logic: risk analysis, monitoring plan, decision rule, exceedance management. The corresponding frameworks are available in the catalogue, and a cross cutting roadmap can consolidate several assessments without duplicating actions.

Can several sites be compared with each other?

Yes. The assessment can be rolled out at scale across several sites or business units, with internal benchmarking and comparison against your own past assessments. Results are reported in a collaborative space branded to your organisation.

Where is the data hosted?

In France, with OVH, with backup at Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European solutions.

Take your first measurement