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A Deep Dive into the Regulatory Logic Behind China's Prohibited and Restricted Pesticide List

Pesticides, as an indispensable input in modern agriculture, are a powerful tool for ensuring national food security and the supply of agricultural products. However, this tool is also a double-edged sword; if mismanaged or uncontrolled, it can pose a severe threat to food safety, public health, and even the ecological environment. It is with this clear recognition that China has always placed pesticide management at a strategic level, constructing a comprehensive safety defense line that extends from source to table and from field to ecosystem.

Complementing the "entry gate" of pesticide registration, the establishment and dynamic updating of a list of prohibited and restricted pesticides is a crucial component of this "full life-cycle" management system. This article will systematically review this list and offer an in-depth analysis of its underlying regulatory logic and future direction, aiming to provide a valuable reference for industry professionals and the general public.

The Multi-dimensional 'Great Wall' of Regulation: Coordinated Governance of Policy, Law, and Justice

China's management of high-risk pesticides is not merely a series of administrative orders but a "three-pronged," multi-faceted governance model that integrates policy guidance, legal regulation, and judicial deterrence. This model covers all key links, including the production, sale, and use of pesticides.

Policy First, Guiding the Way: As early as 1972, China began banning high-risk pesticides, prohibiting the production and import of organomercury pesticides. From the 1982 Regulations on the Safe Use of Pesticides, which barred highly toxic and high-residue pesticides from use on vegetables and fruit trees, to a 2019 central government directive to phase out 10 highly toxic pesticides within five years, policy has consistently set the course for mitigating agricultural risks and promoting green development.

Legal Regulation, Building the Cornerstone: The Regulations on Pesticide Management, first promulgated in 1997 and subsequently revised, provides the core legal framework for managing prohibited and restricted pesticides. It explicitly forbids the use of acutely toxic and highly toxic pesticides on specific crops like vegetables, fruits, tea, and traditional Chinese medicinal herbs. Furthermore, overarching legislation such as the Food Safety Law and the Law on the Quality and Safety of Agricultural Products imposes strict rules, mandating compliance with pre-harvest intervals (PHIs) and prohibiting the use of nationally banned agrochemical inputs.

Judicial Deterrence, Drawing a Red Line: In 2021, a joint judicial interpretation by the Supreme People's Court and the Supreme People's Procuratorate became a powerful deterrent. It stipulates that using a banned pesticide during the production of edible agricultural products will be prosecuted under the crime of "producing or selling toxic or harmful food." This has significantly increased the cost of illegal activities and established a formidable legal deterrent.

A Detailed Look at the List: Which Pesticides are 'Blacklisted' or 'Strictly Regulated'?

As of early 2024, official announcements from the Ministry of Agriculture and Rural Affairs and other departments have identified 80 prohibited or restricted pesticides, 56 of which are classified as acutely or highly toxic.

1. Fully Prohibited Pesticides (61 types)

Pesticides on this "blacklist" are completely banned from production, sale, and use. A staggering 77% (47 types) are acutely or highly toxic. The formation of this list is a dynamic and rigorous process:

• Direct Ban by Announcement: Most substances, such as methamidophos and paraquat, are banned by explicit government notices.

• Phased-Out Ban: Some substances, like omethoate and carbofuran, have a transition period and will be completely banned from sale and use starting June 1, 2026, providing a market buffer.

• De Facto Ban: Other pesticides, including isofenphos-methyl, sulfotep, and chlorpyrifos-methyl, are effectively banned. Although no single "ban order" exists, all their registration licenses have expired and will not be renewed under the policy to phase out highly toxic pesticides. Additionally, products like methyl bromide are prohibited for agricultural use, with their application restricted to specific purposes like quarantine fumigation.

2. Restricted-Use Pesticides (19 types)

These pesticides are subject to strict controls. Their labels must clearly state "Restricted Use" and detail specific application scopes, techniques, and safety requirements. Nine of these are acutely or highly toxic.

• Case in Point: The highly toxic pesticides aluminum phosphide and chloropicrin have not been completely banned. This is because ideal alternatives are not yet available for their use in grain storage fumigation, and the risks are considered manageable under professional supervision. Their use is therefore restricted to certified organizations or personnel with the necessary technical expertise, and they are not available for purchase or use by ordinary farmers.

3. Aligning with Global Standards: China's Commitment to International Conventions

China's pesticide management aligns with global trends through active participation in international conventions.

• The Stockholm Convention: China has implemented bans or strict restrictions on 8 Persistent Organic Pollutants (POPs), including DDT, lindane, and endosulfan.

• The Rotterdam Convention: China adheres to the Prior Informed Consent (PIC) procedure for the international trade of 23 hazardous chemicals and pesticides, such as methamidophos, carbofuran, and aldicarb.

• The Montreal Protocol: The use of methyl bromide is strictly controlled to protect the Earth's ozone layer.

The Path Forward: A Purified Market and Opportunities for Industrial Upgrading

Looking ahead, China's pesticide management will continue to evolve towards greater scientific precision and refinement.

• Strengthening Regulation and Education: On one hand, regular market surveillance and strict enforcement will be used to crack down on the illegal addition or use of prohibited and restricted pesticides. On the other, diverse channels like new media will be leveraged to enhance safety guidance for farmers, promote high-efficiency, low-toxicity alternatives, and bridge the information gap at the grassroots level.

• Dynamic Risk Assessment: Pesticide risks are not static. Continuous monitoring of in-use pesticides, especially those with restricted applications, will be strengthened. This includes assessing risks related to crop phytotoxicity, pest resistance, and environmental impact to provide a scientific basis for future policy decisions.

• Incentivizing Industrial Upgrading: For agrochemical companies, these prohibition and restriction policies are both a challenge and a catalyst for transformation. The government will support this transition by formulating policies that encourage a shift to export markets and accelerate the R&D and registration of green, high-efficiency alternatives, guiding the entire industry towards a safer, more environmentally friendly, and more competitive future.

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