As of 2018, leaves of radish and small radish have to be analyzed separately from the vegetable fruits. According to the Federal Ministry of Food and Agriculture (Bundesamt für Verbraucherschutz und Lebensmittelsicherheit (BVL), this provides an update of EC Regulation RG (EC) 396/2005 (Annex I, Part B), which becomes effective on 1st January 2018.
According to the regulation, the leaves of small radishes and radishes will be assigned to the culture group kale from this year, without any distinction being made between leaves of radishes and small radishes (Raphanus sativus Radish Group). This means that as of 1st January 2018, the maximum residue levels (MRLs) for kale apply for the leaves of radish and small radish as well.
In a technical report published on 22nd December 2017, the BVL points out that it is currently not possible to ensure that MRL's for the leaves can be met, when using plant protection products that are authorized for radish and small radish. The reason for this is that at the moment there are no residue data for the leaves. According to the BVL, the distribution of radish and small radish with leaves remains possible if only substances were applied in the production, which are listed in Annex IV to Regulation (EC) No 396/2005. Furthermore, the goods can be distributed if the now applicable MRLs are complied with. In all other cases, the BVL recommends selling radishes and small radishes without leaves for the time being.
As part of the amended EC regulation, the BVL wants to check the plant protection products that are authorized for the use in radish and small radish. In the next step the BVL wants to exclude the utilization of the leaves by corresponding constraints, where it is necessary.
On the BVL website you will find more information and background information on the updated EC Regulation RG (EC) 396/2005.