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European Regulation on Nicotine Content: implications and repercussions for madagascar vanilla export

Nicotine thresholds: How European regulations almost destabilized Madagascar’s vanilla exports
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Legitimate concerns of farmers: sword of Damocles for thousands of small producers:

In regions like SAVA (Sava and Analanjirofo) and Alaotra Mangoro, nearly 25,000 families rely exclusively on vanilla cultivation. That’s 150,000 people directly dependent on this ancestral agricultural sector in Madagascar.

With 80% of current harvests in breach of the European threshold, their entire economic model is jeopardized.

Madagascar vanilla, the country’s main export commodity, was at the center of a recent decision by the European Commission to adopt Regulation 2023/1281. This regulation drastically lowered the maximum limits of nicotine residues allowed in food imports.

 

For vanilla, the authorized level was reduced from 0.3 to 0.02 mg/kg before being finally revised to 0.3 mg/kg by the European Union.

  • Deciphering a Decision with Significant Repercussions
  • Immediate Consequence: 80% of the local “black gold” production potentially faces a ban on its European commercial outlet, threatening $600 million in annual exports. More than just a loss of revenue, the entire rural economy is destabilized.
  • Offensive Diplomacy to Influence European Rigidity
  • In response to this bombshell, Madagascar reacted at the highest level by activating all diplomatic channels. An inter-ministerial task force was tasked with massive lobbying of the EU to obtain a relaxation, supported by studies on the origin of nicotine in local vanilla.
  • Europe Finally Makes Concessions
  • After 6 months of intense pressure, the European Union agreed to reconsider its stance. On February 7, 2024, the threshold was finally maintained at 0.3 mg/kg for Malagasy vanilla. The industry is “saved,” but compelled to rethink its model in the face of European sanitary standards.

Regulation with severe economic repercussions for the entire industry:

The new Maximum Residue Limit (MRL) on nicotine raises fears among stakeholders in the Malagasy vanilla industry. Beyond direct commercial losses, an entire segment of the local economy is threatened in the medium term.

Hundreds of export industry jobs at risk:

But beyond the fields, the entire downstream chain is critically threatened. In Toamasina alone, the country’s largest container port, around thirty companies specialize in sorting, processing, and shipping vanilla to Europe.

This puts hundreds of skilled jobs at risk.

Nearly a quarter of the country's customs revenue is at stake:

With exports worth $230 to $250 million annually, vanilla accounts for 20% of Madagascar’s customs revenue. Vital resources for funding public services would be seriously reduced if the new European standard were strictly enforced.

An all-out diplomatic offensive to influence Brussels:

Upon the announcement of the new MRL, Madagascar reacted at the highest level and launched a veritable diplomatic offensive to try to soften the European position.

A crisis interministerial task force:

As of August 13, 2023, an interministerial task force involving Foreign Affairs, Commerce, and Agriculture was mobilized. The goal: to urgently orchestrate an offensive plea targeting decision-makers in Brussels. This crisis cell, a true headquarters, worked tirelessly for 6 months coordinating intense diplomatic activity.

Industry professionals were not left behind. Exporters based in Toamasina, as well as producers in vanilla-producing regions, mobilized to support government action. Analyses, testimonies, and field data: all local expertise was tapped.

Analysis of nicotine residues in the industry:

Arguing based on precaution, Brussels requested studies on the exact origin of nicotine in Malagasy vanilla. Meanwhile, several studies were conducted to better understand the origin of nicotine traces.

Continued diplomatic pressure for 6 months:

For nearly 6 months, Madagascar pursued appeals to the European Commission, EFSA, and the Parliament in Strasbourg. The economic and social threat was clearly highlighted, leading to the eventual softening in early 2024.

February 2024: suspense comes to an end:

After 6 months of tough negotiations, Madagascar breathed a sigh of relief: Europe finally agreed to relax its position. The all-out mobilization of Malagasy authorities had finally paid off.

EFSA validates maintenance of previous thresholds for Malagasy vanilla:

On February 7, 2024, the European Food Safety Authority published an opinion reassessing the nicotine issue in vanilla. Aware of the extent of the economic threats, it confirmed the maintenance of the rate at 0.3 mg/kg for Malagasy exports.

Vanilla industry saved, but still under pressure:

On the Malagasy side, there was relief in the producing regions after weeks of uncertainty. The vanilla industry avoided an industrial catastrophe and can continue its traditional activities. However, it also recognizes its extreme vulnerability to European directives, necessitating a rethink of its model.

Toward essential diversification of outlets

Madagascar knows that with the continual tightening of sanitary standards in Europe, the risk of similar crises in the future is real. If such a standoff were to occur again, the outcome could be far less favorable. Diversification of activities and markets is more crucial than ever for long-term survival.

Towards the emergence of quality, resilient, and responsible vanilla sectors

As challenging as this regulatory standoff was, it will also have beneficial effects on Madagascar’s vanilla industry. While constraining in the short term, this necessary modernization will strengthen its sustainability. To meet the required standards of traceability and quality, practices will evolve with the support of comprehensive programs: technical training, financial assistance, structuring of producer collectives, and diversification of activities.

The full expression of Madagascar’s exceptional terroirs will also require more equitable and traceable sectors. Resilient operations where producers fully benefit from their work within responsible cooperatives. This is the price that Malagasy black gold will continue its unique story, combining respect for standards, economic performance, and sustainable local development.

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