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Fonterra Co-operative Group Limited

PO Box 417, Wellington 6011

157 Lambton Quay, Wellington

www.fonterra.com

Fonterra Co-operative Group Limited Submission on:

APP203261, Application for Modified Reassessment of Luna Privilege & Luna Sensation

27 July 2017

Fonterra Co-operative Group Limited

Fonterra Co-operative Group Limited (Fonterra) appreciates the opportunity to work collaboratively with the

Ministry for Primary Industries (MPI) in support of the New Zealand dairy industry and to protect and build on

New Zealand’s reputation as a world class producer of safe food.

Fonterra is owned by around 10,500 New Zealand dairy farmers. Fonterra and its subsidiaries (collectively,

the Fonterra Group), has a global supply chain that stretches from Fonterra’s shareholders' farms in New

Zealand through to customers and consumers in more than 100 countries. Collecting more than 20 billion litres

of milk each year with around 18 billion litres sourced from New Zealand, the Fonterra Group manufactures

and markets over two million tonnes of product annually. This makes the Fonterra Group the world's leader in

large scale milk procurement, processing and management, with some of the world's best known dairy brands.

General Comments

1 Fonterra appreciates the opportunity to comment on APP203261, Application for a Modified

Reassessment of Luna Privilege and Luna Sensation.

2 Due to the practice of waste streams from processing and damaged/downgraded fruit products being used

as feeds for dairy animals, it would be prudent to ensure that the registrant has completed a risk

assessment for residues in milk, especially since there are Codex MRLs for the active ingredients in the

products.

3 We would also ask that the registrant consider the surfactants in the products as well when assessing the

risk, ensuring they meet their obligations under the ACVM Act, particularly because the application is for

the increase in the rate and amount permitted on the vines.

4 Luna Privilege: active fluopyram, Codex MRL for milk is 0.6 mg/kg

Since the product states on label at present that the orchard should not be grazed, it is recommended that

a risk assessment should be required (data provided) to allow the assessment of whether these

requirements should be extended to the kiwifruit (or other fruits) that the product has been applied to.

SUBMISSION 126927

Fonterra Co-operative Group

17-07-27 FonterraCooperativeGroupLtd-Submission on EPA APP203261 FINAL

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5 Luna Sensation: actives fluopyram and trifloxystrobin, Codex MRL for milk is 0.6 mg/kg and 0.02 mg/kg

respectively. (Note this is our assumption of the active ingredients as there is an error in the application)

The label at present is indicating that there is a meat witholding; this is essentially acknowledging that there

is the practice of feeding the waste streams/fruit to animals. It is therefore recommended that the data to

understand the transference or not to milk be provided so that this may be assessed and the appropriate

conditions included on the label.

If there are any queries relating to this submission, please contact Melanie Chong.

Yours faithfully

Roger Andela

General Manager, Milk Sourcing Assurance and Advisory

Please note that the contact details and signatures of the Fonterra representatives referred to in Fonterra’s submission letter and/or cover email should not be included, and/or be redacted, if a copy of Fonterra’s submission, or extracts of that submission, are requested by any third party and provided by MPI in accordance with its submission review process.

SUBMISSION 126927