TO: Members, California Wine Export Program

FROM: Joseph Rollo

SUBJECT: Carbaryl, European Union

On June 28, 2006, the European Union published a Directive to lower the allowed Maximum Residual Level (MRL) of the pesticide Carbaryl (known as the brand name Sevin) on all agricultural products, including wine.

This Directive (enforced beginning in January 2007) lowered the MRL from 3ppm (in most of the EU) to 0.05ppm, the lowest measurable threshold.

Carbaryl is permitted in the U.S. The international standard set by CODEX is 5ppm.

Our industry has used Carbaryl on winegrapes to control thrips, mealybugs, leafhoppers, and particularly caterpillars (omnivorous leafroller, orange tortrix, etc.); however, its use in winegrape production has dropped considerably in recent years as more selective insecticides have been found to be more effective as pest control measures. The incidence of reported use in 2006 is minimal.

Subsequent to the EU Directive’s implementation, government labs in Germany and the Netherlands have found wines from New World Wine countries, not California, that exceeded the new limit for carbaryl. The governments of these countries have argued that the new standards should not be retroactively applied. Wines that were held have been released.

We are aware that importers and retailers, particularly in Germany, have requested that suppliers affirm that their wines meet the new MRL standard. Therefore, you may wish to check that your wines do comply.

Our government is supportive of our position, and that of other New World countries, that this new standard should not be retroactively applied. Also, that any testing done, or certification requested, should include all wines in the market, not just those from the New World. Carbaryl was approved for use in Europe prior to 2007. We have reason to believe that many European wines from previous vintages do not comply with the new MRL standard.

Please let us know of any action taken in Europe against your wines in response to this change in MRL standard. The EU is in the process of a systematic assessment of its pesticide standards and we may be faced with more of these situations. We have put into place a better early-warning system so we can alert you to these issues before they become problems.

Please share this memo as you wish. It will also be placed on our web site: www. calwinexport.com.