When we talk about pesticide residues in tea, the argument usually takes place at two ends of the supply chain. At one end is the tea industry, concerned about pest control, production and access to markets. At the other is the consumer, particularly in markets such as the European Union, where food-safety standards are stringent.
A third end, however, is largely absent from the discussion: the plantation where the pesticide is applied, and the worker who handles it.
To understand why this matters, start with the basics.
A Maximum Residue Limit (MRL) is the maximum concentration of a pesticide residue legally permitted in or on a food product. The European Union’s (EU) MRL system is primarily designed to protect consumers from potentially harmful exposure to pesticide residues through food.
The European Food Safety Authority assesses whether proposed residue levels are safe for consumers, including vulnerable groups.
This matters for Indian tea because the European Union is an important export market, and imported tea must comply with EU MRL requirements.
Where the EU has set a specific MRL for a pesticide–tea combination, that limit applies; where no specific MRL exists, the EU applies a default limit of 0.01 mg/kg. It is this default limit, rather than a blanket 0.01 mg/kg ceiling for all pesticides, that has become particularly contentious.
The stakes are substantial: India exported 257.88 million kg of tea in 2024–25, earning ₹7,503.52 crore, according to Tea Board India. North India alone accounted for 61.38 million kg of exports in 2025.
For the tea industry, however, the distinction has significant consequences. A pesticide may be permitted for use on tea in India, applied according to recommended agricultural practices, and yet the resulting tea may not meet the residue requirement of a particular export market.
The Tea Board has itself identified pesticide-residue requirements as an important challenge for Indian tea exports.
The issue is also increasingly being felt within the tea supply chain, as companies tighten procurement requirements linked to residue compliance.
Behind this debate lies another challenge: the changing climate in which tea is grown.
Changes in temperature, rainfall and humidity can alter pest incidence and make pest management more difficult.
The tea industry therefore faces a difficult balancing act: protecting the crop from pests while reducing chemical dependence and meeting increasingly stringent residue requirements.
This is where Integrated Pest Management (IPM) and regenerative approaches enter the picture.
The Tea Board’s Plant Protection Code provides a framework for responsible pesticide use, while the broader direction of the industry is towards better pest monitoring, biological and cultural controls, and applying chemicals only when necessary.
But perhaps the easiest way to understand what is at stake is to follow the journey of a pesticide through a tea plantation.
First comes the question: can this pesticide be used on tea? That concerns registration, permitted uses, recommended doses and good agricultural practices.
Then comes the question: how much of that pesticide can remain on the tea? That is the MRL question. It is principally about food safety and consumer exposure. If tea entering the EU contains residues above the applicable MRL, it can be considered non-compliant, even if the pesticide was legally used in the country where the tea was produced.
But there is a third question, asked much earlier in the process and inside the plantation itself:
What happens to the worker who mixes, carries or sprays the pesticide?
That is an occupational health and safety question.
It concerns a different kind of exposure—what happens when a worker inhales the chemical, gets it on their skin, handles contaminated equipment or enters a treated area.
The relevant protections are therefore not MRLs but occupational safeguards: training, appropriate personal protective equipment, safe handling and application procedures, washing facilities, medical surveillance and controls on exposure.
And this is where the current debate becomes striking.
We are discussing extensively whether pesticide residues are low enough for the consumer and whether regulatory limits leave enough room for the tea industry to manage pests. Yet the worker who stands in the plantation while those chemicals are handled and applied is barely visible in the conversation.
Assam has an estimated 13.5 lakh tea plantation workers. That is not a marginal constituency. It is a vast workforce whose daily lives are directly connected to the production practices at the centre of this debate.
Assam’s labour authorities recognise pesticide application as an occupational safety issue.
Employers are required to provide training to workers handling pesticides and other toxic substances, protective clothing and equipment, washing facilities and periodic medical examinations. Health records are also required for workers exposed to such chemicals.
Certification systems, too, increasingly include these safeguards. Plantation audits can treat the deployment of untrained workers for chemical spraying as a major non-conformity. Annual health checks for workers involved in spraying are mandatory in many certified gardens.
But compliance on paper does not necessarily mean that every worker experiences the same level of protection.
There are practical gaps that deserve greater attention. Health examination reports, for example, may not always be shared with the sprayers themselves. Temporary workers can be particularly vulnerable if they fall outside established systems of training, monitoring and health surveillance.
Even something as basic as washing after pesticide application can matter. Where washing facilities at the worksite are inadequate or not used, workers may return home before properly decontaminating themselves.
The exposure can then potentially extend beyond the worker to other members of the household through contaminated clothing, skin or equipment.
Research from tea plantations provides further reason for concern. A study of women working in tea plantations in southern India detected pesticides in workplace air and found that only 16 per cent of those studied reported using personal protective equipment.
Researchers also recorded a range of health complaints associated with pesticide exposure. Research involving tea garden workers in Assam has similarly examined biological effects associated with periodic exposure to pesticide mixtures.
None of this means that tea plantations are simply spraying pesticides without safeguards. Nor does it mean that certification systems have ignored occupational health.
The point is more fundamental: worker safety needs to be part of the public conversation about pesticide use, rather than remaining largely within audit reports and compliance systems.
This becomes even more important as the industry responds to climate change.
If changing weather patterns increase pest pressure and lead to greater reliance on chemical control, occupational exposure could become a greater concern.
Conversely, if the industry moves towards IPM and regenerative agriculture, workers need to be part of that transition—with appropriate training, safer work practices and protection from any new risks that the transition may create.
The MRL debate, therefore, needs a wider lens.
Consumer safety and worker safety are not the same thing. An MRL tells us about the residue that can remain on the product reaching the consumer. It does not tell us whether the worker applying the pesticide was adequately protected.
A tea plantation cannot be called sustainable simply because its tea passes a residue test. Sustainability must also mean protecting the workers who handle these chemicals—with proper training, protective equipment, health monitoring and safe washing facilities.
Assam’s tea industry must adapt to climate change and manage pests while meeting global market standards. But sustainability cannot be measured only in kilograms of tea or milligrams of residue.
It must also be measured in the health of those who produce it. We ask: Is Assam tea safe to drink?
We should ask an equally important question: Is it safe to produce?
Also Read: Promised school, put to work: The case of Assam’s absconding POCSO accused
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