Comment submitted by H. Kurosaki, Chairman, The Grain Importers Association, Tokyo, Japan

We have a serious concern about the EPS's announcement on a new MRL of paraquat dichloride on wheat. We hereby submit following objection and request regarding the EPA's Federal Register on September 6, 2006 (Volume 71, Number 172). The new MRL 1.1ppm is 22 times greater than current Japanese MRL which remains at 0.05ppm. Even if it is verified with analysis and data in the U.S., it is sill not allowed in Japanese side. Enough discussion (including ADI) about the "International Residue Limit" (in the Federal Register ?.B) with Japanese sides as one of U.S.wheat importers are not done with/by U.S. side partie(s) related. We request the registrant, or you to make effective action to eliminate all possible cases in which may cause critical import disruption for U.S. wheat to Japan, due to this register. We wish constantly to import U.S. wheat. We request that EPA, registrant, and all the parties in the U.S. related to export of U.S. wheat to Japan keep the MRL for paraquat dichloride at 0.05ppm for above reasons. We would appreciate your cooperation and efforts for stable and continuous export of U.S. wheat to Japan. H. Korosaki, Chairman, Executive Committee The Grain Importers Association, Tokyo, Japan The Members of Executive Committee: Sumitomo Corporation Itochu Corporation Kanematsu Corporation Marubeni Corporation Mitsubishi Corporation Mitsui & Co., Ltd. Sojitz Corporation Toyota Tsusho Corporation