In 2021, Arizona, Indiana, Maine, Mississippi, South Dakota, Washington DC, and Wisconsin state agencies will be performing an audit of all registered 25(b) products to ensure they meet the requirements outlined in AAPCO FIFRA 25(b) Workgroup guidance documents. On September 24, 2020, the Office of the Indiana State Chemist (OISC) emailed all registrants with a fillable audit document and Letter to Registrants with instructions for completing the audit.

The Letter to Registrants outlines the following requirements:

  • The audit must be submitted by December 31, 2020 via email, CD, or thumb drive to all of the above listed states (even if the product is not registered in all states).
    • Maine, South Dakota, and Wisconsin will only accept the audit via email.
  • The audit submission must include the completed audit document and individual file folders for each product with:
    • Current text-searchable market label
    • CSF
    • Efficacy data
    • SDS
    • Any available human health toxicity or hypoallergenic data

Please contact SRC to assist you with this process. If SRC currently manages your state registration renewals, your State Registration Specialist will contact you directly to request permission to complete the audit on your behalf.

Following the Audit Submission

 In 2021 and 2022, states will review audit packets. Revision requests will be provided to registrants in Fall 2022 with the following timelines:

  • Notify states if correcting the changes or discontinuing products before 2023 renewal.
  • Label changes must be submitted by 10/01/2024.
  • New data should be completed by the end of 2024.
  • Formula revisions should be completed by 2025.
    • Depending on the state, this may require discontinuation of product and new registration.

SRC Recommends:

  • Completing and submitting the audit to states as soon as possible to avoid issues renewing your product registration.
  • Proactively comparing your current product registrations to the AAPCO guidance documents and correcting any inconsistencies before receiving the audit feedback from states.
  • Contacting our 7-person State Registration Team to assist you with the audit, reviewing the AAPCO guidance, and generating new data or making any necessary changes to your product registration.

We will continue to monitor this audit and update clients with material changes.

Published September 29th, 2020 by:




Rene’ Leitheim, State Registration Team Manager