Topics

  • Latest Timing Trends
  • Upcoming Calendar Items
  • Company Names
  • Lifecycle of a Label
  • Possible CA Registration Fee Increase
  • SRC’s Communication/Submission Standards
  • CA Mill Tax Update
  • Novel Coronavirus (COVID-19) – Fighting Product Lists

 

Latest Timing Trends

States are experiencing delays in both new section 3 pesticide product registrations and in renewing existing products because of the COVID-19 pandemic. SRC is seeing the below registration timing as of March 2021.

  • Hawaii – 4-6 months. Special requests after 3 months are sometimes granted.
  • Indiana – Recently allowed conditional registrations while the reviewers work through their backlog.
  • Maine – 8-9 months. Approaches registrations as strictly first in, first out.
  • New Jersey – Currently experiencing technical difficulties registering new companies and working towards a solution.
  • South Dakota – 7-8 months. Reviews registrations on a first in, first out basis.

Calendar Items

Validation – Target completion date – Friday, April 2 (Your State Registration Specialist will contact you with any questions.)

This process allows clients to verify current label and SDS versions as well as notify SRC of any upcoming changes in product status. Watch for an email from your State Registration Specialist. Once you receive that email, please go to the SRC Portal and complete the process.

Reconciliation – Target completion date – Friday, April 30

The reconciliation process consists of SRC invoicing or refunding the difference between prepaid state fee estimates and actual funds dispersed on completed initial registrations and renewals.

Company Address & Company Name Changes with EPA & States

Both the EPA and states that register products require company names and addresses to be prominently displayed on labels. Additionally, the company name and address listed should match EPA’s records. A change in company name and/or address should first be updated and approved with EPA prior to changing product labels. States also require updated labels and an EPA approval letter notifying them of this change. Furthermore, a handful of states will require a new registration for products with company name changes in addition to 2 years of discontinuation for products with the old name. Please notify SRC if your company is going or has gone through a company or address change so that we can assist you in ensuring your pesticide product labels remain in compliance with current state and federal guidelines.

Lifecycle of a Label

  • State Label Beginnings
    • Initial registration
    • Occurs after EPA approves your master label
    • State review completion timing averaging ~8-9 months to be registered in all states
  • State Label Maintenance
    • Renewals – most states require licensing fees & product list forms be submitted annually to maintain registrations in states where distribution is desired while the product label is in the channels of trade
  • State Label Updates – triggered by changes including the following examples & should be provided to states for review/approval prior to marketing:
    • Revisions to master labels which trigger required product label changes
    • Claims/Organisms/Directions for Use approved on the current master label, but new to the product label
    • Desire to reformat/redesign the appearance or content of the product label
  • Discontinuation
    • Applicable to product brand names where production has ceased & future distribution is ending
    • SRC should be notified during the validation process or as soon as a company decides to end production
    • Majority of states require a minimum of 2 years of renewing the brand name with an “In Discontinuation” status & accompanying state license fees/forms to allow sufficient time for the remaining product supply to work through the retail channels of trade
  •  Cancellation
    • After the product has completed the required discontinuation period (typically ~2 years) & is out of the channels of trade
    • Product is now eligible for cancellation at the state level during the renewal process. Product will be marked to “Cancel” & no additional state licensing fees will be required for this brand name

Possible California Registration Fee Increase

California’s Department of Pesticide Regulation (DPR) is proposing a fee increase to ensure sufficient funds are available to support the registration program. Below is a snapshot from the proposal released on March 5th, 2021 of the fee increase scenarios being reviewed.  SRC will continue to monitor this and provide updates as we gain additional information.

California Mill Tax Update*

California Mill Taxes are due 30 days after the end of each quarter. California conducts audits and issues fines/fees to companies who do not pay the taxes within this time frame. SRC encourages companies to pay electronically directly to CA.

This year, CA is proposing to change their flat rate structure to one based on risk, where higher toxicity pesticides are assessed at a higher fee. SRC will monitor any rate changes and update our clients of final changes.

SRC’s Communication/Submission Standards

The SRC team strives to respond to client requests as quickly as possible. Below are SRC standard timelines for processing your request.

  • Email or voicemail communication – Our goal is to send an email acknowledgment within 24 hours with an expected timeline to respond to the request.
  • Label Review – Though normally completed in 5 business days, we guarantee comments returned to you within 10 business days of receiving label documents.
  • Initial State Registration Submission or State Label Update – Though normally completed in 5 business days, SRC guarantees submission to all states except California within 10 business days of receiving all client information (labels, documents, funding, etc.)

If we are unable to meet the guaranteed timelines above, your State Registration Specialist will notify you as soon as possible.

Novel Coronavirus (COVID-19) Fighting Product Lists

EPA’s website hosts a list, known as List N, of basic registrants’ products which meet EPA’s criteria for use against SARS-CoV-2. In addition to List N, the CBC hosts a free list for all Basic registrants and Supplemental Distributors, also known as Subregistrants, which are eligible for List N. The list is updated weekly and is the only location a subregistration can be put on a list showing the product is effective against SARS-CoV-2. For more information, and to review the requirements for having your subregistration added to the list, click the link below.

https://biocides.americanchemistry.com/CBCs-List-of-COVID-19-Fighting-Products-FAQs.html

If you would like SRC to add your product to CBC’s list, please contact SRC at 260-244-6270, or email state@srcconsultants.com.

Published 04/01/2021 by:

Rene’ Leitheim: State Registration Manager

Celeste Bontrager: Registration Specialist

Chelsey Sandlin: Registration Specialist

Michelle Rhoades: Registration Specialist

Michelle Warrix: Registration Specialist

Tom Spahr: Registration Specialist

Nicki Baker, Ph.D.: Registration Specialist

Heather Ball: Registration Specialist

 

*Photo by Tyler Franta on Unsplash