State Year-End Registration Renewals are in Full Swing!

Did you know that pesticide registrations for 40 of the U.S. states and territories expire in quarter 4? The SRC State Registration renewal season has begun, and our team has already completed over 10% of year-end registration renewals for our clients. Our 8-person registration team will renew over a thousand products in these 40 states and territories over the next two months. Visit the SRCPortal to track the progress of your product renewals.

 

2021 State Registration Renewal Fee Increases

Most states pesticide legislature allows the state to increase the fee for pesticide registration at any time. We generally see these increase around each state’s renewal deadline. SRC has been notified of the following state fee increases:

  1. Effective September 1st, 2021, California renewal fees increased from $1,150 to $1,525 per product. The initial registration fee will remain at $1,150.  Pesticide product registrations in California expire on December 31st.
  2. Rhode Island has a fee structure which is composed of two parts annual registration fee and the surcharge fee. Effective August 26th, 2021, the surcharge fee has increase from $150 to $250 making the cost to register or renew a pesticide product $300. Rhode Island registrations must be renewed by November 30th.
  3. Washington state legislature passed laws to increase state fees for new pesticide product registrations and renewals. Effective November 1st, 2021, new product registration and renewal state fees will be $650 per product. Washington expires bi-annually, with varying expiration dates based on the registrant’s renewal cycle. Visit the SRCportal or reach out to your state specialist to determine when this change will apply to your registrations.
  4. The U.S. Virgin Islands is proposing a biannual registration fee of $400 per product. Additionally, the territory is proposing a $50 fee for any updates made to an existing product (i.e., label changes). Pesticide registrations for this U.S. territory expire on December 31st. Keep an eye out for updates from SRC as we continue to follow this proposal.

SRC anticipates state increases and includes a buffer for these increases in our year-end state renewal fee invoices. As we are seeing more states increase their fees in 2021 than in average years, your State Registration Specialist will contact you if additional state registration fees will be required.

 

Missouri Label Update Changes

Effective January 1st, 2022, the Missouri Department of Agriculture will be implementing a more thorough review of all revised labels submitted in the state to determine if significant changes were made to the label. If the review finds that significant changes were made, then a new registration and $200 registration fee will be required. This will also lead to an additional renewal registration if the previous label has not left channels of trade before the renewal date of December 31st.

Below are some examples provided by Missouri in a letter to pesticide registrants of what the state considers a significant label change:

  • Changes to Directions for Use
  • Changes to Storage and Disposal
  • Changes to PPE
  • Change in percentage of active ingredient
  • Alternate brand name products
  • Change in brand name of registered product
  • Change in company name or address on the label
  • Changing amounts of N, P, and Kin weed and feed products

The SRC State Registration team will continue to monitor this change and update our clients. SRC Product Label Review will now include a comment to notify you if we believe your label change will result in a new registration in Missouri.

 

Updates to State Device Registration Requirements

The U.S. EPA defines a pesticidal device as any instrument or contrivance (other than a firearm) that uses physical or mechanical means to trap, destroy, repel, or mitigate any pest as specified in 40 CFR 152.5. Examples include air filters, water filters, steam mops, ultraviolet light systems, ozone generators, fly ribbons, rodent glue traps, and equipment that creates a pesticide (such as a chlorine dioxide generator).

10 U.S. states and territories require registration of pesticidal devices. Two of these states, Indiana and Hawaii, have updated their requirements for product registration:

  1. Hawaii Department of Agriculture will now require a device approval fee of $330. This fee was implemented March 1st, 2021 and will apply to any new device registrations.
  2. Indiana no longer requires states to submit a schematic diagram with their pesticidal device application. Though the application still indicates that a schematic is needed, Indiana’s website indicates that it is no longer required.

 

Please contact state@srcconsultants.com for information about SRC’s full-service state registration management.

 

Chelsey Sandlin

Registration Specialist

Published October 18, 2021