On March 9, 2022, the State of Indiana released new and updated policies on its website for pesticide product registrations. These five documents include very important changes to the Indiana pesticide registration process. This article breaks down the new information provided in these policies and how it may affect your product registrations.
Conditional Registration Policy Update
This policy change states submissions received after July 1, 2022, will no longer be eligible for conditional registration. This means all new initial registrations submitted in the State of Indiana will not be legal for sale or distribution until the full review process has been completed. Prior to COVID timing was 3-6 months for Section 3 registrations while devices and 25(b) registrations were 9-12 months.
Products that are Considered Different
Indiana’s updated guidance changes the definition of products that are considered different. Previously, all products with the same product name, company name, EPA registration number, and ingredient statement were considered the same product under one registration. Following this policy change, products must also have the same labeling, claims, and branding, or they will be considered a different product and require separate registration.
Products or label changes falling under this guidance must be submitted to Indiana as an initial registration with a $170 registration fee. Additionally, a $170 renewal registration fee would be due to the state annually to maintain the registration of each “different” product. The Office of Indiana State Chemist has already begun enforcing this change and notifying registrants when label updates are submitted that would now be considered new products.
Under the guidance, the following changes or differences will now require separate registrations in Indiana:
- Products with different
- Directions for use
- Use sites or users
- Methods of application
- Company name
- Product name
- Multiple products in a kit or co-pack
- Replacement filters and UV light bulbs for pesticidal devices
The deadline for compliance with this change is March 1, 2023. All registrants must review their current registrations and resubmit products that were previously registered as the “same” but would now be considered “different”. Any differing products that have not been submitted as initial registrations by the deadline may be subject to late fees or stop sales.
The SRC team strongly recommends reviewing your product labels and submitting all initial registrations for different products before July 1st, 2022, when the Conditional Registration Policy expires. As the definition of “different” product is somewhat open ended, our team has contacted The Office of Indiana State Chemist for additional information related to which products will require separate registration and will provide updates as they become available.
Please contact your SRC regulatory consultant today to assist you in reviewing your labels and submitting initial registrations to Indiana, where necessary, to ensure you are in compliance prior to the deadline.
IN Web Update on How to Submit Labels
Indiana has updated its policy on how to submit labels to clarify that paper labels will no longer be accepted. Labels may be submitted via email or through the ALSTAR Portal and must be a single pdf. If labels are not submitted correctly, registrant will have 30 days to provide new information, before the submission is denied.
Label revision submissions must include a pdf of the label with all changes highlighted and a clean copy of the label named with the 10-digit Indiana Registration Number.
25(b) applications will require efficacy data to be submitted to support any pest control claims. Pesticidal device registrations will only require efficacy data if requested by the reviewer.
Indiana Pesticide Product 25(b) – Minimum Risk Update
Indiana will register all pending 25(b) products for applicants who have current 25(b) registrations. These products will be reviewed during the 25(b) Audit. Upon registration of these pending products, Indiana will email registrants to request an updated Audit Spreadsheet. Indiana plans to review Audit packets this summer with the goal of returning change requests to all registrants in the Fall of 2023. Any changes requested by Indiana must be resubmitted and approved by 2025.
Contact your SRC State Registration Specialist for assistance updating and returning the Audit Spreadsheet.
The SRC Team has reviewed these policies and highlighted changes for your convenience. Links to these documents are below:
- Indiana Pesticide Product 25(b) – Minimum Risk Update
- Conditional Registration Policy Update
- Frequently Asked Questions: Pesticide Product Registrations Update
- Products that are Considered Different Update
- IN Web Update on How to Submit Labels
Contact your SRC State Registration Specialist for more information or updates on these policy changes.
State Registration Specialist
Posted on 03/22/22