EPA Pesticide Registration

In order to sell a pesticide product in the US, the product must be registered by the US Environmental Protection Agency. Products requiring US EPA registration include antimicrobials, insecticides, fungicides, rodenticides, disinfectants, sanitizers, water treatment disinfectants, animal repellents, swimming pool treatments, and other products formulated to kill, mitigate, or repel pests. Since 1981, Delta has been providing consulting services for all aspects of EPA pesticide registration, and we are ready to help you. Some routine pesticide registration services and support we provide include:

• Obtaining new company numbers and registering establishment numbers
• Developing registration strategy including assessment of data requirements, costs of pursuing registration, schedule, and the most efficient regulatory path.
• Developing protocols and placing and monitoring chemistry, toxicity, and efficacy testing necessary to meet EPA data requirements
• Preparing applications with all necessary forms and documents, including confidential statements of formula and proposed labels, in consultation with clients
• Preparing “me-too” applications (i.e., registrations substantially similar to existing registered products)
• Preparing device applications
• Responding to EPA comments and questions
• Preparing distributor and repack registrations

Preparing amendment and notification submissions, including:

• Changes in ingredients
• Alternative brand names
• Additional use patterns
• Changes in directions for use

• Filing annual reports for pesticide production establishments
• Preparing annual maintenance-fee submissions
• Assisting with record-keeping and reporting requirements
• Reviewing labels and advertising copy for registered pesticide products
• Assisting clients with adverse-effects reporting (FIFRA 6 (a)(2))
• Assisting with EPA compliance and enforcement issues

• Preparing responses to Data Call-Ins associated with reregistration of existing products
• Advising clients on strategies for addressing reregistration requirements
• Placing and monitoring studies to comply with Data Call-Ins
• Reviewing and commenting on EPA risk assessments
• Representing clients in reregistration task forces and EPA SMART meetings

• Preparing product registration and data rights transfers
• Preparing tolerance petitions
• Assisting with development of formulator agreements
• Preparing and responding to data compensation requests; supporting client representatives in arbitration proceedings
• Evaluating impact of regulatory or legislative initiatives on products
• Identifying trends in testing requirements, risk assessment procedures, and regulations for new technologies, e.g., biotechnology
• Determining regulatory status of competitors’ products
• Conducting computer searches of the National Pesticide Information Retrieval System (NPIRS) and EPA databases
• Developing strategies for compliance with export notification requirements for unregistered pesticides
• Tracking and responding to newly issued Pesticide Registration (PR) Notices
• Preparing Freedom of Information Act (FOIA) requests for publicly available information from EPA registration files
• Preparing and submitting Notices of Arrival; assisting with importation of pesticides and devices
• Preparing EPA Design for the Environment applications

Learn More about Our Experience.