Some Interpretations on the Chemical Information of Pesticide Registration Products

As of the end of 2017, there were 38,247 pesticide registration products in China, an increase of 7.4% compared with 2016. Among these pesticide registrations, 37,448 were officially registered, an increase of 9.4% over the same period of 2016, 509 temporary registrations, and 290 sub-package registrations.

It is reported that insecticides, bactericides and herbicides are still hotspots for registration, accounting for 90% of the total number of registrations. Among them, the number of pesticides registered ranked first, accounting for 38.9% of the total number of registrations, a total of 14,865 registrations; 9,857 for fungicide registration; 9,675 for herbicide registration. Compared with the previous year, the registration of herbicides and plant growth regulators increased the most, at 12.7% and 12.6% respectively.

According to the product dosage form, the emulsifiable concentrate accounted for 28.3% of the total registered amount, with 9,534; the wettable powder accounted for 20.3%, with 6,860; the suspension, water and water-dispersible granules were registered at 4,210, 2,525 and 1,892 respectively. Among them, dispersible oil suspending agents, suspending agents, water agents, water-dispersible granules and other environmentally safe and safe dosage forms have a faster growth rate, while microcapsule suspensions have doubled, with an increase of 106.3%.

According to Wu Houbin, Director of the International Exchange and Service Division of the Pesticide Testing Institute of the Ministry of Agriculture and Rural Agriculture, the number of pesticide registrations in China will show a rapid upward trend in 2018. However, with the promulgation and implementation of the new Pesticide Management Regulations, Pesticide Registration Management Measures, Pesticide Registration Data Requirements and other regulations and supporting regulations, the pesticide registration threshold has been improved, and the upward trend in the number of registrations will slow down in the next few years. .

Wu Houbin said that the demand for exports, changes in domestic policies and the development of technology will drive the registration of pesticides. For example, with the increase in the global acreage of GM crops, the registration of herbicides for glyphosate, glufosinate, 2,4-D and other GM crops will also increase; the adjustment of domestic crop planting area will promote soybeans, etc. The registration of crops for expanding the planting area will increase; the implementation of the zero-growth action on pesticide use will promote the registration of non-chemical pesticides such as biological pesticides ; for pesticides that are forbidden in China, the registration of corresponding alternative pesticide products will continue to emerge; The registration of dosage forms and dosage forms suitable for drone application will increase.

The newly revised "Pesticide Management Regulations" and related supporting regulations have been released and implemented in 2017. Among them, the chemical information and test requirements for pesticide registration products have changed a lot. Some interpretations on the chemical data of pesticide registration products are now sorted out.

1. How to identify the same product, similar products and new products relative to the company?

A: According to the "Pesticide Registration Data Requirements", if the application for the same product, similar products, or the new content of the enterprise is registered, the "control product" should also be in accordance with the "Pesticide Registration Management Measures" and "Pesticide Registration Data Requirements". Get the registered product.

2. What information should be submitted for the transfer of pesticide registration data?

Answer: According to the “Pesticide Registration Management Measures”, when the transferee applies for pesticide registration, it shall submit the transfer contract of both parties, the transferor’s consent to cancel the registration certificate and the original registration certificate for application for cancellation, and comply with the “Pesticide Registration Data Requirements”. Registration information.

3. How to understand the meaning of “in accordance with the requirements of registration materials” in the first and second paragraphs of Article 18 of the Measures for the Administration of Pesticide Registration?

A: The first paragraph and the second paragraph of Article 18 of the Measures for the Administration of Pesticide Registration have respectively stipulated the authorization of pesticide registration materials and the transfer of registration materials. The “in compliance with the requirements for registration data” in this article refers to the requirements of the current registration data. , the newly issued "Pesticide Registration Information Requirements".

4. Is it possible to authorize some pesticide registration information?

A: No. According to Article 18 of the “Pesticide Registration Management Measures”, the complete registration information of the pesticide registration certificate holder that meets the “Pesticide Registration Data Requirements” can be authorized to be used by other applicants.

5. Can pesticide products in the patent protection period be applied for registration?

A: You can apply. According to the objection or request of the patentee, the Ministry of Agriculture and Rural Affairs will perform the notification procedure in accordance with the provisions of the Administrative Licensing Law.

6. Can a domestic enterprise that has obtained a pesticide product registration certificate but has not obtained a production license (or production approval certificate) continue to apply for pesticide registration?

A: According to the “Pesticide Management Regulations” and “Pesticide Production License Management Measures”, domestic enterprises that have obtained pesticide registration certificates but have not obtained production licenses (or production approval certificates) are not allowed to register and register their new pesticide products. Change and change of company name; pesticide products that have been approved for registration can continue to apply for registration and continuation before August 1, 2019. Enterprises that have not obtained production license after August 1, 2019 will cancel their registration certificate for pesticide products. .

7. Can the registration information that has not been approved for registration be applied for?

A: You can get it back. According to the "Pesticide Registration Data Requirements", the registration materials that have not been approved for registration by the Ministry of Agriculture and Rural Areas shall be kept for 5 years from the date of the decision not to approve, and may be applied for retrieval within one year after the expiration of the period of time. If the applicant re-applies for registration within 5 years, a copy of the registration test report may be used.

8. Do you need to apply for registration changes for changes in the types of sanitary insecticide flavors?

Answer: According to the “Pesticide Registration Data Requirements”, the fragrance content of the sanitary insecticide should be no more than 1%. The change of flavor type may not apply for registration change.

9. How to record the pesticide registration test?

Answer: According to the “Pesticide Management Regulations” and “Pesticide Registration Test Management Measures”, if the pesticide registration test is carried out, the applicant shall report to the competent agricultural department of the provincial government of the locality for the record; the registration test of the new pesticide shall also be conducted by the Ministry of Agriculture and Rural Affairs. Review and approve.

10. The Ministry of Agriculture's original No. 946 announcement stipulates that the diluted dilution of pesticide products should be between 500 and 5000 times. Is it still necessary to comply with this regulation?

Answer: Announcement No. 946 of the Ministry of Agriculture has been abolished. The dilution factor of pesticide products is not subject to the above regulations, but should be convenient for use.

11. How long can the pesticide registration continue to be applied in advance?

A: The holder of the pesticide registration certificate can apply for registration renewal for up to 6 months (about 180 days).

12. Can the applicant who has obtained the pesticide production license but does not have the corresponding production scope apply for registration renewal?

A: Yes. According to the “Pesticide Registration Data Requirements”, the applicant should apply for registration and continue to submit a copy of the production license within the validity period.

13. The normal temperature storage stability test report, quality inspection report, etc. are not issued by the registered test unit, how to prepare these test data?

A: Before the publication of the list of relevant registration test units identified by the Ministry of Agriculture and Rural Affairs, the normal temperature storage stability test report and quality inspection report can be implemented according to the previous requirements.

14. How to calculate the number of residual test points according to the 2-year residual test data carried out in the original Pesticide Registration Data Regulations?

A: According to the original “Pesticide Registration Data Regulations”, a 2-year residual test conducted at one location, the number of test points is calculated in two.

15. Should the pesticide risk assessment report be issued by a qualified unit?

A: The pesticide risk assessment report includes a health risk assessment report, a dietary risk assessment report and an environmental risk assessment report, which can be completed by the registered applicant or by the relevant technical unit entrusted by the registered applicant.

(Source: Agricultural Finance Network Agrochemical Collection)

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