China MoA Plans to Abolish Temporary Pesticide Registration

Original Article from CIRS

China new Regulations on Pesticide Administration (hereafter referred to as the RPA) will be issued shortly. The new RPA will encourage the use of environmental- friendly, low-risk biopesticides and will add contents about establishing tracing and licensing system to pesticides. The biggest change in the new RPA is the abolition of temporary pesticide registration, according to the China Ministry of Agriculture (MoA).

First established in 1982 in China, temporary pesticide registration system once played an active role in facilitating registration process. Temporary pesticide registration is a quick way for market access of the newly developed pesticide products that need to go through field test demonstration, or need to be placed on trial sale and those that need to be used under special circumstances. The manufacturer shall be entitled to sell the pesticide after finishing the field trial and obtaining the temporary registration certificate which can be valid for 3 years in total with 2 renewal chances. At the stage of temporary registration, pesticide products quality will be inspected and market prospect will be forecasted. After that, pesticide manufacturers shall submit complete registration data and apply for full registration. So, generally speaking, temporary pesticide registration is a transitional period of full registration.

However, not all the pesticides can be temporarily registered. Me-too pesticides, which have been registered as full registration by the first applicant, shall only be formally registered.

In addition, along with the development of pesticide industry, the problems of temporary registration are increasingly outstanding. The reasons why MoA plans to abolish temporary pesticide registration include:

  • Potential risk of data evaluation for temporary registration products.

Temporary pesticide registrations are easy to be approved compared to full registrations. Enterprises are only required to submit partial or incomplete data regarding chemical and toxicological properties, efficacy, residue and effects on the environment. After review of all the data, the enterprises will get the certificate 3 months later. Therefore, the product quality and safety can not be guaranteed, which will result in a harmful influence on human beings and the ecosystem environment.

  • Registered products are of serious homogeneity and simplification.

Due to the lower cost and shorter registration time, many enterprises would choose a temporary registration rather than a full registration. Temporary pesticide registrations accounted for more than 80% of China's total registrations before 2008, according to China ICAMA. Moreover, a huge number of those are registrations of me-too products with few new active ingredients, which causes excess capacity and fierce competitions between companies.

Undoubtedly, the cancellation of temporary pesticide registration will become a new challenge to enterprises. No market trial sales, longer registration duration, higher experimental cost and more stringent data requirements, full pesticide registration will inevitably put up strict entry barriers in pesticide registration. But, this also means that enterprises should take careful consideration of pesticide products placed on the market and ensure their quality and safety, which will avoid unnecessary registrations and resource waste consequently.

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