The Biostimulant Industry submitted a response to EPA’s Draft Guidance for Pesticide Registrants on Plant Regulator Label Claims, Including Plant Biostimulants. See here.
In addition, BPIA and the U.S. Biostimulant Coalition submitted a more detailed response. See here. This more detailed response included comments and recommendations focusing on the following points.
Recognizing biostimulants as products supporting natural plant nutrition processes and tolerance to abiotic stress. Recognizing and accepting that many biostimulants have multi-function properties and modes of action depending on formulation, rate, and application. Clarifying EPA’s definitions of product categories that are excluded from the definition of plant regulator under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). Providing specific line by line comments and suggestions to Table 1, 2 and 3. Requesting the deletion of Table 4 as not consistent with the Draft Guidance emphasizing claims/knowledge/intent-based approach since Table 4 is a list of substances registered as plant growth regulators. Recognizing that the potential economic impact of the Draft Guidance on manufacturers could reach or exceed $449 million annualized cost, totaling over $2 billion over a five-year time period. Recognizing the importance of the parallel development of EPA’s Draft Guidance and USDA-led initiative on biostimulants under the 2018 Farm Bill in alignment with other agencies including the National Association of State Departments of Agriculture (NASDA), the Association of American Plant Food Control Officials (AAPFCO), the American Association of Pesticide Control Official (AAPCO), and other stakeholders. Recognizing the importance of the Draft Guidance and its positive impact on the introduction of biostimulants to sustainable agricultural practices through an enhanced regulatory framework.
The more detailed response also includes Appendix 1, Economic Impacts and Implications of Draft Guidance for Plant Regulator Label Claims, Including Plant Biostimulants and Appendix 2, Proposed Addition to EPA Draft Guidance Related to Plant Regulators, Addressing Nutritional Chemicals Excluded From the Definition of Plant Regulators, and Examples of Such Products and Permissible and Impermissible Claims Associated With Such Products.
BPIA would like to sincerely thank our many members who worked tirelessly to help draft these important documents including members of the BIC, RC, and BIW!