Pesticide fragrance regulation update by US EPA

June 11, 2024

US EPA’s Pilot Fragrance Notification Program (PFNP) aims to streamline the process for registrants who want to add new or modify existing fragrances in non-food-use pesticide products. This pilot scheme is set to change; enhanced scrutiny of fragrance registration actions will be conducted after January 1, 2025 to ensure compliance with the program’s terms.

Fragrances play a significant role in various consumer products, including pesticides. When it comes to regulatory oversight, particularly with agencies like the Environmental Protection Agency (EPA), fragrances are subject to specific guidelines to ensure safety and compliance with federal law and environmental regulations.

The EPA regulates fragrances in pesticides to confirm that they do not pose risks to human health or the environment. Fragrances, like other pesticide ingredients, must be evaluated for their safety and efficacy before they can be used in pesticide products. This evaluation typically involves assessing the toxicity, environmental impact, and potential for bioaccumulation of fragrance components.

Approval process for fragrance ingredients

One key aspect of fragrance regulation by the EPA is the approval process for fragrance ingredients. Before a pesticide product containing fragrances can be registered or amended, all fragrance ingredients must be approved by the EPA. The Agency evaluates each individual fragrance component to determine its safety and suitability for use in pesticide formulations.

Historically, registering a fragrance with the EPA involved several steps to ensure compliance with regulatory requirements. Information required to be submitted to the Agency involves details about the fragrance, including its chemical composition, concentration and intended use in the pesticide formulation. You must also include information regarding possible test reports, labels, safety hazards and any regulatory provisions applicable to pesticide products. The fragrance intended for registration with the EPA would then undergo a safety assessment to verify it does not pose risks to human health or the environment.

Pilot Fragrance Notification Program (PFNP)

In recent years, the EPA introduced the PFNP, which provides guidance on the approval process for fragrance ingredients. The primary goal of this pilot program is to streamline submission and review of fragrance ingredients’ information by the EPA, while ensuring that all fragrance ingredients used in pesticide products continue to meet regulatory requirements. It is important to note that this program applies only to non-food use pesticide products.

It is essential to meticulously review the specific requirements and guidance provided by the EPA for PFNP to ensure that the information and forms submitted for fragrance inclusion in your registration are complete and accurate as the registration process with the EPA can be complex and may vary depending on the specific circumstances and regulatory requirements.

Registration action reviews

The EPA has informed us through trade group associations that they are planning to intensify the registration action reviews of fragrances after January 1, 2025, to assure conformance to the terms of this program. It is important to continue registering fragrances with the EPA to be used in pesticide products with these stricter guidelines set to fall in place. If you need help registering a fragrance TSG can help you.

How TSG can help

TSG can provide expert guidance with EPA regulations throughout the entire registration process. If you have any questions about this development from the EPA, please get in contact with TSG’s Principal Scientific Consultant, Dr Luminita Velea, at [email protected].

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