US EPA responds to supply-chain disruption of inert ingredients

July 12, 2021

Due to the limited supply of propylene oxide (PO), the United States Environmental Protection Agency (EPA) will allow registrants of non-antimicrobial pesticides to substitute alternate inert ingredients for those derived from PO. The agency issued a rule “Propylene Glycol Phase 2 – ‘Not In-Kind’ Substitution Mechanism,” which allows substitutes in cases where propylene glycol is added as part of the formulation or as part of a brand-name mixture. EPA approved alternates include:

  1. Glycerin
  2. Diethylene Glycol
  3. Ethylene Glycol
  4. 1,3 Propanediol

Registrants are required to notify EPA if they intend to use alternative inert ingredients in their formulation as a substitute for propylene glycol and the Agency will streamline their review process. Substitutions should not impact the existing product in any way that would require label amendments, such as affecting product-specific data, acute toxicity, or physical/chemical characteristics. Registrants must also certify that the substitution will not adversely impact the product efficacy, phytotoxicity, or any other factor that may change the potential of the product to achieve its intended use.

This action set forth by EPA will end 31 December 2021. Registrants who wish to make permanent substitutions to their non-antimicrobial product must follow PRN 98-10’s standard amendment process.

How TSG can help

TSG’s consultants are experts at assisting clients with developing petition strategies and preparing/submitting inert ingredient petitions. Our experts can also assist with certifying your inert ingredient alternative for your non-antimicrobial pesticide product. Have a question? Get in touch: info@tsgconsulting.com

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