Canadian pesticide registration is a complex process that involves the evaluation of ingredients, extensive testing to determine the potential risks posed to human health and the environment, and the pesticide’s value which is determined by assessing the product’s efficacy. PMRA will only register a pesticide if there is sufficient scientific evidence to show that a product does not pose unacceptable health or environmental risks and that it possesses value in its use. A registration is typically granted for a term of 5 years, then subject to renewal (however, a registration term can be less than 5 years if it is determined that the risks or value should be reviewed after a shorter time period).
Pesticides regulated under PCPA include:
- Antimicrobials (including preservatives, pool and spa products, and sanitizers)
- Biopesticides (including microbials and biochemicals)
- Conventionals (including agricultural products such as fungicides, herbicides and insecticides)
TSG can help
We can help in all aspects of pesticide regulation in Canada:
- Prepare and submit registrations and renewals
- Assess pesticide tolerances/MRLs
- Prepare data waivers
- Act as a Canadian Representative agent for foreign companies
TSG provides companies with high-quality regulatory and scientific consulting services. We aim to understand our client's goals and objectives, learn the scientific and technical aspects of projects and anticipate compliance challenges to plan a strategic path forward. TSG's team of experts is deadline-focused, responsive and committed to professionalism. We have the utmost respect for the confidentiality of our work, strong project management skills, and take great measure to cultivate long-term partnerships with clients.
TSG’s regulatory and scientific specialists are experienced in preparing applications for all varieties of pesticide products, tracking progress through to registration and responding to questions that arise during PMRA’s review. Our experts have good working relationships with PMRA and extensive familiarity with scientific approaches that are unique to Canada. TSG’s Canadian team is led by Laurie Tyo, who has over 20 years of experience assisting clients in the preparation of Canadian registration applications.
Frequently asked questions
PCPA defines a pesticide as “any product, device, organism or substance that is used for directly or indirectly controlling, preventing, destroying, mitigating, attracting or repelling pests”.
The use of pesticides is regulated by Health Canada’s Pest Management Regulatory Agency via the Pest Control Products Act. A program of pre-market scientific assessment, enforcement, education and information dissemination are shared among federal, provincial/territorial and municipal governments. It is a complex process, governed by various Acts, regulations, guidelines, directives and by-laws. TSG’s team has close working relationships with the PMRA and can help clients navigate pesticide regulation in Canada.
This is a little like answering how long is a piece of string but depending on the product involved the process can take anywhere from months to years. The quality of the original submission is paramount as is following process and maintaining good communication with the PRMA. Delays occur when forms need to be resubmitted because of incomplete or inaccurate submissions. At TSG we pride ourselves on being able to expedite the process for our clients.
Registrations need to be kept up-to-date and are typically renewed every 5 years. In cases where it is determined that the risk or value should be reviewed more frequently, a shorter registration term may be granted. Again, renewals are something that TSG can help with. We operate a comprehensive renewals’ service where we have an effective database for keeping clients’ products compliant.
Canada does not have a minimum risk pesticide exemption – all pesticides are required to be registered.
When required data or studies are not submitted to support a data requirement, the applicant may submit a request for a waiver of the requirement based on a scientific rationale or the use of surrogate data. At TSG, we assist clients in preparing data waivers.
Under the Pest Control Products Act, all registrants who do not reside in Canada will be required to designate a resident Canadian Representative. Section 62(2)(a) states that this person and address is to whom and where all regulatory correspondence will be sent for all products and submissions belonging to that registrant. A person must be physically present in Canada to represent a foreign registrant. Registrants outside of North America are required to have on the label the name, postal address and telephone number of a contact person in Canada to which public inquiries may be directed. TSG acts as the Canadian Representative for many clients, providing strategic guidance in addition to the registered office address.