Federal Regulatory Support: Import/Export - Pesticides
Importing Pesticides
The import of pesticides requires
compliance with various regulations before the product can be successfully
introduced into the United States. Prior to importation, the completion of a
Notice of Arrival (NOA) form is required. The form consists of three
sections; the first part must be completed by the person bringing the
product into the U.S.importer, and after completion of section one, the NOA
is sent to the U.S. EPA regional office that is responsible for the port
into which the pesticide will arrive. After ensuring that the pesticide is
properly registered, EPA will return the NOA to the importer and notify
customs that the shipment is cleared for entry. Finally, the NOA is
presented to customs upon entry into the United States. However, if a notice
is not completed, customs can detain the product for up to thirty days.
Pesticides do not require registration if they are imported solely to
produce pesticides for export, if they are being transferred between two
facilities owned by the same producer, or if they are being transferred
between two companies’ facilities and the domestic facility will use the
imported pesticide to formulate registered pesticides.
TSG assists
foreign companies importing pesticides into the United States by acting as a
U.S. registration agent, assisting with
EPA establishment
numbers, and resolving various problems that arise during the import
process.
Exporting Pesticides
In order to export pesticides, it
is necessary to be aware of the requirements and regulations in the country
of destination. While pesticides registered in the United States may be
exported, most countries require registration to import or sell a product.
If a pesticide is unregistered in the United States, the exporter must
obtain a signed and dated foreign purchaser acknowledgement statement (FPAS)
showing that the purchaser is aware that the pesticide is unregistered and
cannot be sold in the United States. The FPAS can be submitted with every
shipment, or before the first shipment in that year, and it must include
various details regarding the exporter, importer and the product itself.
A pesticide is considered “unregistered” by FPAS requirements if it
could not be sold for use in the United States in the form that it was
produced in for export. However, exceptions to the FPAS requirement exist. A
pesticide product is considered to be “registered” if each ingredient is
within certified limits of a registered product, if the active ingredient
concentration is reduced, if there are changes in color or fragrance, or if
the pesticide is being exported for R&D that would not require an
Experimental Use Permit (EUP) in the United States.
Correct labeling
of a pesticide intended for export is necessary in order to guarantee that
it will meet all requirements for exportation. The label on the retail
package should comply with the registration in the country of destination;
additional labels in English, the language of the destination country, and
any other country known to be a transshipment point should be attached to
the outer container.
TSG assists U.S. companies exporting pesticides
abroad with foreign purchaser acknowledgement statements, interacting with
EPA, and assisting with foreign regulatory compliance issues that arise
during the export process.
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