Inert Ingredient Petitions

Pesticide products consist of active and inert ingredients as defined by FIFRA, the federal statute governing pesticides. An active ingredient is one that “prevents, destroys, repels or mitigates a pest, or is a plant regulator, defoliant, desiccant or nitrogen stabilizer.” By law, the active ingredient in a pesticide must be identified by name on the product’s label along with its percentage by weight. All other ingredients in a pesticide are called inert ingredients. Inert ingredients play a key role in the overall effectiveness of a pesticide product, such as extending a pesticide product’s shelf-life or preventing degradation due to sunlight exposure.

Pesticide products often contain more than one inert ingredient, and all inert ingredients, including those in inert mixtures, must be approved for use by EPA. For inert ingredients applied to food, a tolerance or tolerance exemption is also required. A petition for approval must be submitted for new inert ingredients and any changes/amendments to a currently approved food use pattern. EPA reviews all Confidential Statements of Formula (CSF) submitted with a covered pesticide registration application to ensure that inert ingredients are either approved or pending with EPA for the labeled use of the pesticide formulation.

TSG provides comprehensive inert ingredient services for the various product types and uses regulated by EPA, including:

Food and Nonfood Use

TSG is experienced in obtaining approval for inert ingredients used on food, including the establishment of a tolerance or tolerance exemption. TSG assists companies in preparing a new inert ingredient petition or an amended use petition, monitoring field and laboratory studies, analyzing and interpreting data, preparing data packages and negotiating with EPA. Once an inert ingredient is approved for food, it is also permitted for nonfood use.

Nonfood Use Only

TSG assists companies in preparing new inert ingredient petitions for pesticide products applied to nonfood use sites such as ornamental plants, highway right-of-ways, rodent control and consumer products.

Fragrance Ingredient List (FIL)

FIL ingredients are only allowed for nonfood uses, and they are subject to additional limitations and Fragrance Notification Program requirements. For fragrance products, TSG is highly experienced in working with manufacturers to get individual ingredients approved for use in pesticide products.

Trade Name Inert Ingredients

EPA evaluates trade name products based on individual components of that product. TSG assists companies to ensure that each component of the trade name/mixture is approved for use as an inert ingredient.

Minimum Risk FIFRA Section 25(b) Inert Ingredients

Minimum risk pesticide producers may use list “4A” inert ingredients in amounts they believe will result in an effective product only when combined with 25(b) active ingredients. TSG can help companies ensure that they use 25(b) compliant inert ingredients in their product.

USDA’s National Organic Program (NOP) Inert Ingredients List

Some inert ingredients may be eligible for use under USDA’s NOP program. EPA ensures that USDA’s policies are implemented with regard to organic claims made by registered pesticide products. TSG helps companies ensure that any organic pesticide product is using USDA’s NOP compliant inert ingredients.