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California DPR/EPA Concurrent Submission for Pesticide Products – Criteria Update (February 2015)

California’s Department of Pesticide Regulation (DPR) provides concurrent submission opportunities for certain pesticide product types. This process allows DPR to accept pesticide product registration and amendment applications before the federal EPA process in completed, which can have a significant impact on overall timelines and costs.

DPR released an updated set of criteria, found in California Notice 2015-03, that provides additional information regarding pesticide product concurrent submissions.

The following types of applications qualify for concurrent submissions:

    1. New pesticide products containing new active ingredients;

    2. New registrations or amendments of Experimental Use Permit pesticide products;

    3. New antimicrobial registrations or amendments to currently registered antimicrobial (note: The amendment must add new claim to control a pest that
        poses a threat to human health);

    4. New registrations of “public health pesticides” or amendments to registered “public health pesticides” if the amendment adds a new public health use to
        the product label; and

Note: A “public health pesticide” is a “minor use” pesticide as defined by FIFRA §2(11) that is labeled for use in a public health program or is used mainly in a public health
        program by a public health agency.

    5. Pesticide product registrants that receive prior approval from the Pesticide Registration Branch Chief.

Requests for Concurrent Submissions
If an applicant would like to request concurrent submissions and meets the criteria 1-4 listed above, the applicant must submit a letter stating the following:

   ▲ The product/amendment is not yet federally registered/accepted   

   ▲ Concurrent acceptance of the application is requested

   ▲ Which of the 4 criteria the product meets.

If the applicant wishes to request concurrent submission, but the submission does not meet one of the first four criteria, then the applicant must send a letter requesting approval to the Pesticide Registration Branch Chief before submitting an application to DPR. In the letter, the applicant must state:

   ▲ The product/amendment is not yet federally registered   

   ▲ Concurrent acceptance of the application is requested

   ▲ The justification with supporting documentation for the request.

The applicant will be notified of the decision, and if accepted may then proceed to submit the application.

Processing Concurrent Submissions
DPR reviews concurrent submissions in the order that they are received, along with all other applications for pesticide product registration. DPR concurrent submissions do not reduce data requirements. All data and information required by California regulation must still be submitted along with the California registration request.

Upon federal registration or acceptance of an amendment, it is the applicant’s responsibility to submit the following items to DPR:

   1. EPA’s acceptance letter  

   2. EPA stamped-accepted label

Additional information submitted to EPA in support of the proposed registration or amendment. 

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