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Revised Draft Criteria for Biodegradability Claims on FIFRA Registered Products
(April 2011)

The EPA’s office of Pesticide Programs has developed standards for biodegradability claims, which is a critical concern for “down-the-drain” product, which can be aquatically toxic.

As part of a pilot program to encourage biodegradable products, the EPA’s Office of Pesticide Programs (OPP) has developed standards for language regarding the environmentally preferable characteristics used.

Biodegradability is a critical concern with “down-the-drain” products, which can be aquatically toxic. OPP recognizes the value of “biodegradable surfactants” (cleaning agents), a news release says. It also encourages product registrants to follow a list of suggested guidelines for descriptive language and use claims.

Examples include:

1. “All Ingredients” claims, where ingredients must achieve the pass level in a Ready Biodegradability Test and must not contain any carcinogens, mutagens,
or reproductive toxicants, among other standards. “Biodegradability does not guarantee low toxicity,” according to the April 2011 draft criteria. “Chemicals
known to be rapidly biodegradable have also been identified as carcinogens, mutagens or reproductive toxicants (CMR) To ensure that these products
do not pose an unacceptable risk to human health, or the environment, only products that do not contain ingredients considered to be CMRs will be eligible
to make a biodegradability claim.”

2. Surfactant class-based claims must meet the EPA Design for Environment (DfE) Criteria for Surfactants. The product cannot contain any ingredients
considered carcinogens, mutagens, or reproductive toxicants.

OPP has decided to recognize surfactants that protect aquatic life by rapid biodegradation to less toxic compounds by allowing the label to contain a claim of “biodegradable surfactants.”

The guidelines also outline acceptable test methods and criteria for review of listed carcinogens, mutagens and reproductive toxicants in FIFRA-registered products making biodegradability claims. FIFRA is the Federal Insecticide, Fungicide and Rodenticide Act, which provides control of pesticide distribution, sale and use.

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