On behalf of the following associations, I am attaching comments on EPA's "Guidance: Pesticides; Registrants on Plant Regulator Products and Claims, Including Plant Biostimulants." We greatly appreciate EPA's consideration of these comments and look forward to any follow up questions or information the Agency might need. Sincerely, David G. Beaudreau Jr.
Guidance for Plant Regulator Label Claims, including Plant Biostimulants
Activity
Agricultural Retailers Association filed 2 comments on this docket between Aug 8, 2019 and Dec 29, 2020. 0 other organizations filed here. The comment window closed 2036d ago.
What Agricultural Retailers Association filed (2)
On behalf of our associations, attached are comments on EPA's Draft Guidance for Pesticide Registrants on Plant Regulator Label Claims, Including Plant Biostimulants. Sincerely, Agricultural Retailers Association (ARA) American Seed Trade Association (ASTA) Biological Products Industry Alliance (BPIA) Biotechnology Innovation Organization (BIO) CropLife America (CLA) Golf Course Superintendents Association of America (GCSAA) Humic Products Trade Association (HPTA) National Association of Landscape Professionals (NALP) Responsible Industry for a Sound Environment (RISE) The Fertilizer Institute (TFI) U.S. Biostimulant Coalition (USBC)
Abstract
This document is intended to provide guidance on identifying product label claims that are considered to be plant regulator claims by the Agency, thereby subjecting the products to regulation under FIFRA as pesticides. Examples are provided of both claims that are considered plant regulator claims and claims that are not considered plant regulator claims. The guidance does not address or attempt to provide a regulatory definition for “plant biostimulant” or for “nutritional chemical.” As guidance, this document is not binding on the Agency or any outside parties, and the Agency may depart from it where circumstances warrant and without prior notice.
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