Chinese Authority is to Revise the Pesticide Labeling and Instructions Management Measures

On June 14, 2023, the Ministry of Agriculture and Rural Affairs in China released the "Management Measures for Pesticide Labels and Instructions (Revised Draft for Soliciting Opinions)" on its website. If companies in the industry have any suggestions for the draft, they need to submit their revised opinions to the Pesticide Management Division of the Ministry of Agriculture and Rural Affairs before June 30.

The management measures for pesticide labeling and instructions are one of the most important regulations affecting pesticide products. CIRS Group has compared the current "Management Measures for Pesticide Labels and Instructions" with the draft for soliciting opinions, and summarized and commented on the main changes as follows for your reference.

Article 2: Pesticide products stored, transported, sold, and used within China shall have labels printed or attached to their packaging. If the packaging size is too small to include the required information, corresponding instructions shall be provided.

CIRS comments: The current management measures for pesticide labels and instructions only require pesticide products operated and used within China to have labels. However, the new changes add requirements for storage and transportation, and replace "operated" with "sold". This means that pesticide products need to have labels throughout the entire process from factory production to market distribution."

Article 8: Pesticide labels shall include the following information:

(4) Scope of use, method of use, dosage, technical requirements, and precautions, and the corresponding dilution ratio shall be indicated according to the method of use;

Article 17: The dilution ratio refers to the ratio of pesticide formulation to water (oil, soil and other media) according to the method and dosage of use.

CIRS comments: We can look at these two articles together. Article 8 adds the requirement to indicate the corresponding dilution ratio according to the method of use. This reasonable new provision has actually been implemented for some time in the industry, and now it is being legalized through the revised management measures for instructions. Article 17 adds the definition of dilution ratio accordingly. This provision is extremely convenient for farmers to use pesticides in the future, as they will no longer have to worry about how much water to add to dilute the pesticide when reading the label.

Article 9: In addition to the contents stipulated in Article 8, the following labeling requirements shall also be met:

(4) Registered herbicides for genetically modified crops shall indicate the applicable genetically modified crop and transformation name; for herbicide-tolerant crops such as gene editing, the corresponding applicable crop variety name shall be indicated;

Article 33: Herbicides for genetically modified crops shall be labeled with the "genetically modified crop and transformation name" in red; for herbicide-tolerant crops such as gene editing, "herbicide-tolerant crop" shall be indicated.

CIRS comments: Article 9 (4) and the second paragraph of Article 33 are newly added provisions. Since the Ministry of Agriculture and Rural Affairs announced the registration requirements for target herbicides for genetically modified herbicide-tolerant crops last year, I believe that many companies have been conducting experiments on genetically modified herbicide-tolerant crops. Approval of pesticides for genetically modified crops will also be a major issue in the near future, and there are already regulations on how to label them, so everyone should take it seriously."

Article 24: Each pesticide packaging for storage, transportation, and sales shall be labeled with a traceable electronic information code, and there should be a correlation between the traceable electronic information codes of the internal and external packaging.

Article 27: Each pesticide packaging for storage, transportation, and sales shall be printed or attached with an independent label. It is not allowed to share packaging, labels, or use the same label with other pesticides or items.

CIRS comments : We can also look at these two articles together. The sentence in Article 24 is an added content, which manages the bundled sales of two types of pesticides in one package in the market. Article 27 has changed from "each minimum packaging of pesticides" to "each pesticide packaging for storage, transportation, and sales". This also manages the sales of two types of pesticides in one package, such as combo or connected packaging. Behaviors that are not managed in the current regulations for label management are considered in this revised version."

Article 31: Pesticide labels and instructions shall not use unregistered brand logos or trademarks, and the same production enterprise shall only use one brand logo or trademark.

If the label uses a registered brand logo or trademark, it shall be indicated in the four corners of the label, and the area occupied shall not exceed one-ninth of the label area, and the font size of the text part shall not be larger than half of the pesticide name.

CIRS comments: This article's changes may have the most significant impact on the industry. It adds brand logos and specifies that the same production enterprise can only use one brand logo or trademark, meaning that all products of the same production enterprise can only use the same brand logo or trademark. This may raise the question of whether some well-known brands will disappear if they have different trademarks for each product. If the company name is already the brand logo, it is not an issue. However, if each product has a separate trademark, they will need to be changed to a unified brand logo or trademark in the future, which will have a significant impact. The second sentence changes the current "not larger than" to "not larger than half of the pesticide name," indicating that the font size requirement for trademarks will become smaller in the future!

The above is only a personal opinion. If you in the industry have suggestions on this draft, please provide your opinions to the Ministry of Agriculture and Rural Affairs in a timely manner!

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