In a significant move to streamline pesticide registration processes, China’s Institute for the Control of Agrochemicals, Ministry of Agriculture and Rural Affairs (ICAMA), issued a notice on January 20, 2025, regarding the reapplication for pesticide products that were not approved for registration.

Published on the China Pesticide Information Platform, the notice provides detailed guidelines and clarifications for enterprises seeking to reapply for pesticide registration or registration changes after an initial disapproval. This development is expected to enhance regulatory transparency and support businesses in navigating the complexities of pesticide registration in China.

Scope of Application

For pesticide registration and registration change applications (hereinafter referred to as “previous applications”) that have received a “disapproval” decision from the Ministry of Agriculture and Rural Affairs, applicants may submit reapplications (hereinafter referred to as “reapplications”) within five years from the date of completion of the previous application’s processing, in accordance with the requirements of the “Pesticide Registration Approval Service Guide” (Announcement No. 222 of the Ministry of Agriculture and Rural Affairs). Alternatively, applicants may request to use the relevant materials submitted in the previous application.

The following situations are not applicable for requesting to use the materials submitted in the previous application:

1. Pesticide registration is not approved due to current laws, regulations, and policy requirements;
2. The previous application did not meet the provisions of Article 8 of the “Administrative Measures for the Registration of Pesticide” or Announcement No. 345 of the Ministry of Agriculture and Rural Affairs;
3. The previous application was completed before January 20, 2020.

Submission of Materials Instructions

For requests to use the materials submitted in the previous application, the following materials shall be submitted:

1. Pesticide Registration/Registration Change Application Form;
2. Administrative Approval Completion Notice of the Ministry of Agriculture and Rural Affair providing details and explanations on pesticide that were not approved in the previous application (hereinafter referred to as the “Completion Notice”);
3. Application statement for using the materials submitted in the previous application (refer to the template);
4. Relevant supplementary materials required based on the Completion Notice of the previous application;
5. Other materials.

The materials submitted for the reapplication shall be bound in professional volumes, and each volume shall be accompanied by the Completion Notice of the previous application.

Acceptance, Review, and Evaluation

The reapplication shall be processed in accordance with the procedures for the acceptance, review, and evaluation of pesticide registration and registration changes, with approvals conducted in sequence. In principle, ICAMA shall complete the technical review of the reapplication within six months and submit the review opinions to the Pesticide Registration Evaluation Committee for evaluation.

In principle, only the materials submitted in the reapplication shall be subject to technical review, except in cases where the “Administrative Measures for the Registration of Pesticide,” “Requirements for Pesticide Registration Materials,” and relevant technical standards have changed, rendering the materials submitted in the previous application no longer compliant with current requirements.

Other Matters

1. When accepting and publicizing reapplications for pesticide registration products, it shall be noted as “reapplication.”
2. If general materials such as pesticide production licenses and certificates for technical material sources of formulations are no longer in a valid state, compliant materials shall be re-submitted for reapplication.

This notice marks a positive step toward simplifying pesticide registration processes, and REACH24H is committed to helping enterprises leverage these opportunities effectively.

How REACH24H Can Help

Navigating the regulatory landscape for pesticide registration in China can be challenging, especially with evolving requirements and stringent compliance standards. REACH24H, a leading regulatory consulting firm, offers expert assistance to enterprises seeking to reapply for pesticide registration or registration changes. Our services include:

• Regulatory Guidance: Providing up-to-date insights on ICAMA regulations and ensuring compliance with the latest requirements.
• Document Preparation: Assisting in the preparation and professional binding of application materials to meet ICAMA standards.
• Technical Review Support: Helping clients address technical review challenges and ensuring timely submission of reapplications.
• Ongoing Compliance: Offering continuous support to maintain compliance with changing regulatory and technical standards.

With REACH24H’s expertise, businesses can streamline their reapplication processes, reduce delays, and achieve successful pesticide registration in China. For more information or assistance, feel free to contact our team of regulatory experts.