Pursuant to the Pesticide Registration Improvement Act of 2022 (PRIA 5), the conditions around which renegotiations have been conducted during the pesticide registration process have been revised significantly, and are now summarized in a May 5, 2023 U.S. Environmental Protection Agency’s (EPA) memo directed to pesticide registration staff, which is available here.

While directed to EPA staff, the EPA memo is also helpful to manufacturers and other registrants of disinfectants and pesticide products generally on how to handle renegotiations while in the process of registering products with the Agency.

In brief, under PRIA 5, there are now only two situations where renegotiations are allowed for the purpose of extending the time period for review of the contemplated registration action: 

1. There is new or additional data or information from the applicant that is necessary for the administrator to make a decision on the application that cannot be made available within the original decision time review period; or
2. A public comment period associated with the application generates significant comments that cannot be addressed within the original decision time review period.

Historically, EPA used the agency’s lack of resources as the basis for many renegotiations resulting in an extremely high number of pesticide registrations conducted outside of the required time review periods established under PRIA. 

ISSA encourages you to review the complete EPA memo summarizing how the revised renegotiation process under PRIA 5 will operate.