Since 1989, various White House administrations have sought to reinstate old and prohibited fees under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and the Federal Food, Drug and Cosmetic Act (FFDCA). These program fees would go to the U.S. Treasury, and would not be reserved for registration support work within the U.S. Environmental Protection Agency (EPA). Furthermore, such additional fees would require multiple amendments to FIFRA and FFDCA, undoing the positive gains made by Pesticide Registration Improvement Extension Act (PRIA). For Fiscal Year 2013, industry registrants have already agreed to maintenance and registration service fees under the Pesticide Registration Improvement Extension Act of 2012 (PRIA III) in the range of $40 million per year.
CropLife America’s (CLA) Outlook
- CLA praises the reauthorization of PRIA III. Its passage highlights the ability of stakeholders to work together towards improved processes that maintain a high level of protection for public health and the environment.
- CLA opposes further fee increases beyond PRIA III fees, reinstatement of tolerance fees, and creation of proposed new fees. These proposals violate the spirit of the compromise that originally resulted in PRIA.
- EPA’s scientifically rigorous regulation of the pesticide industry would not be strengthened by the proposed fee increases beyond those authorized by PRIA.
- Beginning in 2004, PRIA has significantly improved the predictability and speed of the pesticide registration process.
- PRIA III (P.L. 112-177) is effective for five years and will expire September 30, 2017. EPA’s commitment to PRIA demonstrates the Agency’s willingness to find new approaches to streamline the pesticide registration process.
- Additional registration and tolerance fees are contrary to PRIA and would jeopardize the stakeholder compromise that brought it into being.