The Household & Commercial Products Association (HCPA) commented on the recent information collection request for labeling requirements for Certain Minimum Risk Pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act, Section 25(b). The comments noted that the current approach, relying on labeling requirements to estimate the cost of 25(b) products, underestimates the costs incurred by the manufacturers of these products. In addition to labeling requirements, states also may require companies to submit confidential statements of formulation (CSF), Safety Data Sheets (SDS), efficacy data or any combination thereof, and recommends that the Agency pursue another consultation to better capture the costs incurred by manufacturers. Furthermore, difference in state and federal requirements influence the appropriate authorities that regulate or enforce minimum risk products.
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