The Household & Commercial Products Association (HCPA) recently contacted the Environmental Protection Agency (EPA) about pet spot-on registrations with expiration dates during the next several weeks or months. Since 2010, the EPA has registered pet spot-on products as “conditional” with a two-year expiration date, which has resulted in these products always being under registration and review. HCPA has worked with the EPA to eliminate this burdensome requirement for the agency and the registrants. Unfortunately, the shutdown interrupted those discussions and the backlog of actions may prevent the Agency from acting on these priorities, which continues to put affected manufacturers in a tough position. In addition, HCPA is concerned that enforcement could occur or that states and/or retailers could act before the registration is addressed appropriately.
In a January 15 response, the EPA indicated that they were unaware of this issue, but that it will now be a priority moving forward, and that potentially impacted registrations would not be cancelled if registrants had submitted renewals. The EPA is developing a response based on HCPA comments, but this may take time in the aftermath of the partial government shutdown. If a renewal request has already been submitted, the registration should be covered. However, if you have not yet submitted a renewal, keep any documentation from the electronic submission and send an email to the EPA with a record of the submission for documentation purposes. To better gauge the scope of the overall impact, HCPA also provided the EPA with a list of pet spot-on registrations that expire before March 1, 2019.
Please contact Dr. Steve Bennett, Senior Vice President, Scientific Affairs, at email@example.com for any additional comments or questions.