The volume and complexity of scientific study data to support governmental approval of pesticides has steadily and dramatically increased over the past 20 years. As a result, regulators, industry and growers are expressing strong interest to achieve more progress in harmonization of the registration processes for pesticide approval between the United States and Canada. Farmers and growers have shown increasing desire to transport pesticide products across the border between the United States and Canada. Transportation of regulated goods across international borders creates a particular set of complications that harmonization seeks to resolve.



CropLife America (CLA), CropLife Canada (CLC) and the Mexican trade association AMIFAC have created a working group to represent industry to the North American Free Trade Agreement Technical Working Group on Pesticides (NAFTA TWG) and to work together to achieve harmonization.



Over the past several years, the NAFTA TWG has made progress in harmonizing science-based test protocols and test guidelines requirements, such as identifying what studies need to be conducted and submitted in the U.S. and Canada.



The U.S. Environmental Protection Agency (EPA) and Canada's Pest Management Regulatory Agency (PMRA) differ significantly in their regulatory approval process for pesticides. Registration review time, petition amendment, risk assessment, labels, establishing tolerances or maximum residue limits (MRLs) and label amendment are all approached differently by the American and Canadian agencies. Equally challenging is the sheer number of pesticide products registered for use in both countries. In 2004, there were 16,115 registered pesticide products containing 1,015 active ingredients in the U.S. and 5,274 registered pesticide products containing 525 registered active ingredients in Canada. Since 1997, more than 149 new active pesticide ingredients and 2,489 new uses have been registered by the EPA alone.



Lack of harmonized processes can have real impacts on growers, as differences can affect availability and cost of products.



Some pesticide producers have participated in two pilot programs with EPA and PMRA to facilitate harmonization: the own-use pilot program and the joint-label pilot program. The first allows individual growers to import certain products into the United States for private use while the second attempts to create one label that meets the regulatory requirements for both countries. CLA supports these initiatives and a collaborative process with industry and the government agencies to meet mutual goals.



Because the differences in the approval processes of pesticides in the U.S. and Canada reside within the processes of registration, and not within the mandate or authority of the two agencies, CLA advocates that a regulatory, as opposed to legislative, solution is best suited to achieve harmonization.