Bergeson & Campbell, P.C. serves small, medium, and large pesticide product registrants and other stakeholders in the agricultural and biocidal sectors, in virtually every aspect of pesticide law, policy, science, and regulation.

By Lisa M. Campbell, Lisa R. Burchi, and Barbara A. Christianson

On November 16, 2020, the U.S. Environmental Protection Agency (EPA) announced that it will now provide pesticide registrants with electronic Certificates of Registration, commonly known as “Gold Seal” letters.  A Gold Seal letter from EPA certifies that a product to be exported is registered with EPA and meets all necessary registration requirements.  EPA states that this improved process will allow for the electronic Gold Seal letters to be e-mailed to registrants rather than physically mailed.

Under the new process, a company must submit a written request to EPA, identifying the company name, the EPA Registration Number at issue, and the country to which the product will be exported.  The Pesticide Registration Improvement Extension Act (PRIA 4) category is M006 and will cover up to five Gold Seal letters for one product with a one-month decision time.  The fee for fiscal year 2020-2021 is $291.  EPA states that because the fee is low and EPA’s timeframe to respond is short, this category is not eligible for small business waivers.  EPA also clarifies that distributor products are not eligible for Gold Seal letters.

Information on how to request a Gold Seal letter, including information on how registrants should present the letters to the U.S. Department of State when authentication is needed for business purposes, is available here

This announcement is a welcome improvement to the existing process, providing a key flexibility during the COVID-19 public health emergency.  EPA expects to transition permanently to this digital process, which it notes allows for faster processing, better tracking, and greater consistency.