Pesticides eBulletin: Mode of Action labelling and Christmas applications sift for Plant Protection Products

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HSE eBulletin

Arrangements for Plant Protection Products sift during Christmas period 2020

New arrangements are in place for the applications sift for Plant Protection Products over the Christmas holiday period for 2020.

There will be no extended closing date for the sift prior to Christmas as in previous years; instead we will continue to receive electronic applications over the Christmas period and normal sift closure dates will be applied as detailed below. Applications accepted for further evaluation following these sifts will be given acceptance and target dates according to relevant sift date as shown.

 

Please be aware letters notifying applicants of acceptance or rejection of their applications from sift of 15 December will be sent prior to Christmas but those from sifts of 22 and 29 December will not be sent until after completion of the sift of 5 January 2021.

 

  • Sift of 15 December 2020
    Sift closure date Tuesday 8 December 2020 at 18:00 hours.  Applications accepted following this sift will have a target date calculated from 15 December 2020. 

  • Sift of 22 December 2020
    Sift closure date Tuesday 15 December 2020 at 18:00 hours.  Applications accepted following this sift will have a target date calculated from 22 December.

  • Sift of 29 December 2020
    Sift closure date Tuesday 22 December 2020 at 18:00 hours.  Applications accepted at this sift will have a target calculated from 29 December.
  • Sift of 5 January 2021
    Sift closure date Tuesday 29 December at 18:00 hours. Applications accepted at this sift will have a target calculated from 5 January 2021.

Applications are to be submitted via email to applications@hse.gov.uk. Those too big to be sent by email should be submitted via ShareFile. Please submit any requests for links to ShareFile to applications@hse.gov.uk.


Mode of Action labelling for Plant Protection Products in the UK

Purpose

This Regulatory Update details a new requirement to include information on the Mode of Action (MoA) on all relevant Plant Protection Product (PPP) labels in order to help farmers and agronomists make informed decisions as part of resistance management strategies.

 

Background

In order to support the widespread adoption of responsible resistance management practices, members of the industry body ‘CropLife International’ have made a voluntarily commitment to include Mode of Action (MoA) icons and groups on all product labels by 2023.

 

In 2017 each of the UK Resistance Action Groups (UK-RAGs), weed, fungicide and insecticide, separately met to discuss this initiative and agreed that the inclusion of MoA information on product labels should be actively considered with a view to implementation. 

 

The UK-RAGs released the following joint statement: “Resistance is probably the greatest threat to product efficacy. The combined impact of few new active substances, and even fewer modes of action, and the increasing loss of existing products means that this risk will increase. Common aspects of all resistance management strategies are to prevent repeat treatment of survivors with the same mode of action and to rotate modes of action. The RAGs have therefore agreed that greater prominence of the mode of action will help farmers and agronomists make informed decisions.

 

HSE considered the joint RAG position and consulted with the CPA on proposals to introduce information on the MoA to relevant PPP product labels.  It has consequently been decided that the addition of MoA information to PPP labels will be a requirement in the UK from January 2023 onwards.

 

What is meant by the Mode of Action (MoA)?

The MoA referred to in this Regulatory update is not the specific biological mode of action, but rather the code or group assigned to each active substance by the relevant RAC MoA classification scheme. 

 

The main three classification schemes which should be used are as follows:

  • Fungicide Resistance Action Committee (FRAC)
    The FRAC MoA classification scheme uses a number (sometimes a letter/number combination) to distinguish fungicide groups according to their biochemical mode of action (MoA) in the biosynthetic pathways of plant pathogens.

  • Insecticide Resistance Action Committee (IRAC)
    The IRAC MoA classification scheme classifies insecticides and acaricides into two types of MoA groups: numbered groups whose members are known or thought to act at specific target sites, and UN groups of undefined or unknown mode of action. 

  • Herbicide Resistance Action Committee (HRAC)
    HRAC uses codes to create a uniform classification of herbicide modes of action.  Herbicides are classified into groups according to their target sites, MoA, similarity of induced symptoms or chemical classes.

Scope

This Regulatory Update only applies to professional PPPs containing chemical active substances for which there is an established MoA classification scheme in place: fungicides, herbicides, insecticides and acaricides have well defined classification schemes in place via FRAC, IRAC and HRAC. 

 

For products such as molluscicides and nematicides, there may not be a classification scheme in place and therefore information on the MoA does not need to be included on the label.  Within these schemes there may be various active substances listed as ‘unknown’ MoA and therefore these are excluded until they are assigned into a group.

 

Biological PPPs/biopesticides (pheromones, microbials, plant extracts, other novel modes of action) are recognised as mostly having complex modes of action and are not in scope.  However, in the interest of good practice, HSE encourages the inclusion of general wording on resistance management and using integrated programmes on all product labels. 

 

A small number of biopesticides do have assigned MoA classes, and applicants may choose to voluntarily add this information to the labels.

 

All amateur products are also out of scope.

 

If you are in any doubt as to whether you need to include this information on your product label, please contact HSE at CRD.Information.Management@hse.gov.uk

 

What information must be included on the label and how should it be presented?

The information presented on the label can be limited to solely the MoA code, but the inclusion of further details, such as the Group name, may also be beneficial.  There is no requirement to use a standard format, font or font size and additionally the location of this information on the label is left to the discretion of each company.  An example of how this information may be presented on product labels is included in the CropLife International guidance (see Further Information).  An appropriate location on the label may be the Resistance section, along with any resistance management strategies.

 

What if the MoA classification changes?

Sometimes an active substance may change from one MoA code to another, when research indicates the MoA is different from previously suspected.  In all situations, the onus is on companies to ensure the MoA stated on their product labels is up to date and in line with the current classification. 

 

When must this information be included on labels?

There is no immediate requirement to add the MoA information to product labels.  Companies are encouraged to do so when convenient (e.g. at the next label print), and CRD will include this in any label amendments made as part of ongoing applications.  However, it is a requirement to include this information on all relevant PPP labels from the start of 2023 onwards.

 

Further Information

 

 

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