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ARA, CLA, ASTA File Comments to EPA ANPR Concerning Treated Seed

Feb 09 2024

ARA, CropLife America (CLA), and the American Seed Trade Association (ASTA) submitted joint comments to the U.S. Environmental Protection Agency (EPA) regarding its Advanced Notice of Proposed Rulemaking (ANPR) concerning the Agency's approach to regulating seeds treated with a pesticide registered under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

ARA, ASTA and CLA request that EPA reinforce its interpretation of the Treated Article Exemption to exempt treated seeds from redundant registration under FIFRA. 

Members of ARA, ASTA and CLA would be directly impacted by any rule imposing additional or duplicative regulatory requirements for treated seed. 

The joint comments are divided into sections:

  • Introduction and summary of the ANPR;
  • Comments on specific issues as listed in the ANPR related to seed;
  • Benefits of treated seed;
  • Comments on our collective interests in the ANPR;
  • The existing regulatory framework; and 
  • Concluding remarks summarizing why no additional rulemaking is necessary to ensure adequate labeling and use of treated seeds.