A Compliance Guide to U.S. EPA Inert Ingredients Regulations
What Are Inert Ingredients?
In most pesticide products, besides the active ingredient, there are substances (or groups of structurally similar substances if designated by the Agency) known as inert ingredients. Inert ingredients can be, for example, solvents, carriers, aerosol propellants, fragrances, and dyes.
U.S. EPA Regulations of Inert Ingredients
U.S. Environmental Protection Agency (EPA) regulates inert ingredients under the following Acts and Regulations. Under PRIA5, there are 18 inert ingredient categories that cover new food, nonfood, low-risk polymer inert ingredients, as well as amendments to previously approved inert ingredients and nonfood inert ingredients that are substantially similar to approved inert ingredients.
Inert Ingredient Listings in InertFinder
InertFinder allows users to search for inert ingredients by chemical name and CAS Reg. No. to find inert ingredients permitted for use in the following three categories:
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Food and Nonfood Use: The only inert ingredients approved for use in pesticide products applied to food are those that have either tolerances or tolerance exemptions in the Code of Federal Regulations (CFR), many food use inert ingredients have use limitations and restrictions. All food use inert ingredients are also permitted for nonfood use.
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Nonfood Use Only: Permitted solely for use in pesticide products applied to nonfood use sites, such as ornamental plants, highway right-of-ways, rodent control, etc. Food use is not permitted.
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Fragrance Ingredient List
Commodity Inert Ingredients List
EPA has developed a list of inert ingredients that have been designated as commodity inert ingredients. For those inert ingredients so designated, applicants for pesticide registration or registration amendments will be afforded the ability to obtain these inert ingredients from various commercial sources without having to provide the Agency with specific supplier name and address information for each such source on the CSF Form.
Screenshot from the US EPA official website
Trade Name Inert Ingredient Database
EPA’s Office of Pesticide Programs (OPP) has developed a list of trade names for inert ingredients used in pesticide products registered under FIFRA. A trade name inert ingredient may be a single component, or (more commonly) a mixture of components.
Frequently Asked Questions
Q: What types of inert ingredients are there? Does a film-forming agent in a seed coating formulation count as an inert ingredient?
A: In pesticide products, any substance intentionally added to the product, or a group of substances designated by the authorities as structurally similar, is considered an inert ingredient. Examples include emulsifiers, solvents, fragrances, and dyes. A film-forming agent in a seed coating formulation is also considered an inert ingredient.
Q: Does a company need to have a branch or office in the U.S. to register inert ingredients independently with the EPA?
A: The U.S. EPA does not require companies to have a branch or office in the U.S. to register pesticides independently. However, the EPA does require that there be a U.S.-based contact to assist with communication. Therefore, for foreign companies, an agent located in the U.S. must be appointed to handle registration matters.
Q: Is the U.S. EPA Inert ingredients list publicly available? Can you share the link?
A: Yes, the Inert ingredients list is public, and you can find the information using the query website.
Q: What are the conditions for adding to the Trade Name Database?
A: Applicants who have an EPA company number and whose inert ingredients are listed in the EPA’s inert ingredient database are eligible to apply for inclusion in the Trade Name Database.
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U.S. EPA trade name database
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U.S. EPA Commodity Inert Ingredients list
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