USA - Pesticide Registration Improvement Act (PRIA) registration fees are slated to increase by 5% on of October 1, 2024

Since PRIA was first signed into law in 2004, the law provided EPA with two 5% fee increases over 5 years to address salary and other cost increases. Under PRIA 5, those 5% increases are tied to EPA meeting specific milestones. The law state states that EPA may increase PRIA fees by 5% as October 1, 2024, if EPA has begun to implement an information technology system and includes all registering divisions and provides a real-time, accurate tracking system for all regulatory submissions to OPP. EPA advised the PRIA Coalition that since all registration actions are now tracked in Salesforce, it has met this condition and is planning on increasing PRIA fees by 5% on October 1. We expect that EPA will soon issue an alert advising registrants of the fee increase.

Under PRIA 5, EPA may institute a second 5% fee increase as of October 1, 2026, if the agency has begun to implement the appropriate process improvements identified in a required third-party audit. CPDA understands that EPA recently signed a contract with a vendor to conduct the audit. Under PRIA 5, the audit must be completed by December 29, 2024, and must address, at a minimum, the following:

• The 21-day content screen;

• The 45/90-day technical screen;

• Performance, processes, and progress towards reducing renegotiation rates and the average length of renegotiations;

• Performance, processes, and progress towards eliminating the backlog of registrant submissions not covered by a PRIA code;

• Performance, processes, and progress towards ensuring that all registrant submissions not covered by a PRIA code are completed by the deadlines specified in PRN 98-10: Notifications, Non-Notifications and Minor Formulation Amendments (October 22, 1998, and as amended) and as described in subsections (c)(3)(B) and 18(h) of section 3;

• Compliance with the statute’s provisions related to renegotiations and registrant submissions not covered by a PRIA code;

• Information technology systems;

• Recommended improvements to employee training;

• Performance, progress, and processes in completing registration review; and

• Other appropriate issues, such as submissions by inert suppliers and fast-track amendments.

The October 1 fee increase does not apply to annual maintenance fees. Under the law, EPA may collect $42 million annually in maintenance fees. The maintenance fee caps will not change for 2025, but the per product fee of $4875 could vary slightly depending on the number of active product registrations.

EPA has also advised the PRIA Coalition that it plans to deploy an update to its portal in November or December that will allow registrants to track the status of their pending regulatory actions.

To address ongoing PRIA timeliness issues, CPDA co-signed a letter from the PRIA Coalition to EPA Administrator Regan requesting a meeting with him to discuss significant concerns with the Agency’s review of pesticide product registrations. That meeting request was delegated to Assistant Administrator Michal Freedhoff. The coalition is working to schedule a time for that discussion.