Major Changes in Pesticide Registration Management in China

The final versions of five regulations on pesticide registration have recently been released. The regulatory update has undergone a multi-year review process.

Beginning in April 2022, China's Pesticide Management Department under the Ministry of Agriculture and Rural Affairs (MOA) solicited feedback on these pesticide regulations for the first time. This was followed by a second draft released for comment in early 2023 and a third notification in November 2024. The process has now concluded with the official issuance of Ministry of Agriculture and Rural Affairs Order No. 3 and Announcement No. 925.

These five regulations will come into effect from January 1, 2026. The five regulations are:

• Measures on the Management of Pesticide Registration;
• Measures on the Management of Pesticide Production Licenses;
• Measures on the Management of Pesticide Business Licenses;
• Measures on the Management of Pesticide Labels and Manuals; and
• Measures on the Management of Pesticide Registration and Tests

To help enterprises better understand the requirements of the five regulations, CIRS has analyzed the details in the following.

1. Measures on the Management of Pesticide Registration

(1) Article 8: “The content of active ingredients and formulation of pesticides shall comply with the principles of improving quality, protecting the environment and promoting sustainable agricultural development. The formulation of pesticide products shall be scientific, reasonable and convenient for use.

“For single-dose products with the same active ingredient and dosage form, the content gradient shall not exceed three.

“Mixed formulation shall not have more than two active ingredients, and herbicides and seed treatment agents shall not have more than three active ingredients. Mixed formulation with the same active ingredients and formulations shall not have more than three formulations, and the total content gradients for the same formulation shall not exceed three. Pesticides with low active ingredient content that are used directly without dilution or dispersion shall be classified separately.

“Pheromone and other attractant and disorienting products are registered based on their main active ingredients.

“Specific requirements for the types and content gradients of active ingredients in formulation will be separately formulated by the Ministry of Agriculture and Rural Affairs.

Comments: It mainly provides reasonable regulations on the registration requirements for attractant and disorienting products such as pheromones, and registration is based on the main active ingredients, without limiting the number of active ingredients contained.

(2) Add one paragraph to Article 14 as the first paragraph: "If the applicant is a legal person or other organization, it shall designate a specific person within the organization to be responsible for the relevant work related to the pesticide registration application."

(3) A new paragraph is added to Article 15 as the second paragraph: "Where the pesticide registration business is entrusted to another entity or individual, a letter of authorization signed or stamped by both parties shall also be submitted. The letter of authorization shall clearly state the name of the agent, the matters to be entrusted, the authority, etc.

Comments: The main change is the requirement for a power of attorney when entrusting other entities to handle pesticide registration. This is equivalent to stipulating the role of consulting companies in the submission of documents.

(4) Delete the second paragraph of Article 17.

When applying for new pesticide registration, an application for registration of both the new pesticide technical and the new pesticide formulation shall be submitted simultaneously, and pesticide standards shall be provided.

Within six years from the date of new pesticide registration, if other applicants submit data obtained by themselves or authorized by the new pesticide registration certificate holder to apply for registration, they shall apply as new pesticide registration applications.

(5) Article 18, paragraph 1, is amended to read: "For pesticides containing new compounds that have obtained initial registration, within six years from the date of registration, any other applicant who applies for registration of a pesticide containing the same new compound shall obtain authorization from the registration certificate holder to provide complete registration information, except where the applicant submits data obtained by the applicant itself." A new paragraph is added as paragraph 2: "If any other applicant applies for registration of the pesticides mentioned in the preceding paragraph by submitting data obtained by the applicant itself, the application shall be handled in accordance with Article 17 of these Measures."

Comments: It clarifies that the registration information held by the holder of a new active ingredient pesticide registration certificate only requires the authorization and consent of the registration certificate holder within the six-year protection period of the registration information. If, within six years of the registration of a new active ingredient, other applicants submit data they have obtained to apply for pesticide registration as mentioned in the preceding paragraph, they shall apply for registration as new pesticides and need to submit registration for both the technical and the formulation at the same time.

(6) The second paragraph of the original Article 18 is changed to Article 19 and amended as follows: "Where pesticide registration information is transferred in accordance with Article 14 of the Pesticide Management Regulations, the transferee shall apply for pesticide registration with the following materials:

1. “The transfer contract between the two parties;
2. “Supplement and complete relevant registration information in accordance with the pesticide registration information requirements;
3. “Application by the original pesticide registration certificate holder to cancel the corresponding registration certificate.”

Comment: This clause was not included in the previous draft for public comment. It clarifies the required documentation for transferring pesticide registration information. The key focus is on supplementing and completing the relevant registration information in accordance with the pesticide registration requirements. In other words, it addresses how to apply for registration using transferred materials when the transferor's documentation is incomplete.

(7) The original Article 20 is changed to Article 21 and is amended as follows: "Provincial agricultural and rural departments shall conduct a preliminary review of the materials submitted by the applicant within 20 working days from the date of acceptance of the application, put forward preliminary review opinions, and submit the preliminary review opinions and all application materials directly to the Ministry of Agriculture and Rural Affairs within 5 working days.

“If the applicant fails the preliminary review, the provincial agricultural and rural department may notify the applicant in writing and explain the reasons based on the applicant's wishes."

Comments: It clarifies the responsibilities of provincial pesticide testing agencies and emphasizes the importance of the preliminary review opinions of provincial pesticide testing agencies.

(8) The word “shall" in the first paragraph of Article 21 is changed to “organize its affiliated pesticide testing institutions.” A new paragraph is added as the second paragraph: “If the pesticide testing institutions affiliated with the Ministry of Agriculture and Rural Affairs discover minor flaws in the application materials that require correction during the technical review process, they may require the applicant to provide additional materials within five working days. The relevant period shall not be counted towards the review period.”

(9) The original Article 23 is changed to Article 24 and is amended as follows: “After the pesticide registration application is accepted and before it enters the technical review, the applicant may withdraw the registration application and reapply after supplementing and completing the relevant information.

“The Ministry of Agriculture and Rural Affairs may require applicants to provide additional information within a specified timeframe, based on the opinions of the Pesticide Registration Review Committee.”

Comments: The time limit and conditions for submitting supplementary information have been clarified, and the conditions for withdrawing the original registration application have been updated.

(10) “Article 25: If, during the pesticide registration review and evaluation process, it is considered that the test data submitted by the applicant requires verification, the Ministry of Agriculture and Rural Affairs may organize verification tests and inform the applicant of the required time.

(11) Article 26: If an applicant re-registers a product that has not been approved by the Ministry of Agriculture and Rural Affairs, they may use the corresponding registration information they previously submitted. Specific requirements will be separately stipulated by the Ministry of Agriculture and Rural Affairs.

Comments: Both are newly added articles. Article 25 confirms the legality of verification tests, and Article 26 legalizes the provisions of the Notice issued by the Pesticide Testing Institute on January 20, 2025, which details matters related to re-application for pesticide registration of unapproved registered products.

(12) “Article 31 If a pesticide registration certificate holder changes its name or needs to renew its pesticide registration certificate due to enterprise merger or division, it shall apply to the Ministry of Agriculture and Rural Affairs within 30 days from the date of the change and submit relevant supporting documents.

“The Ministry of Agriculture and Rural Affairs shall complete the review within 20 working days from the date of acceptance of the application and reissue the certificate if the conditions are met.

(13) “Article 32 If any of the following circumstances occur during the validity period of a pesticide registration certificate, the holder of the pesticide registration certificate shall apply to the Ministry of Agriculture and Rural Affairs for a change:

1. "Changing the scope of pesticide use, method of use, or dosage;
2. "Changing the components of the pesticide other than the active ingredient;
3. “Changing the toxicity level of a product;
4. “The content of the active ingredient in the technical product has changed;
5. "Product quality standards have changed;
6. “Other circumstances prescribed by the Ministry of Agriculture and Rural Affairs.”

(14) One item is added to the original Article 40 as the third item: “(3) The holder of the pesticide registration certificate changes its name or merges or splits up, and a new pesticide registration certificate has been issued.” The original Article 40 is as follows:

Article 40: In any of the following circumstances, the Ministry of Agriculture and Rural Affairs shall cancel the pesticide registration certificate and make it public:

1. The validity period has expired and has not been renewed;
2. The holder of the pesticide registration certificate is terminated according to law or is no longer qualified to apply for pesticide registration;
3. The pesticide registration information has been transferred according to law;
4. Other circumstances where the pesticide registration certificate should be cancelled.

Comments: The previous “change of pesticide registration certificate holder” has been changed to “pesticide registration certificate holder changes its name, or corporate mergers and divisions require the change of pesticide registration certificate holder”. It may not be easy to change the registration certificate holder at will in the future.

(15) Article 35 is amended to Article 38 and reads: “Pesticide registration certificate holders shall collect and analyze changes in the safety and effectiveness of pesticide products and promptly report to the Ministry of Agriculture and Rural Affairs; any recall of pesticide products or pesticide use accidents shall be promptly reported to the local agricultural and rural affairs department.”

(16) Article 36 is amended to Article 39 as follows: "For pesticide varieties registered for more than 15 years, the Ministry of Agriculture and Rural Affairs shall organize periodic evaluations based on production and use and changes in industrial policies. The evaluation results shall serve as an important basis for registration renewal reviews.

“The periodic evaluation mainly includes the following contents:

1. “Target organism resistance;
2. “Crop safety;
3. “Agricultural product quality and safety;
4. “The health and safety of humans and animals;
5. "Impacts on beneficial biological safety and the ecological environment."

Comment: China is also about to join the ranks of periodic evaluation of pesticides, which is similar to the re-evaluation of the EU and the United States. Enterprises should attach importance to the periodic evaluation of pesticides.

II. Measures on the Management of Pesticide Production Licenses

(1) Article 18, paragraph 2, is recast as Article 19 and is amended as follows: “Pesticide manufacturers may, within the scope of their pesticide production licenses and in accordance with Article 19 of the Pesticide Management Regulations, accept commissions from new pesticide developers and other pesticide manufacturers to process or repackage pesticides; they may also accept commissions from companies exporting pesticides to China to repackage pesticides.

“Pesticide technical (concentrated) products may not be outsourced for production.”

(2) Add two articles as Articles 20 and 21:

Article 20 The entrusting party and the entrusted party shall sign an entrustment contract, which shall clearly specify the name, specifications, quantity, quality standards, labeling, trademark use, term, fees, etc. of the products entrusted for processing and repackaging.

“The entrusting party shall provide the entrusted party with technical information such as the product formula, production process and technology, and product quality standards of the entrusted processed products.

“Article 21 prohibits renting or lending pesticide registration certificates under the guise of commissioned processing or repackaging.”

Comments: It is clearly stated that the production of technical materials (technical concentrations) shall not be entrusted to others, and it also stipulates details such as the need for the principal and the trustee to sign a contract.

III. Measures on the Management of Pesticide Business Licenses

(1) Article 21 is amended to read: "Those who use the Internet to sell pesticides must obtain a pesticide business license and file the website name, network platform name, application name, etc. with the issuing authority within 20 days of going online. This does not apply to those who sell public health pesticides or pesticide manufacturers who use their own websites to sell their own products.

“Internet pesticide operators that have been operating online before January 1, 2026, must complete the registration before January 31, 2026.

“Restricted-use pesticides and other pesticides specified by the Ministry of Agriculture and Rural Affairs may not be sold on the internet.

“Using pesticides beyond the business scope restrictions or using the internet to sell the pesticides specified in the preceding paragraph, will be handled as if they have not obtained a pesticide business license.”

(2) Article 22: Those who use the internet to sell pesticides must continuously display all information contained in their pesticide business licenses, or a link to it, in a prominent location on their website homepage or main page of their business activities. If the information on the pesticide business license changes, the page content must be updated within ten working days.

“Pesticide manufacturers that use their websites to sell their products shall continuously display all information contained in their pesticide production licenses or their link identifiers. If the information on the pesticide production license changes, the page content shall be updated within ten working days.

“Those who use the Internet to sell pesticides should fully, truthfully and accurately display the labels and other information of the products actually sold.

(3) “Article 23: Third-party pesticide internet trading platforms shall establish and implement management systems such as pesticide business qualification verification, online business behavior supervision, pesticide information display, real-name pesticide purchase, transaction record preservation, and complaint and report handling, and actively cooperate with the agricultural and rural departments in supervision and law enforcement.”

Comment: With the rise of online shopping, laws and regulations have also changed with the times, improving and standardizing the obligations and responsibilities of online pesticide dealers.

It is worth noting that the relevant provisions on pesticide bundled sales are not reflected in the final version of the Pesticide Business License Management Measures.

IV. Measures on the Management of Pesticide Labels and Manuals

(1) Pesticide formulation products should be marked with the registration number of the technical (technical concentration) used and the name of the manufacturer. The relevant content can be reflected in the traceable electronic information code, and the holder of the registration certificate of the formulation product is responsible for the authenticity.

Comments: Formulation products are marked with the registration certificate number and manufacturer name of the technical material used. This is also a further standardization of the market. The technical material manufacturers support the formulation manufacturers to obtain registration by proving the source of the technical material. In the subsequent actual production process, the registered technical material must also be used to produce the formulation and reflect the information of the technical material supplier.

(2) Pesticide products with the same registration number shall be marked with the same trademark, and products that are commissioned for processing or repackaging shall not be marked with the trademark of the trustee.

Comments: The revised “one certificate, one label” approach, previously adopted for public comment, has been replaced with “one certificate, same label”. The officially released version fully considers that a company may need to display multiple trademarks on products with a single registration certificate, such as both the company's trademark and the product's trademark. It also stipulates that products processed under a contract or repackaging agreement may not bear the trustee's trademark. This translates to the fact that even products processed under a contract or repackaging agreement must bear only the trademark of the entrusting party, the registration certificate holder. This discourages the current practice of labeling pesticide products with the trustee's trademark during contract processing or repackaging.

(3) If a pesticide product is registered for use on herbicide-resistant crops, the name of the crop variety used shall be marked; if it is used on herbicide-resistant genetically modified crops, the name of the applicable crop and transformant shall be marked.

Comment: Currently, herbicide-resistant crops in agricultural production are mainly divided into two categories: genetically modified and non-genetically modified. Pesticide products used for these two types of crops should be labeled in accordance with Announcement No. 925.

(4) If pesticide products require the addition of designated adjuvants when used, the relevant information of the adjuvants should be marked.

Comment: With the increasing popularity of drone spraying, many pesticide products require the use of exogenous adjuvants. This requirement applies to the use of exogenous adjuvants. Generally, for special pesticide products that require the addition of specified adjuvants during use, field efficacy test data using the corresponding adjuvant and pesticide must be submitted during registration.

V. Measures on the Management of Pesticide Registration and Tests

(1) Article 16 is amended to read: "Before conducting pesticide registration trials, pesticide registration applicants shall, in accordance with the procedures and requirements prescribed by the Ministry of Agriculture and Rural Affairs, file a record with the provincial agricultural and rural affairs department at the location of the registration trial through the Ministry of Agriculture and Rural Affairs’ pesticide management information platform.

“The filing information in the preceding paragraph includes the filing entity, the name, content and dosage form of the active ingredient, the test project, the test location, the test unit, the test start time, the commission agreement signed with the test unit, and safety precautions. The filing information for new pesticide trials also includes the mechanism and mode of action.

“If there are changes in the test project, location, unit, etc., the pesticide registration applicant shall re-register in accordance with the provisions of the preceding paragraph.”

Comments: The trial registration platform has been changed from the China Pesticide Digital Supervision and Management Platform to the Ministry of Agriculture and Rural Affairs’ Pesticide Management Information Platform. Any changes to the trial unit, location, or project require new registration.

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