Do distributor products need to get currently unavoidable use exemptions if the section 3 product has received a currently unavoidable use exemption?

Yes. Registrants of distributor products must submit a currently unavoidable use exemption application for distributor products. The application can refer (i.e., “right to refer”) to decisions made about the section 3 product as support for an exemption.

No

Pesticide products with intentionally added PFAS are regulated by the MDA while treated articles, such as pesticide treated seeds, with intentionally added PFAS are regulated by the MPCA. Many pesticide products may be used in or on treated articles. The MDA and the MPCA are working together to determine how CUU exemptions will be handled for treated articles. The MPCA will conduct rulemaking for laying out their CUU exemption process including for treated articles. Guidelines for treated article CUU exemptions will be posted on MDA’s website, when finalized.

If a CUU is obtained for a seed treatment pesticide, is an additional CUU exemption needed for the treated seed?

Pesticide products with intentionally added PFAS are regulated by the MDA while treated articles, such as pesticide treated seeds, with intentionally added PFAS are regulated by the MPCA. Many pesticide products may be used in or on treated articles. The MDA and the MPCA are working together to determine how CUU exemptions will be handled for treated articles. The MPCA will conduct rulemaking for laying out their CUU exemption process including for treated articles. Guidelines for treated article CUU exemptions will be posted on MDA’s website, when finalized.

No

Yes.

Will currently unavoidable use guidelines be the same for pesticidal cleaning products as all other pesticides?

Yes.

No

To avoid interruption of product registration applications should be submitted well in advance of the prohibition deadline.

When should currently unavoidable use applications be submitted?

To avoid interruption of product registration applications should be submitted well in advance of the prohibition deadline.

No

Determinations for currently unavoidable use exemptions will depend on when the application was submitted, its place in the queue, and the completeness and succinctness of the application.

How soon will I know if a product has received a currently unavoidable use exemption?

Determinations for currently unavoidable use exemptions will depend on when the application was submitted, its place in the queue, and the completeness and succinctness of the application.

No

Information that is marked as trade secret by the registrant, and that the Commissioner determines to be trade secret, will be accessible to only select individuals involved in pesticide application processing.