Intended phase-out of active ingredients and products classified as CMR categories 1A and 1B

Background

On 14 April 2022 the Registrar of Act No. 36 of 1947 published a letter informing agricultural remedy registration holders in South Africa of his intention to prohibit the use of agricultural remedies (products) that contain one or more active ingredients or co-formulants considered to be classified as category 1A or 1B carcinogenic, mutagenic, or reproductive toxic substances (CMR), according to the GHS classification system from 1 June 2024.

Soon thereafter CropLife SA (CLSA) established a Working Group to identify agricultural remedies containing active ingredients and/or co-formulants that could potentially be classified as substances of concern, assess the impact of the intended phase-out on the crop production industries involved and propose a procedure for the motivation of possible extended phase-out periods of certain products and uses, depending on the availability of suitable alternatives.

The relevant active ingredients and co-formulants considered as substances of concern have been identified and verified with registration holders, based on the GHS classification of their respective products. Subsequently information on the crops and target pests, diseases, weeds or other uses on which these active ingredients are registered were sent to each grower association that could potentially be affected.

The various grower associations identified the registered active ingredients that are currently essential for control of specific targets, and therefore crop production, and indicated whether suitable alternative agricultural remedies are available on the market to control the identified crop–target combinations they highlighted. This feedback was then consolidated and relayed to the Working Group and the Registrar.

The essential active ingredients and uses identified for pome and stone fruit thus far are:

Next steps

CLSA will now request all registration holders to indicate whether possible alternative products are available to replace or partially replace the active ingredients regarded as essential to production for each grower group. This information will be treated confidentially and could include:

• alternative products for which applications for registration of the essential use have already been submitted to the Registrar’s office,
• alternative products that are already under development; or
• active ingredients that could perhaps be suitable replacements, for possible registration in

CLSA will collate the data for discussion with the Registrar, with the aim to:

• identify suitable agricultural remedies that have been submitted or are under development for registration, for possible fast-tracking of registration; and
• agree on those active ingredients and essential uses for which derogations can be submitted to motivate an extended phase-out period while alternative solutions are sought and evaluated as potential replacements.

Note that registration holders will need to decide whether they are going to apply for derogations for extension of the phase-out of their agricultural remedies, and those registration holders that wish to participate will do so collectively via a derogation sub-group for the specific active ingredient.

The Registrar has been receiving regular updates from CropLife SA throughout the entire process, and the Working Group is keen to move forward with the next steps in the process, as indicated.

Hortgro have been intimately involved and continue to be involved in the process, forming part of the CropLife SA (CLSA) Working Group from the onset to ensure that pome and stone fruit essential uses are considered during the process.