Why Biostimulants Could Soon Be Labeled as Pesticides
August 1, 2019 
The EPA is considering listing biostimulants as pesticides, meaning they would require similar regulatory oversight. EPA recently wrote draft guidance to that effect:
“In recognition of the growing categories of products generally known as plant biostimulants, this document is intended to provide guidance on identifying product label claims that are considered to be plant regulator claims by the Agency, thereby subjecting the products to regulation as pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), 7 U.S.C. 136–136y.”
Such a change would be a marked shift in current policy.
“It is quite a dramatic move. It looks like they are conflating plant growth regulators (PGR’s) with biostimulants (not a PGR in most cases) and fertilizer (totally separate and unrelated),” says Richard Smith, University of California Vegetable Crop and Weed Science Farm Advisor at the Cooperative Extension in Monterey, Santa Cruz, and San Benito counties, in a report on GrowingProduce.com.
Hans Dramm, President and CFO of Dramm Corporation, wrote an open letter to the industry, calling attention to the proposed change and the importance of taking action. That letter can also be read on GrowingProduce.com.
BPIA Weighs In
The biostimulant industry, through the Biological Products Industry Alliance and the U.S. Biostimulant Coalition, has submitted its response to EPA’s draft guidance, including recommendations on several points, including:
• Recognizing biostimulants as products supporting natural plant nutrition processes and tolerance to abiotic stress.
• Recognizing and accepting that many biostimulants have multi-function properties and modes of action depending on formulation, rate, and application.
• Clarifying EPA’s definitions of product categories that are excluded from the definition of plant regulator under the Federal Insecticide, Fungicide and Rodenticide Act.
• Recognizing the importance of the parallel development of EPA’s Draft Guidance and USDA-led initiative on biostimulants under the 2018 Farm Bill in alignment with other agencies including the National Association of State Departments of Agriculture (NASDA), the Association of American Plant Food Control Officials (AAPFCO), the American Association of Pesticide Control Official (AAPCO), and other stakeholders.
• Recognizing the importance of the Draft Guidance and its positive impact on the introduction of biostimulants to sustainable agricultural practices through an enhanced regulatory framework.
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