America Exports Sketchy Pesticides With Liability Waiver Forms
Published Date: 12/15/2025
Notice
Summary
The EPA wants to keep collecting info from foreign buyers who purchase pesticides not registered in the U.S. They’re asking for public feedback before renewing this paperwork requirement, which helps keep track of these sales safely. If you’re involved in importing or selling these pesticides, get ready to share your thoughts by February 13, 2026—no extra fees, just your input!
Analyzed Economic Effects
4 provisions identified: 2 benefits, 2 costs, 0 mixed.
Mandatory Export Paperwork for Unregistered Pesticides
If you manufacture, reformulate, repackage, or export pesticides that are not registered in the U.S., you must obtain a signed Foreign Purchaser Acknowledgement Statement (FPAS) under FIFRA section 17(a)(2) and submit it to EPA. EPA accepts these statements by mail or electronically through the Central Data Exchange (CDX); the ICR covers annual or per-shipment statements and is mandatory. The ICR estimates about 100 potential respondents, a total burden of 14,064 hours per year, and total costs of $1,028,658 per year.
Export Labeling Requirement Included
All exported pesticides (both registered and unregistered) must include appropriate export labeling, and EPA consolidated the burden estimates for that labeling requirement together with the FPAS in this ICR. The combined burden estimate in this ICR is 14,064 hours per year and $1,028,658 per year in costs.
Estimated Burden Reduced from Prior Approval
EPA reports a decrease of 2,596 hours in the total estimated respondent burden compared with the currently approved ICR, reflecting EPA's adjustment to actual FPAS filings from 2022–2024. This change is characterized as an adjustment to the ICR burden estimates.
EPA Seeks Input From Very Small Businesses
EPA specifically requests comments from very small businesses (those that employ fewer than 25 people) on examples of steps EPA could take to reduce the paperwork burden for this collection. Submit feedback to docket EPA-HQ-OPP-2021-0749 by February 13, 2026.
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Key Dates
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