Don’t Let Your Pesticide Registration Certificate Expire! Five Major Misconceptions to Watch Out For

A pesticide registration certificate is a permit that authorizes the production, marketing, and use of a pesticide product, serving as its “birth certificate” for market entry. For the certificate holder, it is a vital lifeline and the foundation for realizing economic benefits. In pesticide management, we have observed that some registrants fail to prioritize the renewal of their pesticide registrations, neglecting relevant laws, regulations, and technical standards, which can result in the registration’s non‑renewal or lapse. We have identified several common issues with the aim of providing guidance for submitting applications to renew pesticide registrations.

Misconception 1: Believing that a pesticide registration certificate is automatically renewed upon expiration.

Pesticide registration is an administrative license, and the pesticide registration certificate is an administrative license document. According to Article 50, Paragraph 1 of the Administrative Licensing Law, “Where a licensee seeks to extend the validity period of an administratively granted license obtained in accordance with the law, the applicant shall submit an application to the administrative authority that made the licensing decision no later than thirty days before the expiration of the license’s validity period; provided, however, that where otherwise prescribed by laws, regulations, or rules, such provisions shall prevail.” Article 13, Paragraph 2 of the Regulations on the Administration of Pesticides and Article 30 of the Measures for the Administration of Pesticide Registration set forth respective requirements regarding the time limit and procedures for applying to renew pesticide registrations.

Accordingly, upon expiration of the pesticide registration certificate, its validity is not automatically renewed; the certificate holder must proactively submit an application for renewal.

Misconception No. 2: Ignoring the time limits for applying to renew pesticide registrations.

Pesticide registration renewal is subject to strict application deadlines; failure to file a renewal application within the prescribed time frame will result in the lapse of the pesticide registration certificate.

In accordance with Article 13, Paragraph 2 of the Regulations on the Administration of Pesticides and Article 29 of the Measures for the Administration of Pesticide Registration, the validity period of a pesticide registration certificate is five years. Upon expiration, if the holder intends to continue manufacturing the pesticide or exporting it to China, they shall submit an application for renewal no later than 90 days before the certificate’s expiration date. If the renewal application is not filed by the deadline, a new registration must be applied for.

Accordingly, the holder of a pesticide registration certificate shall submit an application no later than 90 days before the certificate’s expiration; however, to ensure the efficiency of administrative approval, the earliest possible filing date shall not be earlier than 180 days prior to expiration.

If a pesticide registration certificate expires without being renewed, it shall be revoked in accordance with Article 40, Paragraph 1 of the Measures for the Administration of Pesticide Registration.

Misconception 3: Assuming that holding a pesticide registration certificate automatically confers eligibility to apply for registration renewal.

As an administrative license, the primary condition for the continued validity of a pesticide registration certificate is that the certificate holder must meet the eligibility requirements to apply for renewal. Some certificate holders mistakenly believe that merely holding a pesticide registration certificate automatically confers eligibility to apply for renewal; this is a misconception.

In accordance with the relevant provisions of the Regulations on the Administration of Pesticides and the Measures for the Administration of Pesticide Registration, there are currently three categories of pesticide registration certificate holders: First, pesticide manufacturers—domestic enterprises that have obtained a pesticide production license—may serve as registrants for both new and non‑new pesticide products; second, enterprises exporting pesticides to China—i.e., the registrants of foreign‑origin pesticide products; and third, developers of new pesticides—Chinese citizens, legal persons, or other organizations that have not yet obtained a pesticide production license—who may act as registrants for new pesticide products.

Accordingly, the holder of a registration certificate for an overseas‑originated product shall be a foreign enterprise. For a novel pesticide, the first holder of the registration certificate may be a domestic developer of the new pesticide; otherwise, the holder of a registration certificate for any other product must be a pesticide manufacturer, meaning that such holder must possess a valid pesticide production license.

However, it is important to note that certain products are subject to specific eligibility requirements for the holder of the registration certificate, which must be met. For example, according to Announcement No. 868 of the Ministry of Agriculture and Rural Affairs, the pesticide registration certificates for aluminum phosphide technical grade and formulated products held by manufacturers of aluminum phosphide technical grade are retained. Consequently, for the renewal of registration of aluminum phosphide products, the certificate holder must possess a pesticide production license covering the production of aluminum phosphide technical grade; otherwise, the renewal will not be approved. Another example: for products registered solely for export, as stipulated in Announcement No. 269 of the Ministry of Agriculture and Rural Affairs, if a renewal is sought, the certificate holder must be a pesticide-producing enterprise with the corresponding production scope. Furthermore, such exclusively export‑only products must also obtain pesticide registration in the destination country or region, or secure an import permit from the importing country or region. Failure to meet these conditions means that, even if the holder “possesses” a pesticide registration certificate, the renewal of the registration will still not be approved.

Misconception Four: Assuming that once an application is accepted, its registration renewal will certainly be approved.

Acceptance is merely one step in the administrative licensing process. Some applicants seeking to renew pesticide registrations mistakenly believe that once their application is accepted, it automatically means the renewal meets all requirements and will certainly be approved. This understanding is also incorrect. The administrative licensing procedure for pesticide registration renewal comprises several key stages: application, acceptance, review, and issuance of an approval decision. Consequently, acceptance is only one of these steps; whether the renewal is ultimately approved depends on the subsequent review and decision‑making phases. Specifically, the reviewing authority assesses whether the submitted documentation satisfies the statutory conditions for registration renewal, and only if those conditions are met may an approval decision granting the renewal be issued.

Article 38, Paragraph 1 of the Measures for the Administration of Pesticide Registration sets forth the circumstances under which the Ministry of Agriculture and Rural Affairs shall neither accept nor approve an application; applications for the renewal of pesticide registration must also comply with these provisions.

Misconception 5: Ignoring pesticide registration renewal requirements beyond those stipulated in the “Requirements for Pesticide Registration Data”

Chapter 9 of the “Requirements for Pesticide Registration Dossiers” sets forth the application materials that must be submitted for pesticide registration renewal; however, some applicants overlook the final requirement—namely, any other materials prescribed by the Ministry of Agriculture and Rural Affairs. This provision exists because, as an administrative licensing process, pesticide registration renewal is subject to ongoing updates in applicable laws, policy requirements, and technical standards in response to new developments and demands in pesticide management. Accordingly, the “Requirements for Pesticide Registration Dossiers” includes a catch-all clause. When applying for registration renewal, the holder of a pesticide registration certificate must ensure that all submitted materials comply with current relevant regulations and meet prevailing evaluation criteria.

Take the “export‑only registration” as an example: Ministry of Agriculture and Rural Affairs Announcement No. 269 sets out specific provisions for such registration, and any renewal of the relevant product’s registration must comply with that announcement. For instance, if an identical or similar formulation has already obtained domestic registration, a new export‑only registration for that pesticide will not be approved; moreover, for applications already approved, registration renewals are permitted no more than once. This is one of the requirements—beyond those stipulated in the “Requirements for Pesticide Registration Data”—that must be observed when seeking to renew an export‑only registration.

It should be specifically noted that Article 38, Paragraph 2 of the Measures for the Administration of Pesticide Registration, which sets forth administrative measures for false pesticide registration data and test samples, applies not only to initial pesticide registration but also to the renewal of such registration. If, in applying for the renewal of pesticide registration, an applicant conceals relevant information or submits false registration data or test samples, they shall likewise bear legal liability in accordance with this provision.

Source: Pesticide Science and Management- Issue No. 2, 2025