A Comprehensive Overview of Changes in Myanmar’s Pesticide Registration Policy

Release Date:

2019-02-28

Myanmar is a member of the Association of Southeast Asian Nations, with a land area of 678,500 square kilometers, making it the second-largest country in Southeast Asia. According to 2017 statistics from the Food and Agriculture Organization of the United Nations, Myanmar’s population is approximately 52.88 million, with rural residents accounting for 64.8 percent. A World Bank report indicates that Myanmar farmers’ per capita income per cropping season ranks last among ASEAN countries. Despite its fertile soils and abundant water resources, farmers have struggled to generate substantial incomes from their land. Since Myanmar opened up to the outside world in 2012, the government has pursued agricultural reforms and accelerated modernization efforts. Meanwhile, spurred by China’s Belt and Road Initiative, Myanmar’s agrochemical market has attracted increasing numbers of foreign firms in recent years, including a growing presence of Chinese companies. According to a January 28, 2017 report in Myanmar’s Federal Gazette, citing the Yangon Region Agricultural Development Forum, Myanmar’s agricultural sector imports roughly US$200 million worth of pesticides and US$230 million worth of fertilizers annually. The country’s principal crops are rice and pulses, with average harvested areas of 6.86 million hectares and 4.47 million hectares, respectively, during 2012–2016 (FAO data). Major cash crops include rubber, sugarcane, and tropical fruits such as mangoes.

1 Pesticide Registration and Management in Myanmar

In accordance with Myanmar’s regulations on the use and management of pesticides, pesticide imports must first obtain a product registration certificate and an import approval from the local authorities. Pesticides in Myanmar are regulated by the Plant Protection Division (PPD) under the Ministry of Agriculture (website: http://ppdmyanmar.mmhash.com/). Prior to June 2018, as stipulated in PPD circulars, two Pesticide Registration Board Meetings (PRB meetings) were held annually to review and approve pesticide product registrations. Due to various factors, the specific timing of these meetings often varied significantly. Each meeting would first announce the approval outcomes for products submitted in the previous round, followed by a roughly one-month period during which new registration applications could be filed. According to official statistics, by the conclusion of the 27th review meeting, a total of 2,914 products had been granted registration certificates. At the close of the 28th meeting on July 31, 2018, it was announced that 594 products had received registration, including 456 provisional certificates—accounting for approximately 77%—and 138 products approved on a trial basis. Additionally, it was stated that subsequent PRB meetings would be convened every three months, and new requirements for submitting product registration applications for the 29th meeting were subsequently published.

First, let’s outline the three common types of registration documents for pesticides in Myanmar: 1) Experimental Registration, which is valid for two years. This type of registration is granted for new products upon their initial entry into the Myanmar market and does not permit commercial sales; applicants must complete field trials within this two-year period before applying to convert to a temporary registration certificate. Currently, obtaining experimental registration is becoming increasingly challenging, with new products often being rejected outright—particularly if they have not been registered in any country other than China and lack efficacy‑testing data from other markets. As a result, Myanmar’s Ministry of Agriculture tends to decline such applications, especially for formulated products. Formulated products are frequently a company’s flagship offerings, but submitting them for registration should be approached with careful consideration to avoid wasting resources and effort on preparations that ultimately prove futile.

2) Provisional Registration: Valid for five years, allowing import and sale. If a product has already been granted a provisional registration in Myanmar, subsequent applications from other companies will be issued a provisional certificate directly. Choosing this type of registration enables rapid certification and the commencement of sales activities. For products undergoing their first application—transitioning from trial registration to provisional registration—the protection period typically lasts 3–5 years, during which no other company may apply for registration of the same product.

3) Full Registration: valid for 10 years; upon expiration of the temporary registration, an application may be submitted to convert to full registration. To register a pesticide product in Myanmar, applicants are not required to establish a local company; overseas manufacturers may obtain the registration directly, but they must designate a local distributor.

2 Myanmar Pesticide Registration Process and Documentation Requirements

2.1 Myanmar Pesticide Registration Process

Phase 1: Prepare registration documents and samples. Phase 2: Purchase the application form, submit the registration documents, samples, reference standards, and pay the sample testing fees. Phase 3: During the review phase, respond to official inquiries. Phase 4: Pay all official fees and obtain the registration certificate.

2.2 Requirements for Pesticide Registration Dossiers

With the increasing number of foreign‑registered companies in Myanmar in recent years, the PPD has repeatedly tightened pesticide registration standards, adding more documentation requirements and other stipulations. For Chinese firms, the 2017 additions included submitting proof of export‑pesticide information (Freely Sold Certification), product registration certificates and production licenses in China, as well as standard reference samples of the active ingredient. New formulated products—particularly herbicides whose active‑ingredient content or composition differs from previously registered formulations—and ingredients developed in China (such as kasugamycin) are subject to additional requirements, including supplementary international peer‑reviewed publications, details of registrations in the EU and the United States, and documentation guaranteeing the authenticity of toxicity data. At its 27th review meeting, an interim list of suspended‑registration active ingredients was issued, resulting in the rejection of many registration applications for popular compounds. This year, in addition to an increase in the number of annual review meetings, changes to Myanmar’s pesticide registration policy have focused on new sample‑submission requirements, significantly raising both the costs and the complexity of registering pesticides in Myanmar for Chinese companies. Following the 28th review meeting, the registration requirements for Chinese‑manufactured pesticide products in Myanmar are as follows:

1) The application form must be purchased from the Ministry of Agriculture.

2) Product Recommended Application;

3) English label and Myanmar label for the product;

4) Data Requirements for Registration of Pesticides (DRRP), encompassing ten major categories: General Information, Properties of the Active Ingredient, Properties of the Formulated Product, Intended Uses and Methods of Application, Assessment of Efficacy of Pesticides, Toxicology, Residue Data, Environmental Data, Disposal of Surplus Pesticides and Pesticide Containers, and Labelling.

5) Color scan of the Export Pesticide Information Certificate (Freely Sold Certification);

6) Color scanned copies of the product manufacturing license and its English version, stamped with the company’s official seal;

7) Color scanned copy of the manufacturer’s business license and its English version, affixed with the company’s official seal;

8) Samples (250 mL for liquids, 250 g for solids); (Sample quantity requirement for the 27th session: 1 L or 1 kg).

9) Reference standards of active ingredients (two 1-g portions of each active ingredient in the product) and certificates of analysis;

10) 25 g of the technical-grade sample;

11) Toxic impurities in the technical-grade sample (0.5 g of each impurity);

12) Chromatographic columns used for the analysis and quantification of active ingredients in formulation samples;

13) Samples must be shipped by certified air freight (a new requirement introduced by the Myanmar government to combat cross-border smuggling);

14) International peer-reviewed publications on the product’s efficacy (must be provided for formulated herbicides; for other products, submission is required when there are concerns regarding the PPD); additionally, please provide, to the extent possible, information on the product’s regulatory registration in countries outside of China. This will increase the likelihood that the Ministry of Agriculture will approve the product’s registration.

The Burmese-language label includes the following information: the pesticide’s name, formulation, active ingredients and their concentrations; the pesticide registration number; the product category; the mode of action; the packaging specifications; instructions for use; antidote information; precautions for prevention; storage and waste disposal guidelines; usage precautions; and details of the manufacturer and distributor. The color‑coded warning bands on the Burmese label are classified according to toxicity, in accordance with the GHS classification guidelines (Table 1), and are divided into four colors—red, yellow, blue, and green. Each color is accompanied by a corresponding pictogram and explanatory text (Table 1). The label must also state: “Read the instructions carefully; keep the safety lock out of reach of children.”

After a product submits its registration application, it is reviewed at the next PRB meeting; upon approval, the relevant certificate is issued. Since the announcement of the certification results on July 31, 2018, more than four months have passed through December 2018, yet the original copies of the registration certificates for these approved products have still not been fully distributed to the enterprises. The pace at which Myanmar’s Ministry of Agriculture issues these certificates is truly cause for concern.

3 Prohibited and Restricted Registered Ingredients

Myanmar’s pesticide registration policy has been evolving in recent years. As the number of foreign companies registering in Myanmar continues to grow, the Ministry of Agriculture has steadily tightened its registration requirements and expanded the list of prohibited and restricted active ingredients, leading to restrictions on the registration of several popular active substances. Moreover, these prohibited or restricted substances are also subject to EU measures, including the rejection of re‑evaluation applications, the denial of renewal of registrations, and the withdrawal of previously registered products.

On June 17, 2013, the PRB announced that Myanmar had banned the registration of 39 active ingredients, including methomyl, methamidophos, and monocrotophos, and placed 7 additional ingredients under restricted use, such as methyl bromide, bromadiolone, and fenthion. As of 2016, the authorities had officially approved the use of 309 active ingredients in Myanmar. Following the conclusion of the 27th PRB meeting, Myanmar’s Ministry of Agriculture announced that registration applications for 13 active ingredients—including widely used compounds like paraquat, glyphosate, abamectin, chlorpyrifos, and imidacloprid—would be suspended until the 30th meeting (Table 2). On July 26, 2018, 19 additional active ingredients were designated as either prohibited or subject to restricted use (Table 3).

Note: In 2017, in addition to announcing the suspension of registration for 13 active ingredients, it was also announced that 64 products granted temporary registration through testing would receive a five-year period of protection, during which other companies would be prohibited from applying for the same products within that five-year period.

Myanmar’s registration requirements have gradually tightened from their initial low‑threshold stance. Just as many companies were rushing to enter the market, a host of new hurdles have emerged—perhaps to curb homogeneous competition, or perhaps because the Ministry of Agriculture believes foreign firms are moving in too quickly and need a regulatory buffer. Numerous factors must be weighed, while at the same time, these measures may also aim to bolster the development of local Myanmar enterprises. In short, before seeking pesticide registration in Myanmar, it is essential to conduct thorough market research to define the product portfolio. Ideally, you should submit the product list to the Ministry of Agriculture well in advance to obtain information on the appropriate certification type and the expected number of registrations, thereby avoiding unnecessary expenditures of both money and time. Whether your goal is to secure a temporary registration for immediate sales or to prioritize the strategic rollout of new products, a clear plan should be in place ahead of time. Given the frequently evolving nature of Myanmar’s registration policies, seizing opportunities demands swift action—after all, there’s no telling when mainstream active ingredients might face registration restrictions.

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