Answers to Questions on the Management and Registration of Agrochemicals and Fertilizers

Release Date:

2019-09-17

Question

First, there are now many integrated fertilizer‑pesticide products on the market. Are such products permitted by the state?

Second, regarding pesticide products that have been granted pesticide registration certificates and are being incorporated into fertilizers, with labels indicating fertilizer‑like functions, yet the pesticide registration approval documents do not include any mention of fertilizer efficacy—does this constitute a violation of the Regulations on the Administration of Pesticide Labels?

Third, with respect to fertilizer products that hold a fertilizer registration certificate, if they are formulated with unregistered pesticide ingredients, should they be treated as pesticide products and thus subject to the same regulatory regime as counterfeit pesticides?

Answer

I. Pesticide products that also exhibit the effects of fertilizers are permitted, but they must possess a pesticide registration certificate. Because agro‑pharmaceutical products exhibit both fertilizer and pesticide effects, they are commonly referred to as “agro‑pharmaceuticals” in the market. However, the state has not established a unified definition or standard for such products, and the term “agro‑pharmaceutical” is not recognized in national laws and regulations. At present, pesticide registration and approval do not include a category for fertilizer‑pesticides. Agrochemicals and fertilizers can easily cause phytotoxicity, and their combined efficacy does not necessarily exceed the sum of their individual effects; therefore, extensive pesticide registration trials are essential. During the registration and review process, only the pesticide‑related tests are evaluated; the fertilizer efficacy is not assessed, and neither the label nor the product registration certificate bears any indication of “fertilizer‑pesticide.” However, the product composition and manufacturing processes submitted in the documentation must include relevant information. According to reports, in the past, more than ten manufacturers in China had registered such products, with over 30 registered formulations. All these products were marketed under the category of pesticide formulations, including, for example, a chlorpyrifos‑based fertilizer‑pesticide mixture specifically targeting soil-dwelling pests, and a bentazone‑butachlor fertilizer‑pesticide mixture for controlling weeds in rice fields. Meanwhile, with the implementation of the new Regulations on the Administration of Pesticides (hereinafter referred to as: With the implementation of the Regulations, obtaining such registration certificates now requires submitting new documentation; however, the updated requirements for these documents were not published until the end of 2017. As a result, many enterprises did not complete the necessary materials and begin the registration process until 2018. It is expected that, in three years’ time, registration certificates for pesticides with both pesticidal and fertilizer‑enhancing properties will finally be approved; in the short term, such certificates will remain in short supply. In 2018, the Pesticide–Fertilizer Professional Committee of the China Pesticide Industry Association announced that China’s first technical specification for granular pesticide–fertilizer products and a corresponding industry standard were under public consultation; if all goes smoothly, they are expected to be officially promulgated in 2019. This underscores the necessity of regulating pesticide registration to standardize the management of agro‑pharmaceutical products, thereby ensuring that such products are produced, marketed, and used in compliance with established procedures.

II. A product that holds a pesticide registration certificate but illegally adds fertilizer to it is considered a counterfeit pesticide. “Measures for the Registration of Fertilizers” (hereinafter referred to as: The Measures define fertilizers, and Article 34 explicitly states: Mixtures of fertilizers and pesticides, as well as organic fertilizer products manufactured and used by farmers themselves, are not subject to these Measures. In other words, “a mixture of fertilizer and pesticide” cannot be registered as a fertilizer, and “fertilizer‑pesticide products” are not classified as fertilizers. Therefore, whenever a pesticide is added to a fertilizer, the product is classified as a pesticide and must be registered, manufactured, marketed, used, and regulated in accordance with pesticide regulations. Pesticides produced without having obtained a pesticide registration certificate are deemed to have been manufactured without lawful registration. or if the types of active ingredients contained in the pesticide do not match those listed on the pesticide’s label or in its instructions, it shall be deemed a counterfeit pesticide. In other words, At present, agrochemical‑fertilizer products containing pesticides must all be registered as pesticides, and their packaging must strictly comply with the Measures for the Administration of Pesticide Labels and Instructions. Of course, products that have already obtained pesticide registration certificates must not be arbitrarily formulated with fertilizers. , arbitrarily entangled with fertilizers.

III. Fertilizers containing unregistered “pesticides” can be classified as counterfeit pesticides. In accordance with the provisions of the Regulations: Pretending non-pesticides are pesticides It may then be deemed a counterfeit pesticide. In other words, if a fertilizer‑pesticide product does not have an approved pesticide active ingredient listed in the pesticide registration, it is not considered a pesticide, and such a product must be labeled accordingly. If a product is labeled as a pesticide, it can be classified as a counterfeit drug by being “passed off as a pesticide when it is not.” Conversely, if the product is originally a fertilizer and its label does not declare any so‑called pesticide ingredients—merely claiming insecticidal and disease‑preventive effects—while the fertilizer itself contains no active ingredients with such functions, it shall be deemed to have an unqualified label for having improperly altered the labeling content.

IV. Counterfeit pesticides and unauthorized alterations to fertilizer label content shall be subject to penalties in accordance with the following provisions: The Regulations stipulate: “Anyone who produces pesticides without obtaining a pesticide production license, or who produces counterfeit pesticides, shall be ordered by the agricultural administrative department of the people’s government at or above the county level to cease production; any illegal gains, illegally produced products, and tools, equipment, raw materials, and other items used in the illegal production shall be confiscated. If the value of the illegally produced products is less than RMB 10,000, a fine of no less than RMB 50,000 but no more than RMB 100,000 shall be imposed; if the value exceeds RMB 10,000, a fine of not less than ten times but not more than twenty times the value of the products shall be imposed. The licensing authority shall revoke the pesticide production license and the corresponding pesticide registration certificate.” Where the conduct constitutes a crime, criminal liability shall be pursued in accordance with the law. “Anyone engaging in the business of counterfeit pesticides shall, upon order of the agricultural administrative department of the local people’s government at or above the county level, cease such operations; any illegal gains, illegally traded pesticides, and tools and equipment used in such illegal activities shall be confiscated. If the value of the illegally traded pesticides is less than RMB 10,000, a fine of no less than RMB 5,000 but no more than RMB 50,000 shall be imposed; if the value exceeds RMB 10,000, a fine ranging from five to ten times the value of the goods shall be imposed.” Where the conduct constitutes a crime, criminal liability shall be pursued in accordance with the law. “The Measures stipulate:” “Where any of the following circumstances exists, the agricultural administrative department at or above the county level shall issue a warning and impose a fine of up to three times the illegal gains, with the maximum fine not exceeding RMB 20,000; if there are no illegal gains, a fine of no more than RMB 10,000 shall be imposed:” (3) Products whose packaging lacks labels, bears incomplete or illegible labels, or has labels with unauthorized alterations. ”

Source: Shandong Provincial Pesticide Inspection Institute Yang Lijian

Ask

Tags:

Nearly 500 million bees in Brazil have died from pesticide poisoning, with fipronil detected in 80% of the dead bees.

The National Catalogue of Hazardous Wastes will be revised once again, and these pesticide wastes are included therein.

More information

The National Agricultural Technology Center has issued guidelines on “one spray, three protections” for wheat to address the heightened risk of recurrent outbreaks of Fusarium head blight, stripe rust, and aphids.

2026-04-10

The petrochemical and chemical industries comprise more than 27,000 large-scale production enterprises—efforts to upgrade and retrofit aging facilities are being further intensified.

2026-04-06

In 2026, corn borer, cotton bollworm, and ear rot—among other corn pests and diseases—are expected to occur at a relatively severe level. The National Agricultural Technology Center has issued a control plan!

2026-04-02