Interpretation: What You Need to Know About Announcement No. 269, Which Is Exclusively for the Export of Pesticide Products

Amid the industry’s long-awaited anticipation, a much‑needed policy measure has finally been implemented. On June 8—just one day after the Ministry of Agriculture and Rural Affairs of the People’s Republic of China issued Announcement No. 269, announcing that high‑ and medium‑risk areas nationwide had been cleared of COVID‑19 cases—the pesticide export sector has ushered in its own spring of favorable policies.

(See the announcement for details) After much anticipation, it’s finally here! The Ministry of Agriculture and Rural Affairs has issued a registration announcement for pesticide products restricted to export. One article)

Below, we will walk you through the potential benefits and associated uncertainties of Policy 269, sentence by sentence.

The first provision in the announcement clearly states that the prerequisite for applying solely for export pesticide registration is that the product must have obtained pesticide registration abroad or an import authorization from the importing country (or region). However, whether “obtaining pesticide registration” also encompasses registration of the registrant or the supplier, and whether “import authorization” likewise includes emergency-use permits or trial-use permits, remains to be clarified through further policy interpretation. That said, given the requirement in Article 2, Paragraph (2)—“If the supporting documents do not match the name of the applicant enterprise, compelling evidence of a business partnership must be provided”—it is highly likely that supplier registration will be permitted.

In addition to new pesticides, having domestic registrations for similar products is another prerequisite for applying for export‑only pesticide registration; accordingly, manufacturers holding a large number of active‑ingredient and formulated‑product registration certificates can reap the greatest policy benefits. Moreover, Article 4, Paragraph (2)—“If an identical or similar formulation has already obtained domestic registration, no further approval shall be granted for export‑only registration of that pesticide product”—further reinforces this advantage.

Article 1, Paragraph (1), which states, “This enterprise has already obtained active‑ingredient registration within China and is applying for registration of the same active ingredient at a different concentration,” is intended to address the issue of discrepancies between domestic and foreign active‑ingredient registration concentrations. It removes the restriction that new active‑ingredient registrations may not be lower in concentration than existing registrations, thereby allowing products with higher domestic concentrations and lower foreign concentrations to be exported.

According to Article 1 of the announcement, except for new pesticides, applications for registration of pesticide formulations intended solely for export must pertain to either a new active‑ingredient concentration or a new formulation. However, whether the concentration requirements for such export‑only registrations are subject to the domestic registration‑concentration‑gradient policy remains to be clarified through further interpretation of that policy. Under the current gradient‑management regime, as stipulated in Article 8 of the Measures for the Administration of Pesticides: “For single‑component products with the same active ingredient and formulation, the number of concentration gradients shall not exceed three. For mixed‑formulation products, the number of active ingredients shall not exceed two; for herbicides, seed treatments, pheromones, and similar products, the number of active ingredients shall not exceed three. For mixed‑formulation products with identical active ingredients and formulations, the number of mixing ratios shall not exceed three, and the total number of concentration gradients for any given ratio shall not exceed three. Pesticides with low active‑ingredient concentrations that are used directly without dilution or dispersion shall be classified separately.”

According to the data‑submission requirements set out in Article 2 of the announcement, the most significant benefit lies in the export of new active ingredients. Compared with the five reports previously required for non‑new‑pesticide exports—five batches of analytical and quality‑control test reports, as well as oral, dermal, and inhalation toxicity studies—the only additional requirement is information on the physicochemical properties of the active ingredient and the technical grade material; all other data may be either retrieved or submitted as summaries. However, specific reporting criteria—such as the applicability of older‑style reports, testing guidelines, and laboratory accreditation standards—will require further clarification through policy interpretation. Based on this, it is anticipated that applications for export‑only registration of active ingredients whose patent protection has recently expired will surge. Consequently, the workload of the Quality Division and the Toxicology Division within the Ministry will also increase sharply in the short term. This situation, moreover, underscores that China’s pesticide exports remain largely confined to a “physicochemical‑plus‑toxicity” stage.

Conversely, pursuant to Article 3, Paragraph (3) of the announcement, “Applications for the registration of new pesticide formulations intended solely for export shall submit documentation in accordance with the requirements for non‑new‑pesticide registration.” Accordingly, from the perspective of documentation requirements, applications for export‑only registration of new pesticide formulations are relatively the most stringent. However, since non‑new‑pesticide registration is further subdivided into several categories, the specific category applicable and whether non‑essential efficacy and residue studies must be conducted domestically remain subject to further policy clarification.

According to Article 4, Paragraph 3 of the announcement, “Applications for registration of export‑only active ingredients shall be submitted by the manufacturer of the corresponding technical‑grade material.” For products such as microbial or plant‑derived substances that are registered only as active ingredients and not as technical‑grade materials, further clarification of the relevant policies is required.

Other matters that require further clarification through policy include the specific review timeline, the validity period of the relevant certificates, and whether renewals are permitted.

By significantly reducing domestic enterprises’ compliance costs for export, Announcement No. 269 represents a substantial easing of regulatory burdens for production firms that primarily export, particularly in the context of inconsistent pesticide registration requirements between China and other markets. Eligible companies should closely monitor international pesticide market trends—especially those related to products whose patent protections have recently expired—and identify strategic entry points. For instance, recent severe locust infestations in Africa and Southeast Asia have prompted international organizations such as the FAO to increase procurement of ultra‑low‑volume formulations to support aerial spraying operations. However, at present, China has only nine registered ultra‑low‑volume insecticide formulations, including 4% abamectin–thiamethoxam, 5% chlorantraniliprole, 3% flonicamid, 6% emamectin benzoate–indoxacarb, 20% diazinon, 3% thiamethoxam, 3% indoxacarb, 1.5% avermectin, 5% nitenpyram, 1% avermectin benzoate, and 4 g/L fipronil.