How to add undersown crops to your pesticide product label



It’s common agricultural practice for growers to undersow cereals with grass or clover as a secondary crop, providing grazing and increased biodiversity.

However, many herbicide, growth regulator, fungicide and insecticide products do not have label recommendations for use on undersown crops. Use of pesticides on a cereal crop undersown with grass or clover therefore technically breaches the conditions of authorisation.

To regularise the position, and in recognition of this common agricultural practice, we encourage authorisation holders to add undersown crops to their product labels, by applying for authorisation.

How to apply – for insecticides and fungicides

For insecticides and fungicides, you can apply for undersown crops of grass or clover to be added to authorised products for use on cereals by submitting:

  • a covering letter fully explaining your request and detailing the requirements below
  • completed application form CRD2
  • letters of access to third party data
  • any previous relevant correspondence for example a copy of the parent product authorisation, previous authorisation/trials permit/EAMU as appropriate or any written advice previously provided by HSE

You do not need to include revised draft labels in the application but you should include:

  • evidence relating to consumer safety
  • evidence of undersown crop safety
  • on the application form, details of the:
    • product name
    • Ministerially Authorised Pesticide Product (MAPP) number
    • active ingredient(s)
    • type of product (such as fungicide or insecticide)

Consumer safety

You must provide evidence to demonstrate that there will be no increased risk to consumers from the addition of undersown crops to the label, for the listed products applied as foliar treatments to cereals. This evidence could be based on the authorised use on the cereal crop, the known properties and behaviour of the active substance or a simple risk assessment.

Crop safety

You must provide evidence that you have considered the crop safety profile of the product and that it would not be expected to cause crop damage to the undersown ley.

How to apply – for herbicides and growth regulators

To add undersown crops to herbicide and growth regulator products, you must submit an application which requires technical consideration.

You do not need to include revised draft labels, but you should include:

  • a statement relating to consumer safety
  • data or a case to support crop safety to the undersown crop
  • on application form CRD1, details of the:
    • product name(s)
    • MAPP number(s)
    • active ingredient(s)
    • type of product, such as herbicide

It’s also possible to add a request for undersown crops to an application you’re submitting for another reason.

How authorisations will be amended

For successful applications, we will issue an amended authorisation, specifying undersown crops of grass or clover and allowing these uses to be added to the product label.

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Updated 2024-06-04