The Applicant Guide: Applications for addition of undersown crops to product labels
It is common agricultural practice for growers to undersow cereals with grass or clover as a secondary crop, providing grazing and increased biodiversity.
It is recognised however that many herbicide, growth regulator, fungicide and insecticide products do not have label recommendations for use on undersown crops, so use of pesticides on a cereal crop undersown with grass/clover 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, applications for the addition of undersown crops of grass and/or clover to products already authorised for use on cereals may be made via the admin stream. The application would not require revised draft labels, but should include the following information:
- Details of product name, Ministerially Authorised Pesticide Product (MAPP) number, active ingredient(s) and type of product (such as fungicide or herbicide, insecticide) on the appropriate application form
- evidence relating to consumer safety (see section below)
- evidence of undersown crop safety (see section below)
Consumer safety
The applicant 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
The applicant must provide evidence that they 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, the applicant must submit an application which requires technical consideration. The application would not require revised draft labels, but should include the following information:
- details of product name(s), MAPP number(s), active ingredient(s) and type of product (such as fungicide or herbicide, insecticide) on the appropriate application form
- a statement relating to consumer safety (see section above)
- data or a case to support crop safety to the undersown crop.
It would also be possible to add a request for undersown crops to an application submitted for other reasons.
How will authorisations be amended?
Where the application is successful, an amended authorisation will be issued, specifying undersown crops of grass/clover and allowing these uses to be added to the product label.