Proposed amendments to Canada’s Pest Control Products Fees and Charges Regulations

January 21, 2025

Why is the Pest Management Regulatory Agency (PMRA) proposing to update the fees for pest control products?

All registrants must pay an annual charge for every active pest control product in their name to maintain their right to manufacture/import/sell/use the pest control product in Canada.

The PMRA has concluded that current fees do not reflect the administrative costs for post-market regulatory activities, resulting in an escalating economic burden on taxpayers. Moreover, the current fees do not align with those charged by other regulatory bodies. 

The proposed changes aim to more precisely reflect the costs associated with Health Canada’s regulatory activities on pesticides. The changes will also incorporate effective mitigation measures to minimize the economic impact on small businesses and maintain continued access to certain pesticides.

The proposed changes do not apply to fees for new applications, amendments, notifications or renewals. A separate consultation for those fees is planned for 2028.

The annual charges are intended to fund re-evaluations and post registration compliance and enforcement.

PMRA Annual Charge Fee current and proposed comparison

The table below details the current and proposed fee structures. Health Canada is proposing to introduce a tiered fee schedule based on the number of products that a company has registered. The initial annual fee per pest control product registration is $6130 CAD with reductions between 10-25% for additional regulations. The proposed regulations include three categories of reduced fees under the annual charge structure:

•  for qualifying small businesses
•  for semiochemicals, microbial agents, or non-conventional active ingredients
• specialized pest control products in the “COMMERCIAL” or “RESTRICTED” sectors, meeting criteria of limited acreage of use, public health threats and/or threats to species at risk

The proposed amendments also introduce exemptions:

•  to annual fees for registrations held by federal, provincial or municipal governments in Canada
•  A three-year waiver for new technical active ingredients and associated and use products

Under the proposal, the lowest annual charge would apply for a registrant that qualifies for multiple types of fee mitigations.

Small businesses are defined as: Fewer than 100 employees, and less than $5 million (CAD) in annual gross revenue globally and from all product lines. The proposed regulations also define affiliates and subsidiaries, requiring that revenues of current companies or their affiliated companies must be included in the calculations.

Biopesticides: While the term biopesticide is not defined within the Pest Control Products Act or the Pest Control Products Regulations, it is used in the Regulatory Impact Analysis Statement (RIAS) and other PMRA guidance to refer to microbials, semiochemicals and non-conventional pest control products. Examples of non-conventional products include, but are not limited to, food items (vinegar, corn gluten), plant extracts (essential oils, vegetable oils), inert materials (diatomaceous earth), commodity chemicals (sodium chloride).

Specialized pest control products: Previously referred to in previous consultations and in the RIAS as niche products, these pest control products have limited economic incentive to maintain registration but are highly valuable for specific uses, such as:

• Low-acreage crops
• Products that support public health programs
• Products that support environmental protection, for example, to control invasive non-native species and protect species at risk

The proposed amendments further qualify the specialized pest control products as having a “COMMERCIAL” or “RESTRICTED” marketing classification.

Key dates and links  

• Public comment period on the proposed regulations ends February 19, 2025
• Target date to publish the final regulations is before June 20, 2025
• Target coming-into-force date is April 1, 2026

Access the propped regulations and submit comments at this link: Canada Gazette, Part I, Volume 158, Number 51: Regulations Amending the Pest Control Products Fees and Charges Regulations (Annual Charge)

How TSG Consulting can help

TSG can help you estimate what your new annual fees will be, including whether you may qualify for the reduced fees as a small business, biopesticide or specialized product. We can also assist you with discontinuations of registrations before the new fees come into force later this year.