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EPA shares best practices for completing CSF

March 14, 2023

The Confidential Statement of Formula (CSF), form 8570-4, is an essential form required to be completed and submitted as part of the application package for registering or amending a registration of a pesticide product. The CSF lists all of the product’s components, active and inert ingredients, with their CAS numbers, their percent by weight along with some physical chemical properties and additional information on registrant and producer.

Recently, the Agency provided a few updates on best practices for completing CSF requirements.

  • Listing of the product’s chemical components on the CSF should start with the active ingredient(s), followed by inerts (buffers, surfactants, thickeners, solvents etc.), dyes, fragrances, and diluents.
  • Generally, EPA requires that applicants include the name and address of each ingredient’s supplier on the CSF. Exceptions apply to inert ingredients designated as commodity inert ingredients (known as List N). These commodity chemicals can be obtained from various commercial sources without having to provide EPA with the supplier’s name or address on CSF form. When completing the CSF, registrants can list these ingredients as “Commodity Inert Ingredient”. No additional information is necessary. Only inert ingredients designated as commodity inert ingredients are eligible for reduced CSF reporting. EPA recommends listing these commodity inert ingredients on the CSF with their chemical name as recorded in List N.
  • It is important to note that reduced CSF reporting does not apply to substances on the commodity inert ingredients list when used as an active ingredient in a pesticide product.

Trade Names can be used on the CSF form on column 10, with the supplier's name and address

  • listed in column 11, ONLY if the product/mixture is already registered with EPA.
  • Trade name and commodity inert status can be used on CSF, with the commodity name (and CAS#) along with the Trade name listed in Column 10. The supplier's name and address for the Trade Name product/mixture must be listed in column 11 along with the phrase “Commodity Inert”.
  • The concentration of the dye and/or fragrance being added or changed must not exceed 1.0% (by weight) of the total pesticide product composition.
  • All ingredients of a fragrance must be approved by the Agency before a notification or amendment can be submitted for that fragrance.

How can TSG help you?

TSG’s Principal Scientific Consultant and chemistry expert, Dr. Luminita Velea can provide support and assistance when addressing CSF requirements. Questions about EPA’s best practices? Get in touch to schedule a chat with Dr. Velea: [email protected]