Recently, the Ministry of Agriculture and Rural Affairs issued Announcement No. 925, putting forward further requirements on the labeling of pesticide labels and instructions. Officials from the Crop Production Management Department (Pesticide Management Department) and the Legal Affairs Department of the Ministry of Agriculture and Rural Affairs accepted interviews with media reporters to interpret the relevant contents of Announcement No. 925.

Q: Could you please introduce the considerations behind the issuance of Announcement No. 925?

A: Since the promulgation and implementation of the "Measures for the Administration of Pesticide Labels and Instructions" in 2017, it has played an important role in ensuring the quality of pesticide products and the safety of pesticide use. After years of development, new situations and changes have occurred in agricultural production methods, pesticide business formats, and pesticide application technologies. In particular, new problems have emerged, such as difficulties in tracing the original drugs used in pesticide products and the sale of the same product under different trademarks. These problems are not conducive to ensuring pesticide quality, maintaining a fair competition order in the pesticide market, or protecting the legitimate rights and interests of the majority of farmers. In response to the above problems, it is necessary to further standardize pesticide labels in combination with reality to promote the healthy and sustainable development of the pesticide industry.

Q: How to understand the labeling of source information of technical materials (parent drugs) on pesticide formulation products?

A: Pesticide formulation products are processed from pesticide technical materials (parent drugs). Labeling the source information of technical materials (parent drugs) on the labels of pesticide formulation products, with the holder of the formulation product registration certificate being responsible for the authenticity of the information, helps to ensure the quality of formulation products. According to the requirements of Announcement No. 925, the source information of technical materials (parent drugs) includes the registration certificate number and the name of the manufacturer of the technical materials (parent drugs). For imported technical materials (parent drugs), the source information refers to the registration certificate number and the holder's information. The above information can be directly printed on the label or reflected in the traceable electronic information code. If different batches of formulations are processed using different technical materials (parent drugs), the corresponding labels shall be made respectively.

It should be noted that if the registration of technical materials (parent drugs) is exempted due to technical, safety and other reasons, and the production license obtained by the enterprise complies with relevant regulations, the pesticide formulation products may not label the information of technical materials (parent drugs).

Q: How to understand that pesticide products with the same registration certificate number should be labeled with the same trademark?

A: After the cancellation of commodity names for pesticide products, trademarks actually play the role of commodity names, and farmers usually identify and choose pesticide products by trademarks. In practice, some pesticide products with the same registration certificate number are sold in the market with different trademarks, making farmers mistakenly think they are different pesticide products. This causes difficulties for farmers in selecting pesticides, repeated use of pesticides, etc., disrupts the order of the pesticide market, affects the healthy development of the industry, is not conducive to the supervision of pesticide quality, and also brings hidden dangers to agricultural production and the quality and safety of agricultural products. To implement the requirements for building a unified national market, Announcement No. 925 stipulates that pesticide products with the same registration certificate number shall be labeled with the same trademark to ensure the consistency of trademarks used for products sold nationwide. Specifically, on the premise of complying with Article 31 of the "Measures for the Administration of Pesticide Labels and Instructions", pesticide products with the same registration certificate number can be labeled with one or more trademarks according to actual needs, but the consistency of the trademarks labeled on pesticide products with the same registration certificate number sold in the market must be maintained.

The Ministry will open a column for reporting product trademark information in the "Approved Label Query Window" of the pesticide management information platform. Holders of pesticide registration certificates shall truthfully and timely report the trademarks labeled on pesticide labels and their change information through this column.

Q: Why are products processed or repackaged by entrustment not allowed to label the trustee's trademark?

A: Entrustment is an act in which the trustee carries out entrusted activities in the name of the entrustor, and the entrustor bears the corresponding legal consequences. Article 19 of the "Regulations on the Administration of Pesticides" stipulates that for entrusted processing or repackaging of pesticides, the entrustor shall obtain the corresponding pesticide registration certificate and be responsible for the quality of the pesticides processed or repackaged under entrustment; Article 47 stipulates that it is prohibited to transfer, lease or lend pesticide registration certificates. In practice, some enterprises, in the name of entrusted processing or repackaging, actually rent or lend pesticide registration certificates, and label the trustee's trademark on the labels of pesticide products processed or repackaged under entrustment. This not only violates the basic principles of the entrusted legal relationship, but also misleads farmers. In response to the above problems, the announcement clearly stipulates that products processed or repackaged by entrustment are not allowed to label the trustee's trademark, which helps to further standardize the order of the pesticide market and protect the rights and interests of farmers, such as the right to know and the right to choose.

Q: What are the special requirements for labeling pesticide products used for herbicide-tolerant crops?

A: At present, herbicide-tolerant crops in agricultural production are mainly divided into two categories: genetically modified and non-genetically modified. Pesticide products used for these two categories of crops shall be labeled in accordance with Announcement No. 925. Those used for non-genetically modified herbicide-tolerant crops shall be labeled according to the crop variety; those used for genetically modified herbicide-tolerant crops shall be labeled according to the transformant. Among them, the labels of pesticide products used for genetically modified herbicide-tolerant crops shall also comply with the requirements of Announcement No. 542 of the Ministry of Agriculture and Rural Affairs regarding label content, safety protection, application technology, etc.

Q: What information about designated adjuvants should be labeled when pesticide product labels indicate designated adjuvants?

A: To ensure safety and stability, some pesticide products need to be added with designated adjuvants when used. In accordance with the "Measures for the Administration of Pesticide Registration", such products shall submit pesticide registration test data containing the corresponding adjuvants during pesticide registration. In connection with the registration requirements, the labels of pesticides shall also indicate the name, main components and other contents of the designated adjuvants.

Q: What should be done if the labeling of pesticide product labels does not comply with the provisions of Announcement No. 925?

A: According to Articles 22 and 23 of the "Regulations on the Administration of Pesticides", pesticide labels and instructions shall comply with the relevant provisions of the Ministry of Agriculture and Rural Affairs and shall not contain false or misleading contents for users. According to Articles 53 and 57 of the "Regulations on the Administration of Pesticides", if the packaging, labels or instructions of pesticides produced, purchased or sold do not meet the requirements, the agricultural and rural departments at or above the county level shall order corrections, confiscate illegal gains and illegally produced or traded pesticides, and impose fines; if they refuse to make corrections or the circumstances are serious, the issuing authority shall revoke the pesticide production and operation licenses and the corresponding pesticide registration certificates. After the implementation of this announcement, pesticide product labels and instructions that do not comply with the announcement shall be investigated and dealt with in accordance with the relevant provisions of the "Regulations on the Administration of Pesticides". It should be noted that pesticide product labels and instructions produced before January 1, 2026 that are inconsistent with this announcement can continue to be sold within the validity period of the products.