This document sets out the procedures and data required to support changes to plant protection products to reflect use on undersown crops.
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 treatments do not have label recommendations for use on undersown crops, and thus use of pesticides on a cereal crop undersown with grass/clover technically breaches the conditions of approval. This may have an impact on single farm payments.
To regularise the position, and in recognition of this common agricultural practice, we would like to encourage approval holders to add undersown crops to their product labels, by submitting an application for approval.
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 approved for use on cereals may be made via the admin. route. The application would not require revised draft labels, but should include the following information:
- Details of product name, Ministerially Approved Pesticide Product (MAPP) number, active ingredient(s) and type of product (i.e. fungicide, insecticide) on the appropriate application form.
- A statement relating to consumer safety (see section below)
- A statement relating to undersown crop safety (see section below)
Consumer safety
The applicant is required to provide a statement that they have evidence to demonstrate that there will be no increased risk to consumers from the addition of under sown crops to the label, for the listed products applied as foliar treatments to cereals. This evidence could be based on the approved use on the cereal crop, the known properties and behaviour of the active substance or a simple risk assessment.
Crop safety
The applicant is required to provide a statement that they have considered the crop safety profile of the product and that it would not be expected to cause crop damage to the under-sown 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 (i.e. fungicide, insecticide) on the appropriate application form.
- A statement relating to consumer safety (see section above)
- Data or a case to substantiate crop safety to the under-sowing must be provided.
It would also be possible to add a request for undersown crops to an application submitted for other reasons.
How will approvals be amended?
Where the application is successful, an amended approval will be issued, specifying undersown crops of grass/clover and allowing these uses to be added to the product label. Please note that this change to the label can be made to Control of Pesticides Regulations (COPR) approvals (or Plant Protection Products Regulations (PPPR) provisional approvals) during the transitional period following Annex I inclusion.
When the product is assessed at Step 2 of re-registration (following Annex I inclusion or renewal), approval holders will be required to provide the evidence supporting the statements on consumer safety and crop safety
