No.

Does leaching of PFAS into a pesticide from a fluorinated container constitute intentionally added PFAS in a product?

No.

No

Registrants are responsible for determining if their products meet the definition of “cleaning product” and notifying the MDA on renewals.

Who determines if my product is a cleaning product?

Registrants are responsible for determining if their products meet the definition of “cleaning product” and notifying the MDA on renewals.

No

Any registrant or manufacturer that would like to continue registering a product with the MDA that contains intentionally added PFAS after the statutory deadlines for prohibition (January 1, 2026 for cleaning products and January 1, 2032 for all other pesticide, fertilizer, soil and plant amendment, and agricultural liming products).

Who must submit CUU applications to the MDA?

Any registrant or manufacturer that would like to continue registering a product with the MDA that contains intentionally added PFAS after the statutory deadlines for prohibition (January 1, 2026 for cleaning products and January 1, 2032 for all other pesticide, fertilizer, soil and plant amendment, and agricultural liming products).

No

Yes. Registrants of distributor products must submit a currently unavoidable use exemption application for distributor products. The application can refer (i.e., “right to refer”) to decisions made about the section 3 product as support for an exemption.

Do distributor products need to get currently unavoidable use exemptions if the section 3 product has received a currently unavoidable use exemption?

Yes. Registrants of distributor products must submit a currently unavoidable use exemption application for distributor products. The application can refer (i.e., “right to refer”) to decisions made about the section 3 product as support for an exemption.

No

Pesticide products with intentionally added PFAS are regulated by the MDA while treated articles, such as pesticide treated seeds, with intentionally added PFAS are regulated by the MPCA. Many pesticide products may be used in or on treated articles. The MDA and the MPCA are working together to determine how CUU exemptions will be handled for treated articles. The MPCA will conduct rulemaking for laying out their CUU exemption process including for treated articles. Guidelines for treated article CUU exemptions will be posted on MDA’s website, when finalized.

If a CUU is obtained for a seed treatment pesticide, is an additional CUU exemption needed for the treated seed?

Pesticide products with intentionally added PFAS are regulated by the MDA while treated articles, such as pesticide treated seeds, with intentionally added PFAS are regulated by the MPCA. Many pesticide products may be used in or on treated articles. The MDA and the MPCA are working together to determine how CUU exemptions will be handled for treated articles. The MPCA will conduct rulemaking for laying out their CUU exemption process including for treated articles. Guidelines for treated article CUU exemptions will be posted on MDA’s website, when finalized.

No