How to avoid adding synergist fertilizers to become fake pesticides?

Fertilizer synergists containing chemical components that have been registered as pesticides (plant modifiers) in China are considered fake pesticides; for the ingredients in fertilizer synergists, the corresponding pesticides (plant modifiers) have not been registered in China, but pesticides (plant modifiers) have been registered abroad.
Transfer) registration is also considered a fake pesticide
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Fertilizer synergists have no registration of plant regulators at home and abroad, but they have the function of promoting growth, etc.
How to avoid plant regulators? According to Article 2 of the "Pesticide Management Regulations" (revised in 2017): The pesticides mentioned in these regulations refer to the prevention and control of diseases, pests, grasses, rats and other harmful organisms that harm agriculture and forestry, as well as the purposeful regulation of plants , Chemical synthesis of insect growth, or a substance or a mixture of several substances derived from biological or other natural substances and their preparations
.
What is the purpose of regulating plant growth? Let me start with the definition of plant growth regulators: a class of pesticides used to regulate plant growth and development.
It is a large number of compounds synthesized by humans to regulate the growth of cultivated plants and remove weeds.
It is also used in the in vitro culture of plant organs or cells.
In
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Including synthetic compounds with similar effects as natural plant hormones and natural plant hormones extracted from organisms
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From a definition point of view, both natural plant hormones and synthetic compounds with similar functions belong to the category of plant regulators
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That is to say, most of the analogues of plant regulators described are classified in the category of plant regulators regardless of whether they are registered or not
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What is the purpose of regulating plant growth? Watering, fertilizing, sunlight, wind and other climatic factors will affect (regulate) plant growth, but these factors affect (regulate) plant growth.
Obviously, these factors are not directly related to plant hormones (but may indirectly affect plant endogenous hormones).
It does not have the properties of natural plant hormones, of course it cannot be attributed to plant regulators; certain natural products affect (regulate) plant growth in different periods of plant growth and in different environments, and there is no way to define them as purposeful growth regulation.

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In my daily scientific research and work, the author found that the primary application of some microbial metabolites in plant growth significantly promotes the absorption of nutrients by plants and promotes plant vegetative growth, but the application of the same dose in the middle and late stages of plant growth instead promotes the nutrition of leaves.
Flowering and fruit setting transfer, different periods have significantly different effects on plant growth and development.
Phytohormones and their analogs often revolve around certain functions of phytohormones and continue to work, so the concentration is strict, and the large amount is easy to accumulate and form in the plant.
Phytotoxicity
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Plant growth regulators are plant endogenous hormones or analogs of endogenous hormones, which can directly affect the content of plant endogenous hormones.
Fertilizer synergists should be neither endogenous plant hormones nor similar things, and cannot directly affect The content of plant endogenous hormones is often an indirect effect, and the effect of indirect effect on plant growth regulation will not always be consistent, which is the purposeful regulation of plant growth described in the pesticide management regulations, so that it can respond to plant growth and development.
Processes and changes in the natural environment
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The extension of the domestic fertilizer definition beyond nutrients and the expression of foreign biostimulants both indirectly regulate crop growth
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But no matter how you explain it, domestic fertilizers and pesticides always have some intersections, which will increase the uncertainty of product classification, thereby increasing corporate risks.
How do foreign countries avoid it? In order to help companies determine whether biostimulant products should be managed as growth regulators in the United States, the U.
S.
Environmental Protection Agency issued a labeling guidance document for plant growth regulators and biostimulants in March 2019 and solicited public comment
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The review has ended, but the official version has not yet been released
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Although this draft guideline is not a regulatory document and has no legal effect, the views in it are worth learning from relevant companies.
The future management trend of biostimulants in the United States can also be seen from it
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First of all, according to section 2(v) of FIFRA regulations, this guide excludes some products from the jurisdiction of plant growth regulators, mainly including plant nutrients (fertilizer products), plant inoculation bacteria, soil amendments, and vitamin-phytohormones.
Products
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These products do not need to obtain EPA pesticide registration in accordance with FIFRA regulations
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At the same time, the guide also gives the label descriptions corresponding to these products
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Taking fertilizer products as an example, the label states as follows: avoid or prevent the occurrence of plant deficiency; improve soil nutrient conditions, increase the overall plant quality or yield; improve the living environment of symbiotic and non-symbiotic microorganisms in the rhizosphere, and promote plant nutrient absorption, etc.

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Tag corresponding to soil amendment include the following: adjusting the pH of soil; cation exchange capacity changes and the like
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However, the above are only for these 4 types of products, and do not cover other indistinguishable biostimulant products
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Therefore, the EPA has also given an additional “non-pesticidal claims”, see the original text of the guidance document for details
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Some examples of expressions are shown in the figure below
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Examples of general non-pesticide label expressions in the EPA guidelines At the same time, the guidelines divide the corresponding label expressions into 4 categories based on the product efficacy described in the definition of plant growth regulators in the FIFRA regulations, namely, accelerating or delaying plant growth; accelerating or delaying plant maturity ; Change the morphology of plants; improve the quality of plant products
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The guide also lists specific expression examples for each function category to guide companies in the judgment and selection of compliance
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Take "accelerating or delaying plant growth" as an example, the label expression of this effect can be "promoting plant cell growth, stimulating cell division and differentiation, promoting rooting, promoting stem elongation, etc.
"; similarly, the label expression of "changing plant morphology" It can be "change the morphology of plants, control root tillers, etc.
"
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The corresponding label expression examples of these four functions are shown in the figure below
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Examples of plant growth regulator label expressions in the EPA guidelines In short, to determine whether a product enters the U.
S.
market as a biostimulant or a plant growth regulator, a preliminary judgment should be made with the exclusion method based on the guidelines
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First, determine whether it belongs to the four categories of products that are specifically excluded by FIFRA section 2(v)
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If it does not belong to the above 4 categories of products, then combine the effects of the product itself, and compare the label expression of plant growth regulators and the label expression of other non-pesticide products to make judgments and selections
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The determination of the product category with both modulator and biostimulant effects depends on the company's market positioning of the product
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For products on the market that express the efficacy of modulators, they need to apply for EPA pesticide registration under pesticide management; otherwise, they do not need to obtain EPA pesticide registration
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(The relevant content of the US Environmental Protection Agency is quoted from the second issue of World Pesticides.
) Summary Fertilizer synergists must be legalized in order to be able to sustainably develop healthily.
Avoiding the "trap" of plant regulators is an important part of it.
The author proposes from the following two aspects Some suggestions: 1.
Fertilizer synergist should strengthen the mechanism research, through systematic scientific research, it is proved that it is not "influence (regulate) plant growth purposefully", so that it can be fundamentally demarcated from plant growth regulators.
Limit illegal evasion
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2.
Fertilizer synergists should establish and formulate standards as soon as possible in the country to give fertilizer synergists a clear positioning, which will promote the healthy development of fertilizers containing synergists under the framework of the standard
.
3.
Fertilizers containing synergists should refer to the guidelines of the U.
S.
Environmental Protection Agency.
In addition to not containing plant regulators registered at home and abroad, as far as possible, refer to the label expression of fertilizer synergists (biostimulants) for improving nutrient supply and soil improvement.
Do not use plant regulators for expressions such as structure, improving nutrient absorption and assimilation efficiency, increasing soil beneficial microbial populations, degrading soil organic matter, and resisting adversity stress
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Finally, I hope that domestic production, learning, research, politics, and promotion will be deeply integrated to develop fertilizer synergists into a large industry and contribute to the cause of weight loss and efficiency in my country! (From? China Organic Fertilizer Association)