TSCA/FIFRA/TRIEPA Seeks Public Comment On Whether To Limit The Scope Of The Treated Article Exemption: The U.S. Environmental Protection Agency (EPA) published an advanced notice of proposed rulemaking (ANPRM) on October 12, 2023, soliciting public comment and suggestions on specific issues related to seed treated with conventional pesticides (treated seed) and paint treated with conventional or antimicrobial pesticides (treated paint). 88 Fed. Reg. 70625. According to the ANPRM, EPA is considering whether a rule under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to regulate certain use of treated seed and treated paint products or other administrative action is appropriate considering questions raised by stakeholders. EPA notes in its October 12, 2023, press release that treated seed and treated paint are currently exempt from FIFRA registration requirements if they meet the exemption criteria pursuant to the treated article exemption. EPA requests comment and information from all stakeholders on the use and usage of treated seed, including storage, planting, and disposal of the treated seed, and on whether or to what extent treated seed products are being distributed, sold, and used contrary to treating pesticide and treated seed product labeling instructions. Similarly, EPA requests comment from stakeholders on the addition of labeling requirements on the labels of treated paint products and potential language tha

The U.S. Environmental Protection Agency (EPA) published an advanced notice of proposed rulemaking (ANPRM) on October 12, 2023, soliciting public comment and suggestions on specific issues related to seed treated with conventional pesticides (treated seed) and paint treated with conventional or antimicrobial pesticides (treated paint). 88 Fed. Reg. 70625. According to the ANPRM, EPA is considering whether a rule under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to regulate certain use of treated seed and treated paint products or other administrative action is appropriate considering questions raised by stakeholders. EPA notes in its October 12, 2023, press release that treated seed and treated paint are currently exempt from FIFRA registration requirements if they meet the exemption criteria pursuant to the treated article exemption. EPA requests comment and information from all stakeholders on the use and usage of treated seed, including storage, planting, and disposal of the treated seed, and on whether or to what extent treated seed products are being distributed, sold, and used contrary to treating pesticide and treated seed product labeling instructions. Similarly, EPA requests comment from stakeholders on the addition of labeling requirements on the labels of treated paint products and potential language tha