“Of the canceled registrations, highlights include products based on carbendazim (22), pyraclostrobin (15)…”
Flavio Hirata is an agronomist from Esalq/USP, specialist in pesticide registration, and partner at the agribusiness consulting firm AllierBrasil.
AllierBrasil is the organizer of the 15th Brasil AgrochemShow, which will happen on August 13th and 14th in São Paulo, and the AllierBrasil Forum (Nanjing, New Delhi, Osaka and São Paulo).
Pesticide registration is the gateway to market access in Brazil. Registration of a technical product and its formulated product can take up to 10 years or even more, with a cost that can exceed US$ 100,000, plus the annual maintenance fees.
In 2023, the Ministry of Agriculture of Brazil approved 555 pesticide registrations, totaling 2,737 approvals in the past 5 years. This has directly affected the market, causing increased competition, a greater number of players, reduced prices and longer payment terms (for importers).
Companies are demanding more product registrations. Even so, in 2023 the Ministry of Agriculture canceled 177 registrations, which is almost one third of the number of approved registrations in the same year.
48 technical products and 129 formulated products were cancelled, and 89 of those cancellations were upon the registration holders request.
Source: Ministry of Agriculture, adapted by AllierBrasil
Of the canceled registrations, highlights to carbendazim (22), pyraclostrobin (15), fipronil (9) and mancozeb (8). After Anvisa’s ban on carbendazim, most of the companies requested cancellations. However, there are still 21 registrations of carbendazim in Agrofit, the Ministry of Agriculture’s data system of pesticide registrations. Fipronil-based products had the second highest number of cancellations in 2023. Those were most likely motivated by Ibama’s ban on the foliar application, which was the main market for the product.
Registration Approval Year for Canceled Pesticide Products In 2023
| Year | 2013 and before | 2014 | 2015 | 2016 | 2017 | 2018 | 2019 | 2020 | 2021 | 2022 | 2023 |
| Products | 99 | 2 | 2 | 8 | 11 | 12 | 9 | 5 | 13 | 13 | 3 |
Source: Ministry of Agriculture, adapted by AllierBrasil
Almost one quarter of the cancellations, 43, were registrations approved between 2019 and 2023 (24.29%). In other words, these products didn’t even last 5 years on the market. Of these, 16.38% were approved after the beginning of 2021, with 2021 and 2022 being the years with the highest number of approved registrations that resulted in cancellations in 2023. It is important to highlight that the majority of canceled registrations were for equivalent products, according to the “Report: Canceled Registrations (vol. 2023)” elaborated by AllierBrasil.
Source: Ministry of Agriculture, adapted by AllierBrasil
Notes: TP: Technical Product
FP: Formulated Product
In regard to canceled registration requests, that is, registration processes that have not yet been completed, according to the Ministry of Agriculture, 85 requests were cancelled, including 17 rejections, of 33 technical and 52 formulated products. In regard to “cancellations”, it is common for registrant companies to request the cancellation of the claim before the process is rejected, so that it is not published as such.
The number of registration cancellations tends to increase. This is because, in accordance with Article No. 35 of the New Brazilian Pesticides Law: “Once the registration for the pesticide is approved, …, the holder of the registration will have up to 2 (two) years to start production and sales of the product, under penalty of cancellation of the granted registration”. A registration approval can take up to 10 years or more, and, ironically, the registration will be canceled if the product is not commercialized within 2 years.
Issues related to pesticide registration will be subject of several lectures at the 15th Brasil AgrochemShow, on August 13th and 14th in São Paulo.
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