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Related Applications and Their Fees Primary and Secondary 

Pesticide Registration Improvement Renewal Act 

(PRIA 2) 

Primary/secondary is a term used by the Office of Pesticide 

Programs for a number of situations in which one or more 

applications or registration actions are dependent upon or 

related to another action. Because of the relationship, fees are 

generally reduced for the dependent or secondary action. 

Some of these situations were called parent/child relationships 

under PRIA 1. Primary/secondary relationships are described 

below for new active ingredients, uses, and products and 

amendments along with fees associated with the secondary actions and submission 

requirements. 

Questions on fee reductions or discretionary refunds should be directed to the registration

ombudsman for the type of pesticide, i.e. conventional, antimicrobial or biopesticide. The 

ombudsman should also be consulted when a product is submitted that contains two or more 

different types of active ingredients such as a biological or a biochemical active ingredient 

combined with a conventional active ingredient. For information on primary/secondary Plant

Incorporated Protectant (PIP) applications such as stacked PIPs, applicants should consult the 

Biopesticides and Pollution Prevention Web site or the Chief of the Microbial Pesticides

Branch. 

New Active Ingredients and First Food Use 

The fee for an application to register a new active ingredient or first food use covers any 

applications to register the active ingredient’s technical (manufacturing use) and end use 

products and any tolerance petitions submitted simultaneously. “Simultaneously” means 

received by the Agency within 14 calendar days of the date that the initial submission is 

received by the Agency. Any associated action submitted more than 14 calendar days after 

that initial submission and while the application for the new active ingredient or first food use 

is still pending will be classified as a separate new active ingredient or first food use 

application and subject to the corresponding full new active ingredient or first food use PRIA 

fee and eligible for a FIFRA Section 33(b)(8)(C) discretionary refund which must be 

requested. 

New Uses 

The fee for the application is based on the number of new uses requested and includes (a) all 

label amendments to add the new uses to registered product labels and (b) the tolerance 

petitions submitted simultaneously. “Simultaneously” means received by the Agency within 

14 calendar days of the date that the initial submission is received by the Agency. An 

additional related label amendment for that new use or other related action submitted more 

than 14 calendar days after the date of the initial submission and while the initial submission 

Related Information 

Data Requirements 

Checklists 

New Product Applications 

Submitted with New Use 

Requests (6 pp, 80K, About 

PDF) 

Primary and Secondary 

New Product Applications

(4 pp, 69K, About PDF)

Pesticides: Regulating Pesticides 

http://www.epa.gov/pesticides/regulating/fees/related-apps.html

Last updated on Wednesday, May 09, 2012

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is still pending will be classified as a separate and additional new use application subject to 

the corresponding full new use PRIA fee and eligible for a FIFRA Section 33(b)(8)(C) 

discretionary refund which must be requested by the applicant. 

Any other amendment to a registered label besides adding the new use(s), its use directions 

and precautionary and advisory statements is a separate registration action, subject to a 

separate fee for the corresponding PRIA category. 

New Product Applications Submitted with New Use 

If a new use application only proposes to register the new use for a new product, 

review of the new product application is covered by the PRIA new-use fee. Any 

additional new products submitted simultaneously are separate new product 

applications, each subject to at least an additional new use fee. However, the 

Agency will automatically apply FIFRA Section 33(b)(8)(C), the discretionary 

refund provision, to reduce the fee for these additional new product applications. 

If a new use application amends at least one registered label to add that new 

use, then any new product application submitted simultaneously with a request 

to add that same new use is considered a separate application, subject to a 

separate new use fee. The Agency will automatically apply FIFRA Section 33(b)

(8)(C), the discretionary refund provision, to reduce the fee for such a new 

product application. 

To assist applicants in identifying the appropriate fee for a secondary action 

submitted with a new use, applicants should consult the table, New Product 

Applications Submitted with New Use Requests (6 pp, 80K, About PDF) , which also 

shows the Agency’s system for tracking and linking related new product 

applications. The timeframe for the secondary decision is the same as that of the 

primary decision. 

New Products 

Each new product application is subject to a PRIA fee. If one set of data or data waivers, 

excluding product chemistry, pertains to two or more applications and the data and 

applications are submitted simultaneously, the Agency applies the discretionary refund 

provision to reduce the fee(s) for the “secondary” application(s) in accordance with FIFRA 

Section 33(b)(8)(C) to take into account the decreased amount of work required to review 

them. The Agency furthermore will apply the refund at the time the applicant pays the fee to 

reduce the burden on registrants in paying a full fee and on the Agency in issuing refunds. 

The application with the data is called the “primary” application or decision and the other 

applications dependent upon the primary’s data submitted simultaneously with the primary 

are referred to as the secondary applications or decision. “Simultaneously” means received 

by the Agency within 14 calendar days of the date that the initial primary product submission 

is received by the Agency. If not submitted “simultaneously”, the latter submission will not 

be deemed a secondary application, and a reduction in the fee will not be automatically 

considered and must be requested with a justification by the applicant. The primary 

application with the data must be submitted before or with the secondary applications; the 

secondary applications cannot be submitted prior to the primary application containing the 

data. 

If the new product application relies on data with another application such as an amendment, 

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and the two applications are not submitted simultaneously, each of these applications is 

treated as an individual, separate application with its own fee, start date, and due date. In 

these cases, the applicant must reference the data in the other application(s) and specifically 

request the fee reduction or discretionary refund. 

To identify the appropriate fee for a secondary new product, applicants should consult the 

table, Primary and Secondary New Product Applications (3 pp, 35K, About PDF) , which also 

shows the Agency’s system for tracking and linking related new product applications. The 

timeframe for the secondary decision is the same as that of the primary decision. 

Amendments 

When an applicant applies to amend a number of product labels with the same label language 

and submits a single set of data to support the change in the label language, it is considered 

one request with a single associated fee. The amendments must be submitted in the 

same package or envelope, and one set of data must apply to all of the amendments to 

qualify for a single amendment fee, otherwise, each amendment is a separate action with a 

separate fee. 

How the Agency keeps track of related applications/actions 

Each type of action is tracked in the Agency’s databases with each action identified by a 

decision (tracking) number in its database, and on pay.gov forms, invoices, and notifications 

of receipt. Each PRIA decision has a PRIA fee category and decision review timeframe 

associated with it. The Agency uses a decimal system (i.e. A540.X) that follows the number 

of a PRIA fee category to identify secondary decisions, which applicants will observe on 

different forms of correspondence from the Agency. The decimal system allows the Agency to 

link primary and secondary decisions in its tracking system and to identify the fees 

associated with secondary decisions. The decimal system is also used to identify the number 

of uses in an application and the number of active ingredients in a product. 

Type of Action Fee PRIA Tracking Code 

- Decimal

Primary Fee of category No decimal

Secondary 

No Fee $0.00 .0

25% of fee .1

Secondary new product with 

more than product chemistry – 

primary is new use amendment

Fee in table on new product 

applications submitted with 

new use requests

New use fee 

category.1

Secondary new product with 

more than product chemistry – 

primary is new product

Fee in New Products fee 

table

New Product Fee 

category.2

Two Active Ingredients in a 

Product Per active ingredient New ai fee category.2

Four uses requested for a 

registered active ingredient Per use

New use fee 

category.4 (decimal 

shows number of 

uses)

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New Active Ingredients - The application to register the technical (manufacturing use) 

product is generally designated as the primary decision and assigned the PRIA fee category 

and the fee appropriate for the fee category. The other components, i.e. end-use product 

applications and tolerance petition are considered secondary decisions. 

New Uses - One application, generally a registered technical (manufacturing use) product, is 

designated as the “primary” decision and assigned the PRIA fee category and the fee 

appropriate for the fee category. The other components, e.g., label amendments proposing 

the new use directions and tolerance petition associated with the new use are considered 

secondary decisions. If a technical (manufacturing use) label is not submitted, the product 

with the highest concentration of active ingredient will be designated the “primary” 

submission. 

New Products and Amendments - The application containing the data is designated as the 

primary decision. Other applications that are dependent on the same data are “secondary” 

decisions. 

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