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Guidance on IR-4 Exemptions 

Registration Service Fees 

Guidance on IR-4 Exemptions 

1. Under what circumstances am I eligible for an InterRegional Project Number 4 (IR-4) registration service 

fee exemption?

2. How must I submit the registration request to qualify 

for the service fee exemption? 

3. What do I do if I want to amend the application? 

4. How do I request an IR-4 exemption on EPA Form 

8570-1, Application for Pesticide Registration? 

5. Who is the IR-4 contact coordinating submissions? 

6. Are applications solely associated with IR-4 tolerance 

petitions and in the public interest subject to the 21-

day initial content screen? 

7. What are some common issues that should be considered when developing these 

submissions? 

8. Are applications associated with non-food use data submitted by the IR-4 program 

eligible for the IR-4 exemption? 

9. If I request an IR-4 exemption, when will the decision review period for my 

application begin? 

1. Under what circumstances am I eligible for an Inter-Regional Project 

Number 4 (IR-4) registration service fee exemption?

If the Agency determines that an application is solely associated with a 

tolerance petition submitted in connection with IR–4 and an 

exemption from registration service fees is in the public interest, such an 

application would be exempt from registration service fees. The public 

interest finding is being discussed within the Agency. 

2. How must I submit the registration request to qualify for the service fee 

exemption? 

The registration request must be submitted simultaneously with the IR-4 

tolerance petition or within 14 days of the petition. If the registration 

request or petition is delayed, EPA will determine that the registration 

Resources 

About Registration Service 

Fees 

Questions and Answers on: 

21 Day Screening 

Worksheet 

Actions Not Covered by 

Registration Service Fees 

Biopesticides 

Fee Payments 

Fee Waivers 

Fund Management 

Guidance on Federal and 

State Agency Exemptions 

Guidance on IR-4 

Exemptions 

In-Processing of 

Applications 

Inert Ingredients 

Pesticides: Regulating Pesticides 

http://www.epa.gov/pesticides/fees/questions/guidance_ir-4.htm

Last updated on Wednesday, May 09, 2012

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request is not solely associated with an IR-4 tolerance petition and a 

registration service fee will be due. The registration application must be 

accompanied by the notice of filing for the tolerance petition. If you 

choose to submit the Section 3 registration application separately from 

the IR-4 petition but within the 14 days, reference the commodities and 

the date of the IR-4 tolerance submission so the Agency can link the 

submissions. 

3. What do I do if I want to amend the application? 

Once the 14 days have elapsed, any changes to the application will 

require a new application that will be subject to a PRIA fee unless the 

original application and petition are withdrawn and then submitted 

simultaneously again with a request for an IR-4 exemption. 

4. How do I request an IR-4 exemption on EPA Form 8570-1, Application for 

Pesticide Registration? 

To request an IR-4 exemption, include the following statement in the 

“Explanation” box of Section II: 

“This application is being submitted with a tolerance petition 

submitted in connection with IR-4. I request that EPA exempt the 

registration service fee for this application under the IR-4 

exemption provisions at FIFRA Section 33(b)(7)(E).”

Also in this section, reference the commodities that are the subject of the 

IR-4 petition. 

5. Who is the IR-4 contact coordinating submissions? 

The IR-4 Program has agreed to coordinate the submission of requests for 

IR-4 exemptions. If you have any questions, contact: 

Dr. Daniel L. Kunkel 

IR-4 Project Headquarters 

Phone: 732-932-9575 ext. 4616 

Fax: 609-514-2612 

kunkel@aesop.rutgers.edu

6. Are applications solely associated with IR-4 tolerance petitions and in the 

public interest subject to the 21-day initial content screen? 

Yes. An application must contain all the necessary forms, data, and draft 

labeling, formatted in accordance with guidance published by the Agency. 

If it does not, corrections to the application must be made by the end of 

the 21 days, beginning the day the exemption is granted. If EPA rejects 

an application and you wish the Agency to consider your application 

again, you must submit a new application. To qualify for the IR-4 

exemption, the IR-4 tolerance petition must be withdrawn and then 

submitted simultaneously with the new application. 

7. What are some common issues that should be considered when developing

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these submissions? 

A Section 3 label amendment must reflect the application rates and the 

formulations used in the IR-4 field residue trials. 

Requests to change the use directions or the formulation submitted after 

14 days of the submission of the IR-4 petition do not qualify for a PRIA 

exemption since the requests will not be solely associated with submission 

of the IR-4 petition. 

Any requests to change/add formulations, REI, PPE, PHI, use rate, 

number of applications, or add aerial application after 14 days have 

elapsed will constitute a new request and will be subject to PRIA fees. 

The Notice of Filing (NOF) provided by the registrant and submitted by IR4 must list the same commodities and proposed tolerance levels listed in 

section “F” of the IR-4 petition request. EPA will only be able to establish 

tolerances for commodities that were proposed in the Federal Register

and discussed in the NOF. 

The Agency encourages registrants to work with IR-4 to ensure that 

applications are complete when the Agency receives them. 

8. Are applications associated with non-food use data submitted by the IR-4 

program eligible for the IR-4 exemption? 

No. Under PRIA, this exemption only applies to applications solely 

associated with tolerance petitions submitted by the IR-4 program. Under 

the Federal Food, Drug, and Cosmetic Act, a non-food use application 

does not require a tolerance; therefore the application is not eligible for 

an IR-4 exemption. However, an application may be considered under 

the “minor use” provisions of FIFRA [Section 33(b)(7)(D)], or under the 

“small business waiver” provisions of FIFRA [Section 33(b)(7)(F)]. 

9. If I request an IR-4 exemption, when will the decision review period for my 

application begin? 

The decision review period will begin on the date the exemption is 

granted. Applicants will be notified by mail when the exemption has been 

granted. 

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