EPA Registration Jacket 84229‐16
1

) 

Material to be added to an e-Jacket/Jacket 

Reg. No. Decision # Y""z':J"{ 2...-:?, 

Description: 

1. Placement within the e-Jacket/jacket: 

o Default: (chronological, top = newest) 

o File Location: (eg. "before page 45 in .pdf') 

2. lS6Send to Data Extraction contractors this material: 

IS!rNewly stamped accepted label 

o Notification 

GYNewCSF 

o Other: ___________ _ 

3. Attach this coversheet to the top of the material or jacket. It must be well 

organized and clipped together, NOT STAPLED. Then give the material with 

this coversheet to staff in the Information Services Center (Room S-4900). 

Reviewer: J~~ ~ Division: RD 

Phone: '30 lo-6'-<. l -s- Date: lL- S--(o 

Created November 5, 2010 
2

#~'iOS1",,~ U.S. ENVIRONMENTAL PROTECTION AGENCY EPA Reg. Numbcr: Date oflssuancc: 

\.9z'" Office of Chemical Safety and Pollution Prevention s fa • 0 Registration Division (7S0SP) 84229-16 NOV 5 2010 

~,,,,,,,,,oi 1200 Pennsylvania Ave., N.W. 

Washington, D.C. 20460 

NOTICE OF PESTICIDE: Term of Issuancc: --X Registration 

(under FIFRA, as amended) 

_ Reregistration Unconditional 

Name of Pesticide PrOduct: 

Tide Technical ~A 

Namc and Address ofRegistra!lt (include ZIP Code): 

Tide International USA, Inc. 

c/o Pyxis Regulatory Consulting, Inc. 

4110136'" S1. NW 

Gig WA 98332 

Note: Changes in labeling differing in substancc Ii-om that acceptcd in connection with this registration must be submitted to and accepted by the 

Rcgistration Division prior to use of the label in commerce. In any correspondence on this product always refer to the above EPA registration number. 

On the basis of information furnished by the registrant, the above named pesticide is hereby registered/reregistered under the Federal Insecticide, Fungicide 

and Rodenticide Act. 

Registration is in no way to be construed as an endorsement or recommendation of this product by the Agency. In order to protect health and the 

environment. the Administrator, on his motion, may at any time suspend or cancel the registration of a pesticide in accordance with the Act. The acceptance 

of any name in connection with the registration ofa product under this Act is not to be construed as giving the registrant a right to exclusive use of the name 

or to its usc ifit has becn covclCd by others. 

This product is conditionally registered in accordance with FIFRA section 3(c)(5) provided that 

you: 

I. Submit and/or cite all data required for registration/reregistration/registration review of your 

product when the Agency requires all registrants of similar products to submit such data. 

2. Make the following label changes before you release the product for shipment: 

a. Revise the EPA Registration Number to read, "EPA Reg. No. 84229~16". 

3. The data requirements for storage stability (830-6317) and corrosion characteristics (830-

6320) have not been satisfied, and must be submitted within eighteen months of the date of 

this letter. 

Sfgl;om'[~ Datc: 

NOV 5 2010 Venus Eagle, Product Manager (0 I) . ,A. _L • ..:. 

"AFom' 
3

Page 2 

EPA Reg. No. 84229-16 

4. Submit one copy of the revised final printed label for the record before you release the product 

for sm pment. 

If these conditions are not complied with, the registration will be subject to cancellation in 

accordance with FIFRA section 6( e). Your release for shipment of the product constitutes acceptance of 

these conditions. 

A stamped copy of the label is enclosed for your records. If you have any questions regarding 

this notice, please contact Kable Bo Davis at (703) 306~0415 davis.kable@epa.gov. 

Enclosure- Stamped Labeling 

Venus Eagle 

Product Manager (01) 

Insecticide-Rodenticide Branch 

Registration Division (7505P) 
4

Tide Technical Imidacloprid 

FOR MANUFACTURING USE ONLY 

ACTIVE INGREDIENT: 

Imidacloprid, 

1-[( 6-chl oro-3 -pyridi nyl)metby I] -N-nitro-2-im idazol idinim ine ......................................... , ...... " ......... 99.0% 

OTHER INGREDIENTS: ................................................................................................................... 1.0% 

TOTAL: ............................................................................................................................................. 100.0% 

If swallowed: 

KEEP OUT OF REACH OF CHILDREN 

CAUTION 

FIRST AID 

• Call a poison control center or doctor immediately for treatment advice. 

• Have person sip a glass of water if able to swallow. 

• Do not induce vomiting unless told to do so by the poison control center 

or doctor. 

• Do notgive anything by mouth to an unconscious person. 

NOTE TO PHYSICIAN 

No specific antidote is available. Treat symptomatically. 

HOT LINE NUMBER 

Have the product container or label with you when calling a poison control center or doctor, or going for 

treatment. You may also contact CHEMTREC at 1-800-424-9300 for emergency medical treatment 

information. 

EPA Reg. No. 84229-xx 

EPA Est. No. 

Net Weight: 

ACCEPTED 

wP.ih COIvnmNTS ~;D. EPA Letter Dated: 

NOV 5 2010 

Manufactured for: 

Tide International USA, Inc. 

21 Hubble 

Irvine, CA 92618 
5

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

CAUTION 

Harmful if swallowed. Wash thoroughly with soap and water after handling and before eating, drinking, 

or using tobacco. Wear long~sleeved shirt and long pants, socks, shoes and chemical resistant gloves 

made of any waterproof material such as barrier laminate, butyl rubber, nitrile rubber, neoprene rubber, 

natural rubber, polyethylene, polyvinylchloride (PVC) or viten. 

ENVIRONMENTAL I1AZARDS 

This product is highly toxic to aquatic invertebrates. Keep out of lakes, streams, or ponds. Do not 

discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans, or other waters 

unless in accordance with the requirements of a National Pollutant Discharge Elimination System 

(NPDES) pennit and the permitting authority has been notified in writing prior to discharge. Do not 

discharge effluent containing this product to sewer systems without previously notifYing the local sewage 

treatment plant authority. For guidance, contact your State Water Board or Regional Office of the EPA. 

DIRECTIONS FOR USE 

It is a violation of Federal law to use this product in a manner inconsistent with its labeling. This product 

is to be used only for formulation into registered insecticide products and is not for resale under this label. 

Instructions to Formulators: This technical product may be used to manufacture insecticide end-use 

products for: 

I) Terrestrial Non-Food Crop, Residential and Commercial Outdoor (including Greenhouses): lawn, turf 

and ornamentals in and around residential or commercial buildings; 

2) Residential and Commercial Indoor Non-Food: Greenhouse ornamentals 

3): Terrestrial Non-food Crop Use, Domestic Indoor & Outdoor Use: companion animals. 

4) Uses for which U. S. EPA has accepted the required data andlor citation of data that the fonnulator has 

submitted in support of registration; 

5) Uses for experimental purposes that are in compliance with U.S. EPA requirements; and 

6) Terrestrial Food Crops, including: 

Barley 

Head and Stem Brassica Vegetables 

Bushberries 

Canola 

Citrus (containerized and field) 

Cotton 

Cranberries 

Fruiting Vegetables 

Grapes 

Greenhouse Vegetables (tomato, cucumber) 

Hops 

LeafY Petiole Vegetables 

Leafy Vegetables 

Legume Vegetables 

Pecan 

Pome Fruits 

Potato (including seed piece treatment) 

Root Vegetables 

Strawberries 

Stone Fruit 

Sugarbeet 

Tobacco 

Tuberous and Conn Vegetables 

Tropical Fruits 

Oats 

Rye 

Sorghum 

Wheat 

2 
6

STORAGE AND DISPOSAL 

Do not contaminate water, food or feed by storage or disposal. 

PESTICIDE STORAGE: Store in a cool, dry place away from food, drink and animal feeding stuffs. 

If spilled, do not. flush to waterways (see Environmental Hazards). Carefully collect and containerize 

spilled material in a manner that produces the least amount of airborne dust. Suitable protective 

equipment should be worn during any spill cleanup operation (see Precautionary Statements). Residual 

surface material may be removed with towels moistened with methanol. 

PESTICIDE DISPOSAL: Pesticide wastes are acutely hazardous. Wastes resulting from the use of 

this product may be disposed of on site or at an approved waste disposal facility. 

CONTAINER DISPOSAL: 

Container Disposal - Liner: Nonrefillable container. Do not reuse or refill this container. 

Completely empty liner into application equipment by shaking and tapping sides and bottom to loosen 

clinging particles. When completely empty offer for recycling if available or dispose of liner in a sanitary 

landfill. 

Container Disposal- Outer Drum: Nonrefillable container. Do not reuse or refill this container. When 

completely empty offer for recycling if available or dispose of box in a sanitary landfill. 

CONDITION OF SALE AND LIMITATION OF WARRANTY AND LIABILITY 

NOTICE: Read the entire Directions for Use and Conditions of Sale and Limitation of Warranty and Liability 

before buying or using this product. If the terms are not acceptable, retum the product at once, unopened, and the 

purchase price will be refunded. 

The Directions for Use of this product must be followed carefully. It is impossible to eliminate all risks inherently 

associated with the use of this product. Ineffectiveness or other unintended consequences may result because of 

such factors as manner of use or application, weather, presence of other materials or other influencing factors in the 

use of the product, which are beyond the control of Tide International USA, Inc. or Seller. AD such risks shall be 

assumed by Buyer and User, and Buyer and User agree to hold Tide International USA, Inc. and Seller hannless for 

any claims relating to such factors. 

Tide International USA, Inc. warrants that this product conforms to the chemical description on the label and is 

reasonably fit for the purposes stated in the Directions for Use, subject to the inherent risks referred to above, when 

used in accordance with directions under normal use conditions. This warranty does not extend to the use of this 

product contrary to label instructions, or under abnormal conditions or under conditions not reasonably foreseeable 

to or beyond the control of Seller or Tide International USA, Inc., and Buyer and User assume the risk of any such 

use. TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, TIDE INTERNATIONAL USA, [NC. 

MAKES NO WARRANTIES OF MERCHANTABILITY OR OF FITNESS FOR A PARTICULAR PURPOSE 

NOR ANY OTHER EXPRESS OR IMPLIED WARRANTY EXCEPT AS STATED ABOVE. 

To the extent consistent with applicable law, neither Tide International USA, Inc. or Seller shall be liable for any 

incidental, consequential or special damages resulting from the use or handling of this product. TO THE EXTENT 

CONSISTENT WITH APPLICABLE LAW, THE EXCLUSIVE REMEDY OF THE USER OR BUYER, 

AND THE EXCLUSIVE LIABILITY OF TIDE INTERNATIONAL USA, INC. AND SELLER FOR ANY 

AND ALL CLAIMS, LOSSES, INJURIES OR DAMAGES (INCLUDING CLAIMS BASED ON BREACH 

OF WARRANTY, CONTRACT, NEGLIGENCE, TORT, STRICT LIABILITY OR OTHERWISE) 

RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, SHALL BE THE RETURN OF 

THE PURCHASE PRICE OF THE PRODUCT OR, AT THE ELECTION OF TIDE INTERNATIONAL 

USA, INC. OR SELLER, THE REPLACEMENT OF THE PRODUCT. 

Tide International USA, Inc. and Seller offer this product, and Buyer and User accept it, subject to the foregoing 

Conditions of Sale and Limitation of Warranty and Liability, which may not be modified except by written 

agreement signed by a duly authorized representative of Tide International USA, Inc. 

[EPA approval date] 

3 
7

Form approved. OMS No. 2070-0060, 2070-0057, 2076~o107, 2070-0122. 2070-0164. 

Applicant's Name and Address 

Tide International USA, Inc. 

21 Hubble 

United States 

Environmental Protection Agency 

Washington, DC 20460 

Formulator's Exemption Statement 

(40 CFR 152.85) 

EPA File SymbolJRegistration Number 

84229-

Product Name 

Tide Technical Imidacloprid 

Irvine, CA 92618 

Date of Confidential Statement of Formula (EPA Form 8570-4) 

07/22/2010 

(1) This product contains the following active ingredient(s): 

Imidacloprid 

(2) Of these, each active ingredient listed in paragraph (4) is present solely as the result of the use of that active ingredient in the manufacturing, 

formulation or repackaging another product which contains that active ingredient which is registered under FIFRA Section 3, is purchased by 

us from another person and meets the requirements of 40 CFR section 158,50(e)(2) or (3). 

(3) Indicate by checking (A) or (8) below which paragraph applies: 

71 (Al An accurate Confidential Statement of Formula (EPA FORM 8570-4) for the above identified product is attached to this statement. 

That formula statement indicates, by company name, registration number, and product name, the source of the active ingredient(s) listed in 

paragraph (1). 

OR 

I (B) The Confidential Statement of Formula (CSF)(EPA Form 8570-4) referenced above and on file with the EPA is complete, current an 

accurate and contains the information required on the current CSF. 

(4) The following active ingredients in this product qualify for the formulator's exemptton. 

Source 

ill 

Michael 

n 

n, • 

o 

• , • , • > , 

, 

, ... 

'" . *Product ingredient source information may be entitled to confidential treatment*
8

4110 136m St. NW 

Gig Harbor, WA 98332 

COURIER DELIVERY 

Venus Eagle (PM 1) 

Document Processing Desk (REGFEE) 

Office of Pesticide Programs (7504P) 

U.S. Environmental Protection Agency 

Room S-4900, One Potomac Yard 

2777 S. Crystal Drive 

Arlington, VA 22202-4501 

July 22, 2010 

Phone: 253-853-7369 

Fax: 253-853-5516 

www.PyxisRC.com 

RE: Tide International USA, Inc. - Tide Technical Imidacloprid (EPA Reg. No. 84229- ) 

Application for a New Pesticide Registration 

Dear Ms. Eagle, 

On behalf of Tide International USA, Inc. please find the enclosed application materials for registration of 

Tide Technical Imidacloprid, a technical product containing imidac10prid as the active ingredient. 

In support of this application, we submit the following documents: 

I. Application for a New Pesticide Registration (EPA Fonn 8570-1) 

2. Receipt ofPRIA pre-payment from pay.gov 

3. Confidential Statement of Formula 

4. Five (5) copies of the proposed labeling 

5. Certification With Respect to Label Integrity 

6. One copy of the Tide Technical Imidacloprid proposed label on CD 

7. Formulator's Exemption Statement (EPA Form 8570-27) 

8. Letter of Authorization 

We trust you will find this application complete and in compliance with the requirements for registration 

under FlFRA. Please feel free to call me if you have any questions or need any additional information. 

Sincerely, 

:/!iJj}~ Michael Ke!Jogg 

Enclosures 

cc: D. Wang; Tide International USA, Inc. 

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') ~1.at.K 'form. " .•. 'ov "~l on, 

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United States D Registration opp Identifier Number 

&EPA Environmental Protection Agency Amendment 

We,hington, DC 20460 Other 

Application for Pesticide - Section I 

1. Company/Product Number 2. EPA Product Manager 3. Proposed Clossification 

84229-.e .... V. Eagle 0 Nono D Restricted 

4. Company/Product (Nomo) PM. 

Tide International USA, Inc. I Tide Technicallmidacloprid 1 

5. Nllmo lind Addross of Applicant (Includ. ZIP Codel 6. Expedited Reveiw. In accordance with FfFRA Section 31cH3) 

Tide International USA, Inc. )b))il, mv product is similar or identical in composition and labeling 

c/o Pyxis Regulatory Consulting, Inc. to: 

4110 136th S1. NW EPA Reg. No. 

Gio Harbor. WA 98332 D Chock if rhfs js a new address Product Name 

Section - II 

0 Amendment - Explein billow. U Final printod labels in rapsonso to 

Agency lener deted 

0 Resubmission in response to Agency lener deted 0 ~Me Too~ Applicetion. 

0 Notification - Explain below. 0 Other· Explain below_ 

Explanation: Use odditionul pagels) ir necessary. (For section I end Soction II.) 

This application falls under R300 (44) since it is a 100% repack of a registered product and no data is being submitted. The fee due is $1365 

and the decision limeline is 3 months. A receipt of pre-payment from pay.gov is enclosed with this application for registration. Should you 

have any questions, please contact me at (email) Mike@PyxisRC.comor(phone) 253-853-7369. 

Section - III 

1. Met.rlel Thi. Product Will Be Pockaged In: 

Child-Resistant Packeging Unit Packeging Watar Solubla Packaging 2. Type of Conteiner 

~V" ~Y" B V" 

,f No ,f No gM.'" Plastic 

No GlaS!J 

* Certification must If ~Yes~ No. per If ·Yos~ No. per Paper lined fiber drum Unit Peokeging wgt. conteiner Packaga wgt oonteiner .t Other tSpecifyr btl submitttld , 3. Locution of Net Contents Informetion 4. Sizer,) Retell Conteiner S. Looation of Lablll Directions 

[{J Label U Contoiner 2.2 kg (5 Ib), 20 kg (44 Ib), 25 kg (55) t:::=j On Label 

On LabelinG nceampany;ng praduel 

6. Menner in Which Lebal Is Affixed to Product UUthogrePh 0 Other 

.I Paper.Pelued 

Stenci ed 

Section -IV 

1. Contect Point {Comp/ere itams direcrly below for fdanrffic.rion of fndiyfdulll to bll contacted, if necessary, ro process (hit; applicarion.) 

Name Title Telephone No. (Include Arell Code) 

Michael Kellogg Agent (253) 853-7369, 

Certification 6. Data Application 

I oenify that the statements I hllve made on this form and ell attachments thareto ere true, eccurete ond complete. Re'C&ivoU , • 

I acknOWledge that IIny knowlinglly felse or misleading statemont may be punhlhable by fine or imprisonment af ~ • : (Stamped) both under epplicebleleW. • , • , , , .. , 

2. Signeturo . ;/ () 3. Titlll · .. ~ ~ , • • , , • , .. • • ~ - 'df'! Agent .. •••• 

• • , · ... , .. • 77 · • 4. Typed Neme 5.01lto .. • • • ,~. 

Michael Kellogg 7/ -'? <"7/;0 · , ... • , . • 

- EPA Form 8570·1 " IR.v. 3-941 PreViOUS adltlons Uf8 obsoleto. White • EPA File Copy longlnen • 

*Product ingredient source information may be entitled to confidential treatment*
10

Mike Kellogg 

From: 

Sent: 

To: 

paygovadmin@maH.doc.twaLgov 

Thursday, July 22, 2010 4:36 PM 

Mike Kellogg 

Subject: Pay. Gov Payment Confirmation 

THIS IS AN AUTOMATED MESSAGE. PLEASE DO NOT REPLY. 

Your transaction has been successfully completed. 

Transaction Summary 

Application Name: PRIA Service Fees 

Pay.gov Tracking 1D: 2S1669G] 

Agency Tracking 1D: 74128228884 

Account Holder Name: Der I Wang 

Transaction Type: Sale 

Transaction Amount: $1~365.ee ~ 

Billing Address: 2ee7A~ Via Mariposa West 

City: Laguna Woods 

State/Province: CA 

Zip/Postal Code: 92637 

country: USA 

Card Type: American Express 

Card Number: ***********1886 

Transaction Date: Jul 22~ 2919 7:35:51 PM 

Decision Number: 

Registration Number: 84229-xx 

Company Name: Tide International USA 

Company Number: 84229 

Action Code: R3ee 

1 

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UNITED STATES ENVIRONMENTAL PROTECnOt{ AGENCY 

WASHINGTON, D.C. 20460 

July 28, 20 I 0 

OPP Decision Number: D-437723 

EPA File Symbol or Registration Number: 84229-RA 

Product Name: TIDE TECHNICAL IMIDACLOPRID 

EPA Receipt Date: 26-Jul-2010 

EPA Company Number: 84229 

Company Name: TIDE INTERNATIONAL, USA, INC. 

JANELLE KAY 

TIDE INTERNATIONAL, USA, INC. 

C/O PYXIS REGULATORY CONSULTING, INC 

411 0 136TH ST. NW 

GlGHARBOR, WA 98332-

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

SUBJECT: Receipt of Registration Application Subject to Registration Service Fee 

Dear Registrant: 

The Office of Pesticide Programs has received your application and certification of 

payment. If you submitted data with this application, the results of the PRN-86-5 screen will be 

communicated separately. During the administrative screen, the Office of Pesticide Programs 

has detennined that this Action is subject to a Pesticide Registration Service Fee as defined in 

the Pesticide Registration Improvement Act. 

The Action has been identified as Action Code: R300 

NEW PRODUCT;ME-TOO PRODUCT FAST TRACK; 

No additional payment is due at this time. 

If you have any questions, please contact the Pesticide Registration Service Fee 

Ombudsman at (703) 308-9362. 

Front 

Sincerely,? 

End Processing 

~ Staff ~ 

Information Technology & Resources Management Division 
12

i 

IFee for Servicel 

)/ 

{879092>-

This package includes the following 

(!l New Registration 

°Amendment 

for Division 

OAD 

oBPPD 

@RD 

I 

i 0 Studies? 0 Fee Waiver? 

I 0 volpay % Reduction: 

Risk Mgr. OJ 

Receipt No. 

EPA File Symbol/Reg. No. 

Pin-Punch Date: 

s-I 879092 :====~ 

I 84229-RA 

i 7/26/2010 

D This item is NOT subject to FFS action. 

Action Code-: 

Iii 

:! Parent/Child Decisions: I 

Requested: I JZ30D Iii ! 

Granted: II( J;o-v I , 

:.--

Amount Due: $ 13';j- , I 

i i 

--,'---------- I ' 

1m Inert Cleared for Intended Use [ill 

ReViewer~ 

Remarks: 

Uncleared Inert in Product 

Date: :?j?rj;o---
13

, 

PRlA 2 - 21 Day Content Screen Review Worksheet 

(EP AlOPP Use Only) 

3/23/09 

21 Day Screen Start Date: -71-----"....?-:.;;(p;.--=-(-,,---------=----:o;-

Experts In-Processing Signature: i3. "Z- Date 7- 2..'lf -/0 Fee Paid: Yes ~ 

Division management contacted on issues No Yes Date _____ _ 

EPA Reg. N\llllber: ?rj;129 - f?1l- EPA Receipt Date: 7- 2.(,. -10 

Items for Review Yes No N/A* 

1 Application Form (EPA Fonn 8570-1)(link to fonn) signed & complete 

including package type x: 

Confidential Statement of Formula all boxes completed, [onn signed, and 

dated (EPA Fonn '<~A ) (Link to fonn) >< 2 a) All inerts (link to http://www.epa.gov/opprdOOl/inerts/), yes no 

including fragrances, approved for the proposed uses (see 

Footnote A) 

3 Certification with Respect to Citation of Data (EPA Fonn 8570-34) (Link to 

Y... [onn) completed and signed (N/A if 100% repack) 

Certificate and data matrix consistent 

If applicant is relying on data that are compensable, is the offer yes no 

to pay statement included. (see Footnote B) 

If is there a letter OLA "" 1 for ,use only. 

,'V' (N!'f . . Fonn ~J ,v-"!I(Link to fo?n) 

)( 4 completed and A 1 source IS unregIstere or owns the 

Data Matrix (EPA Fonn 8570-35) (Link to fonn) both internal and external 

copies (PR 98-5) (Link to PR 98-5) completed and signed (N/A if 100% >( 

5 yes _no ?t";' 

a) Selective Method (Fee I : use) 

b) Cite-All (Fee category experts use) fi!~~~{' . "',' .,. .. :\';''/ ....•• '. 

c) Applicant owns all data (Fee category experts use) Iff:'),':, 

" .,:- '::~' ".' --

5 Copies of Label Oink to httQ:llwww.eQa.gov/oQufeadl/labeling/lrm[) 

,~ 6 (Electronic labels on CD are encouraged and guidance is available)( link to 

http://www.epa.gov/pesticides/regulating/registering/submissions/index.htm#labels 

I ) 

I 
14

r~') 

.. ~') 

7 Is the data packa2e consistent with PR Notice 86-5 (link to PRN 86-5) X 

Notice of Filing (link to 

8 htto:llwww.ega.gov/[!esticides/regylatinvtolerance uetitions.htm) included 

with petitions (link to 

http://www.epa.l!ov/pesticides/regulatinl!itolerances.htm) + 

9 If applicable for conventional applications, reduced risk rationale (link to 

http://www.epa.gov/opprdOOllworkplauireducedrisk.htrnI) TRequired Data (link to 

http;//www.eg3.gov/l!esticideslregulatinf!!data reguirements.htm) and/or 

data waivers. See Footnote C. 

a) List study (or studies) not included with application 

10 

2 
15

, 

Comments: 

r -L ' Vv! ! n 

* N/A - Not Applicable 

Footnotes 

} (7,F 

\j -

~ - I (' , v 

A. During the 21 day initial content review, all CSFs will be reviewed to detennine 

whether all inerts listed, including fragrances, are approved for the proposed uses. If an 

unapproved inert is identified, the applicant must either 1) resolve the inert issue by, for 

example, removing the inert, substituting it with an approved inert, submitting 

documentation that EPA approved the inert for the proposed pesticidal uses, correcting 

mistakes on the esp, etc, or 2) provide the data to support opp approval of the inert or 3) 

withdraw the application. Removing or substituting an inert ingredient will require a new 

CSF and may require submission of data. All infonnation. forms. data and 

documentation resolving the inert issue must have been received by the Agency or the 

application withdrawn within the 21 day period, otherwise, the Agency will reject the 

application as described below. 

To successfully complete this aspect of the 21 day initial content screen, applicants are 

strongly encouraged to verify that all inert ingredients have been approved for the 

application's uses even if a product is currently registered by consulting the inert Web 

3 
16

, 

site [link to http://www.epa.gov/opprdOOl/inertsilists.html] and if the inert is not 

approved, to obtain the necessary inert approval prior to submitting an application 

to register a pesticide product containing that inert ingredient. Some inert 

ingredients are no longer approved for food uses or certain types of uses. The name 

and/or CAS number on a CSF must match the name and CAS number on this web site. 

Simple typographical errors in the name or CAS number have resulted in processing 

delays. 

If an inert is not listed on the inert ingredient web site and the applicant believes that the 

inert has been approved, the applicant should contact the Inert Ingredient Assessment 

Branch (IIAB) at inertsbranch@epa.govand resolve the issue. Copies of the 

correspondence with IIAB resolving the issue should accompany the application. All 

new inerts except PIP inerts are reviewed by IIAB. The lIAB should also be contacted 

for any questions on what supporting data needs to be submitted for and the Agency's 

inert review process. Questions on PIP inerts should be directed to the Chief of 

Microbial Pesticides Branch [Link to 

http://www.epa.gov/oppbppdllbiopesticidesicontactsbppd.htm]. 

When a brand, trade, or proprietary name ofan inert ingredient is listed on a CSF, 

additional information such as an alternate name of the inert, CAS number or other 

information [link to http://wW\V.epa.gov/opprdOOllinerts/tips.pdf] must also be included 

to enable the Agency to detennine ifit has been approved. Each component of an inert 

mixture (including a fragrance) must be identified. In some cases, the supplier of the 

mixture or fragrance may need to provide this information to the Agency. Prior to the 

Agency's receipt of an application, applicants must arrange with a proprietary mixture or 

fragrance supplier to provide the component information to the Agency or promptly upon 

EPA's request. If the inert ingredients in a proprietary blend (including fragrances) 

carmot or are not identified or provided within the 21-day content review period, the 

Agency will reject the application. 

During the 21 day content review, applicants should submit information to the individual 

identified by the Agency when the applicant is informed ofan unapproved inert. 

Unapproved Inerts Identified on CSFs 

All applications except conventional new products and PIPs 

Once an unapproved inert is identified on a CSF, the Agency will contact the 

applicant with the following options: 

1. Correct the application by, for instance, correcting the inert's identity or CAS 

number, providing documentation that the inert has been approved, or 

removing the unapproved inert from the CSF or replacing it with one that is 

approved for the application's uses; or 

2. Submit the information and data needed for the Agency to approve the 

unapproved inert. If this option is selected and implemented, the Agency may 

request an extension in the PRIA decision review timeframe to accommodate 

the inert review/approval process; 

4 
17

3. Withdraw the application (the Agency retains 25% of the full fee for the fee 

category estimated); or 

Ifnone of these options is selected and implemented by the applicant mthin the 

21 day content review period, the Agency will reject the application and retain 

25% of the full fee of the category identified. 

Conventional New Product Applications 

When the Registration Division identifies an unapproved inert on a CSF with an 

application for a new product that the applicant has not identified as requiring an 

inert approval (R311, R312 or R313), it will contact the applicant with the 

following options: 

1. Correct the application by, for instance, correcting the inert's identity or CAS 

number, providing documentation that the inert has been approved, or 

removing the unapproved inert from the CSF or replacing it with one that is 

approved for the application's uses;.or 

2. Submit the information and data needed for the Agency to approve the 

unapproved inert, including any required petition to establish or amend a 

tolerance or exemption from a tolerance. (This option may change the PRIA 

category for the application, which CQuld require a longer decision review 

time and a larger fee. If additional fees are due, they must be received by the 

Agency within the 21 day content review period.) 

3. Withdraw the application (the Agency retains 25% of the full fee for the fee 

category estimated); or 

If none of the above options is selected and implemented during the 2 I-day 

content-review period, the Agency will reject the application and retain 25% of 

the appropriate fee for the new product-inert approval category. 

PIP Applications 

When the Biopesticide and Pollution Prevention Division identifies an 

unapproved inert on a PIP CSF and a request to approve the inert does not 

accompany the application, it will contact the applicant with the following 

options: 

1. Correct the application by, for instance, correcting the spelling or name of the 

inert to that in 40 CFR 174, or providing documentation that the inert has been 

approved; or 

2. Submit the information and data needed for the Agency to approve the 

unapproved inert. If an inert ingredient tolerance exemption petition is 

required, the petition must be received by the Agency and the B903 fee paid 

within the 21 day period. If this option is selected and implemented, the 

Agency mIl discuss harmonizing the timeframe for both actions. 

5 
18

3. Withdraw the application (the Agency retains 25% of the full fee for the fee 

category estimated); or 

If none of the above options is selected and implemented during the 21 day 

content review period, the Agency will reject the application and retain 25% of 

the fee. 

B. A policy on documentation of offers to pay is still being developed, however, for a 

me-too or fast track (similar/identical) new product, R300 or AS30, an application 

without the necessary authorizations of offers to pay will be placed into either R301 or 

A531. The Agency recommends that authorizations of offers to pay be submitted with 

other PRIA applications to avoid delays in the Agency's decision. 

C. Biopesticide applicants are advised to contact the Agency and discuss study waivers 

prior to SUbmitting their application to the Agency. Documentation of such discussions 

should be submitted with the study waiver. 

6 
19

21-Day Screen Completed by 

Contractor 

21-Day Expires on r-/~-Io 

Jacket# gf:l;/l-~ 

MRID# ___ _ 

Content Scr en: Recommended to 

86-5 Review: Passed/FanedEA7 

Transfer This Jacket to: 
20
21

, ) . . 

NEW APPLICATIONS 

FILE NUMBER: -,eLZ¥.=d'?:.:...?~~<:.-:#-___ _ 

FEP COPPIN ENTRY) ~, pm ;4" //£) 

, 

(Initial & date) '. 

FILE ROOM: _____ _ 

(Initial & date) 

SIG: 

(Initial & date) 

FILE ROOM: _____ _ 

(Initial & date) 

-L ASSIGN TO PM --c-&.,--'/ _ (NO DATA) 

__ JACKET TO SHELF (DATA) 
22

) -) 

To the Document Center (ITRMD) 

*Please transfer jacket/mini-jacket to the ProdJJct Manager 

Team circled below: 

Minor Use Section: PM-5 

Insecticide Branch: PM-10 PM-13 

Herbicide Branch: PM-23 PM-25 

Fungicide Branch: PM-20 PM-21 PM-22 

InsectIRodent Branch: PM-7 

*Reminder to PM - If applicable, pick-up data from the 

Screening Room. 

Processed by RD's Completeness Check Team 

(Date) 
23

Tide International (USA) Inc. 

21 Hubble, Irvine, CA 92618, USA. Phone: 949-679~3S35 Fax: 949~679-3538 

December 28, 2009 

To Whom It May Concern: 

RE: letter of Authorization 

Dear Sir or Madam: 

Please let this letter serve to confirm that Janelle Kay and Michael Kellogg of Pyxis Regulatory 

Consulting, Inc. are authorized to act as agent for Tide International USA, Inc. (EPA Company Number 

84229), before the U,5. Environmental Protection Agency, California Department of Pesticide Regulation 

Pesticide Registration Branch and other state governmental agencies in all matters regarding our 

pesticide registrations pursuant to the Federal Insecticide, Fungicide and Rodenticide Act ("FIFRA"J, 7 

U.S.C. § 136 et seq. and state law. 

If you have any questions, please do not hesitate to contact me, 

Sincerely, 

9-~r- Der·1 Wang, Ph,D. 

Vice President 

cc: Pyxis Regulatory Consulting, Inc. 

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24
Page 25 - *Confidential Statement of Formula may be entitled to conf