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Guidance for the Office of Pesticide Program’s Pilot Fragrance Notification 

Program

This document provides guidance for EPA’s Office of Pesticide Programs (OPP) Pilot 

Fragrance Notification Program (PFNP) for registrants seeking to add new or modify existing 

fragrances in new or currently registered pesticide products. The Pilot will be conducted for two 

years starting on September 19, 2011. The PFNP is a process improvement effort to streamline 

the current process used to amend registrations when fragrance ingredients are added, removed, 

or modified. This guidance document includes the eligibility criteria for participation, 

submission requirements and submission instructions. Certification forms and the audit 

procedure are also included.

I. Eligibility for Participation in the Pilot Fragrance Notification Program 

Registrants seeking to add or modify fragrances in new or currently registered products

have the option of using the OPP Pilot Fragrance Notification Program. Participation in the OPP 

Pilot Fragrance Notification Program is subject to the following requirements and limitations:

1) Registrants must certify (see Attachment 1) that all fragrance component ingredients 

in the newly-proposed fragrance are included on the Fragrance Ingredient List (FIL)

http://www.epa.gov/opprd001/inerts/fmaingredient.pdf. 

2) The concentration of the fragrance being added or changed must not exceed 1.0% (by 

weight) of the total pesticide product composition.

3) Individual fragrance component ingredients that would exceed 0.1% (by weight) of 

the total pesticide product composition must have existing approval for use as 

pesticide product inert ingredients. 

4) Fragrance actions involving pesticide products that are insect repellents or baits are 

not eligible for the OPP Pilot Fragrance Notification Program. Also, antimicrobial

aerosol products that make public health claims are not eligible because confirmatory 

efficacy data are required to support any change in an antimicrobial aerosol product 

formulation intended to control public health microorganisms. 

5) This notification program is for non-food use pesticide products only. Food-use 

products are ineligible.

6) Requests for inclusion of individual fragrance ingredients that are not on the FIL

should be submitted directly to the Inert Ingredient Assessment Branch in the 

Registration Division for evaluation and a determination of appropriateness for 

inclusion on the FIL. 
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7) Newly proposed fragrances that contain ingredients not listed on the FIL are not 

eligible for the OPP Pilot Fragrance Notification Program. All ingredients of a 

fragrance must be listed on the FIL and/or approved by the Agency before a 

notification or amendment can be submitted for that fragrance under the Pilot

Fragrance Notification Program.

8) It is the responsibility of the registrant to contact the fragrance supplier to ensure that 

the fragrance composition is submitted to the Agency. The fragrance composition 

consists of the complete listing of all components that make up the fragrance. The 

approved identity of new fragrances is to be submitted to the Agency as outlined in 

Section II (B) below.

9) OPP will audit the program yearly. As part of this process, OPP will use composition 

data for a random sampling of the new fragrances.

 

II. Pilot Fragrance Notification Program Requirements

A. Registrants filing a Fragrance Notification are required to submit the following:

1. EPA Form 8570-1 identifying the submission as an addition of a fragrance or identifying 

new or modified fragrances eligible for the Pilot Fragrance Notification Program. The 

form is available at www.epa.gov/opprd001/forms.

2. Fragrance Supplier Certification Letter (See Attachments I and II) certifying that all 

fragrance ingredients in the newly proposed fragrance are on the FIL.

3. Confidential Statement of Formula (CSF). The form is available at 

www.epa.gov/opprd001/forms.

B. The fragrance supplier agrees to submit the composition of approved fragrances annually to 

the Inert Ingredient Assessment Branch in the Registration Division of the Office of Pesticide 

Programs within the following time frames: 1) for new fragrances approved by EPA by June 

30th, the fragrance supplier must submit the composition of that approved fragrance to the 

Agency by December 31st of the same calendar year; and 2) for new fragrances approved by 

EPA between July 1st and December 31st, the fragrance supplier must submit the composition 

of the approved fragrance to the Agency by June 30th of the following calendar year. 
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III. Submission instructions

1. Registrants submitting the information identified above for Fragrance Notifications

should follow the instructions for submitting various types of applications to OPP found 

in Pesticide Registration (PR) Notice 2006-1, April 12, 2006, entitled “New Instructions 

for Transmitting Information to the Office of Pesticide Programs”. 

www.epa.gov/PR_Notices/. Submissions would be sent to:

Document Processing Desk (Code ______ )

Office of Pesticide Programs (7504P) 

U. S. Environmental Protection Agency 

1200 Pennsylvania Avenue, N.W. 

Washington, DC 20460 

Submissions via Hand Delivery or Courier Delivery: Deliveries by you or a commercial 

courier should be directed to: 

Document Processing Desk (Code ______ )

Office of Pesticide Programs (7504P) 

U. S. Environmental Protection Agency 

Room S-4900, One Potomac Yard 

2777 South Crystal Drive 

Arlington, VA 22202-4501 

2. The fragrance supplier or registrant is responsible for ensuring that the information 

related to the fragrance identity is submitted to the Agency for delivery to the Inert 

Ingredient Assessment Branch in the Registration Division. This information should be 

titled as “Fragrance Identity” and submitted by hard copy or in an excel format on a CD.

Submissions should be sent to:

Document Processing Desk (Code ______ )

Office of Pesticide Programs (7504P) 

U. S. Environmental Protection Agency 

1200 Pennsylvania Avenue, N.W. 

Washington, DC 20460 

Submissions via Hand Delivery or Courier Delivery: Deliveries by you or a commercial 

courier should be directed to: 

Document Processing Desk (Code ______ )

Office of Pesticide Programs (7504P) 

U. S. Environmental Protection Agency 

Room S-4900, One Potomac Yard 

2777 South Crystal Drive 

Arlington, VA 22202-4501 
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IV. Contact Information

For information regarding the Fragrance Ingredient List (FIL) contact:

Prakashchandra Shah

Inert Ingredient Assessment Branch (IIAB)

USEPA/OCSPP/OPP, Registration Division

Shah.pv@epa.gov

703-308-1846

For information regarding the OPP Pilot Fragrance Notification Program, contact:

Dennis Edwards

Chief, Regulatory Management Branch I

USEPA/OCSPP/OPP, Antimicrobials Division

Edwards.dennis@epa.gov

703-308-8087
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ATTACHMENT I

Certification for the OPP Pilot Fragrance Notification Program

Version I: For use when the fragrance supplier knows the fragrance identities 

and the registrant does not

(Basic Product Name)

EPA Reg. No.

Statement of Fragrance Supplier

On behalf of [name of fragrance supplier], I certify that all of the ingredients found in fragrance 

formula ________to be used in EPA Reg. No.______ are listed in the Fragrance Ingredient List 

(FIL) at http://www.epa.gov/opprd001/inerts/fmaingredient.pdf and meet the other requirements 

of the Pilot Fragrance Notification Program. I understand that it is a violation of 18 U.S.C. §

1001 to willfully make any false statement in this letter. I agree

(1) to maintain records documenting the identities of the fragrances in this formula for a 

period of 5 years after I cease selling this formula to [name of registrant] and to provide this 

documentation to the U.S. Environmental Protection Agency (EPA) upon request, 

(2) to notify EPA and [name of registrant] if fragrance formula ________ changes in a 

manner that makes the formula ineligible for the Pilot Fragrance Notification Program and 

(3) to certify that the composition of new fragrances will be submitted annually. 

I understand that the registrant will contact the fragrance suppliers to ensure that the submissions 

are made to the Agency.

____________________________ _________________

Signature, Fragrance Supplier Date

(Name, Fragrance Supplier, Address, Phone)
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Statement of Registrant

As the registrant of EPA Reg. No.______, I am aware that it is my responsibility to ensure that 

(1) this product meets the terms of the OPP Pilot Fragrance Notification Program and 

(2) EPA has access to complete and accurate formulation information for the pesticide. 

I acknowledge that if this product does not meet the terms of the OPP Pilot Fragrance 

Notification Program, including the requirement that all fragrance ingredients are on the FIL, 

then the sale or distribution of this product may be in violation of FIFRA and I may be subject to 

enforcement action and penalties under Sections 12 and 14 of FIFRA.

____________________________ __________________

Signature, Registrant Company Date

(Registrant Name)

(Registrant Address)

(Registrant city, state, zip code)
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ATTACHMENT II

Certification Letter 

for the OPP Pilot Fragrance Notification Program

Version II: for use when the registrant knows the fragrance identities

(Basic Product Name)

EPA Reg. No.

On behalf of [name of registrant], I certify that all of the fragrances in EPA Reg. No._____ are 

listed in the Fragrance Ingredient List (FIL) at

http://www.epa.gov/opprd001/inerts/fmaingredient.pdf and meet the other requirements of the 

OPP Pilot Fragrance Notification Program. I understand that it is a violation of 18 U.S.C. §1001 

to willfully make any false statement in this certification. I further understand that if this product

is not consistent with the terms of the OPP Pilot Fragrance Notification Program, 40 CFR 

152.46, including the requirement that all fragrance ingredients are on the FIL, then the sale or 

distribution of this product may be in violation of FIFRA and I may be subject to enforcement 

action and penalties under Sections 12 and 14 of FIFRA. 

____________________________ __________________

Signature, Registrant Company Date

(Registrant Name)

(Registrant Address)

(Registrant city, state, zip code)
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ATTACHMENT III

Fragrance Supplier Audit Procedure 

for the OPP Pilot Fragrance Notification Program

Recordkeeping /Audit Procedure

The recordkeeping obligations and the audit procedure are required elements of the 

OPP Pilot Fragrance Notification Program. Failure to comply with these voluntary 

Program elements means that any changes in fragrances from the most recent 

Confidential Statement of Formula filed with EPA require approval from the Agency. 

Sale or distribution of a formulation whose fragrances have neither been approved by 

EPA nor qualify for the OPP Pilot Fragrance Notification Program may result in 

enforcement action and penalties under Sections 12 and 14 of FIFRA.

The OPP Pilot Fragrance Notification Program recordkeeping and audit procedures are as 

follows:

1) Certification Statement/Fines & Penalties: In lieu of submitting composition data for 

each fragrance, registrants may sign and submit the “Fragrance Supplier Certification 

Letter” (attached) or ensure that the fragrance supplier does so. A false statement on the 

certification letter may violate 18 U.S.C. § 1001

2) Recordkeeping Requirements: The fragrance supplier and/or registrant will maintain a 

record of the composition data for each fragrance in a registered pesticide product and

agrees to make such records available upon request by EPA (Note: OPP uses a similar 

model for efficacy data for non-public health pesticides).

3) Audit Procedure: EPA, at its discretion, may conduct periodic audits of such records 

by requesting that composition data for a portion of the new fragrances registered by 

notification.