In comments submitted to the Environmental Protection Agency (EPA) this week, AHPA continued to encourage the agency to expand its use of its crop grouping regulations by including more botanical commodities in two proposed new crop groups to help ensure that all of the minor crop botanical commodities marketed in the U.S. are covered by federal regulations.
On August 27, 2019, EPA issued a Federal Register notice announcing a proposal to separate the current Crop Group 19 (which includes both herbs and spices) into two new crop groups: Crop Group 25: Herb Group; and Crop Group 26: Spice Group. The August 27 Notice states that, once final, these revisions will increase the utility and benefit of the crop grouping system for producers and other stakeholders involved in commercial agriculture.
AHPA again advocated EPA to add hundreds of commercially available herbs and spices to the recently proposed crop groups because it is essential to ensure companies can comply with EPA's pest control regulations. AHPA advocated EPA add numerous botanicals that it did not include from a previous AHPA submittal, as well as a large number of additional botanicals more recently identified by AHPA members.
EPA has long expressed a position that crop grouping has significant benefits for numerous stakeholders, including producers of minor crops. AHPA has also noted that virtually all herbs, spices and other botanicals are minor crops, such that AHPA’s members have particular interest in the benefits that are expected by creation of proposed new Crop Group 25 and proposed new Crop Group 26.
AHPA's letter also notes that EPA has previously concluded that the lower crop registration costs associated with expanded crop groups will encourage more herbs and spices to be registered, providing additional tools for pest control.
"Adding new crops to a crop group reduces mandatory paperwork requirements and results in no appreciable costs or negative impacts to consumers, minor crop producers, pesticide registrants, the environment, or human health," said AHPA President Michael McGuffin. "AHPA members rely on the availability of raw agricultural commodities that are not contaminated with excessive levels of environmental pollutants. This requires that clean air, water, and soil be available for the production of food crops."