existing formulation, further extensive testing is likely to be
required.
Active substances
Consideration should always be given to the impact on bio-
logical efficacy from changes in active substance(s) content.
Generally, these changes are associated with other signifi-
cant changes to the formulation chemical composition and
should therefore be supported by relevant efficacy data.
Some EPPO member countries provide specific guidance
describing
threshold
levels
in
the
individual
content
of
active substance(s), up to which it may be possible to sup-
port
changes
by
an
appropriate
reasoned
case.
4
These
thresholds are based on extensive national experience and
historical data. Guidance should always be sought from the
relevant regulatory authority.
Part I: General factors to be considered and
information required when a change in chemical
composition is proposed
It is essential to have information regarding the nature and
the magnitude of the proposed change. This should include
information on the chemical nature of the co-formulant(s)
being changed (in content, added or removed) and, if rele-
vant, an explanation of their chemical similarity. When
considering the potential impact of any change, information
on the function of formulation components is most impor-
tant, together with the reasons for making any changes.
This applies particularly to the surfactant system. For exam-
ple, the function may be to improve formulation stability in
the spray tank or improve plant coverage and uptake of
active substance in the plant.
It is also helpful to understand the use of the product and
how the active substance is delivered to the target. For for-
mulations that are diluted and sprayed on the crop and/or
weed this may be via uniform distribution on the leaf surface.
Therefore, effectiveness may be modified by changes in dis-
tribution and absorption on the leaf surface or by changing
the rate of release of the active substance. Crop safety may
be a key consideration, whether for a particular active sub-
stance or for sensitive plants (often horticultural) which are
more susceptible to developing phytotoxic symptoms.
This section details the criteria that determine the catego-
rization of the proposed changes in chemical composition.
It also provides a summary indication of the type of data
required to support the change, which is discussed in more
detail in Part II of this Standard.
Appendix 1 describes more specialized types of products
(or
situations
of
use)
where
different
factors
are
more
relevant. For example, for seed treatments the key issue is
retention of active substance on the seed, and this may be
addressed by reference to physical/chemical data; for baits,
addressing any potential changes in palatability may be the
main issue.
Changes in co-formulants which are not biologically signifi-
cant
For these changes, no efficacy data are required. However,
an explanation of the biological nonsignificance of any
changed co-formulants should be provided, making refer-
ence to relevant parts of Table 1. This should be an integral
part of a justification to explain why the proposed change
is deemed unlikely to impair efficacy.
Note that, as a general rule, it is the amount of active
substance and co-formulants applied to the target that is
important and not the content of the formulation itself, i.e.
the in-use diluted formulation.
It should be remembered that the impact of a series of
individually
nonsignificant
changes
may
be
cumulative.
Any
comparison
of
a
proposed
change
in
formulation
should always be made with the originally authorized for-
mulation. It is not appropriate to make a series of minor
changes, each without supporting data, with the final result
being
a
substantively
significant
change.
If
the
overall
changes (compared with the originally authorized and tested
formulation) are beyond those considered as nonsignificant,
then some data will be required to confirm that efficacy is
not adversely affected.
Changes that are nonsignificant for efficacy, where no
supporting data are required, are given below. The appli-
cant should notify and provide an appropriate explanation
of the nature of the change. For example, it is noted that
co-formulants
with
different Chemical
Abstracts
Service
(CAS) numbers may be chemically equivalent. Equally, for
compounds with identical
CAS numbers, the
degree of
ethoxylation can be significantly different. It is up to the
applicant to explain and justify function, properties and
why they are equivalent, and reference should also be made
to the chemistry assessment. Please also note that other cri-
teria are relevant for more specialized formulation types
and certain situations of use (see Appendix 1).
Changes in co-formulants which are biologically significant
Significant
changes
in
chemical
composition
are
those
regarded
as
potentially
having
some
biological
impact,
requiring
assessment
and
supporting
data.
Where
the
change is considered significant, data are required to con-
firm that the performance and crop safety of the proposed
change are comparable relative to the current formulation
composition.
For most formulations, and particularly foliar applied
sprays, the two key components that may affect efficacy are:
A change in the solvent system, i.e. moving from one sol-
vent to a chemically different solvent or significantly
changing the content of individual solvent(s). This may
4
For example, ranges up to
Æ
10% are commonly specified. Where
changes are being made simultaneously to more than one active sub-
stance, the cumulative changes should also be taken into account and
reference made to the original authorized product.
2
Efficacy evaluation
ª
2020 OEPP/EPPO,
Bulletin OEPP/EPPO Bulletin
0
, 1–7