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Licence and registration transfer project

With the commencement of the ACVM Act all animal remedy licences and pesticide registrations must be converted to ACVM registrations unless either:

• the trade name product is not an agricultural compound under the new Act (e.g. household pesticides, home gardening products, etc); or
• the trade name product fits the definition of an agricultural compound that is exempt from the requirement to be registered.

Transition period

The transition period lasts for three years from the commencement of the ACVM Act. By the end of that period the transfers must have been  com-pleted. At that time it will be illegal to import, manufacture, sell or use a trade name product that requires registration that has not received its new ACVM registration.

In the mean time, products that are presently licensed or registered will remain so until they are transferred. They will be regulated under the provisions of the Animal Remedies and Pesticides Acts, respectively.

Hazardous substance?

If a trade name product is not a hazardous substance the ACVM Group will issue its new registration. However, new registrations will not be issued for trade name products that are also hazardous substances (or where the hazardous status is uncer-tain) until the ACVM Group is advised that either:

• an ERMA approval has been issued; or
• an ERMA approval is not required.

The ACVM Group is working with ERMA NZ to clarify the rules that it should use to identify what is not a hazardous substance. The ACVM Group will make these rules public as soon as they are finalised, so licensees or registrants can see whether ERMA approvals are necessary for their products before an ACVM registra-tion can be issued.

Exempt products

As stated above some trade name products may not have to be regis-tered under the ACVM Act (see page 5 on exempt agricultural compounds).

Pesticides

All agricultural compound pesticides  will have to be registered. They will all be hazardous substances as well, so they will need ERMA approvals. Pesticides that will not be agricultural compounds (see page 7 ) will not have to be registered under the ACVM Act, but they will need ERMA approvals.

Vertebrate pest control products

The ACVM Group has not seen the controls ERMA NZ will impose on vertebrate pest control products. If they are insufficient to:

• manage the risks to animal welfare;
• prevent residues that breach New Zealand residue limit standards; and
• manage the risks to trade in primary product (e.g. violative residues in export game meat),

then MAF will ensure that they are defined as agricultural compounds and will require them to be registered under the ACVM Act.

Prescription animal remedies

All prescription animal remedies will have to be registered. Almost all will retain their present PAR classifica-tions. However, a few classifications may change when the PAR criteria listed on page 5 are applied.

Over-the-counter products

A number of over-the-counter animal remedies may be exempt from regis-tration. A few, such as over-the-counter antibiotic trade name prod-ucts, may be made prescription animal remedies. Information on oral nutri-tional compounds is provided on page 8.

Transfer request

The transfer of a trade name product will commence on receipt of a transfer request containing the information described on page 3. Because the conversion of licences and registra-tions must be done by Regulations (section 88 of the ACVM Act), the actual time available for processing registrations is approximately two years. Consequently, it is important that licensees or registrants start the transfer of their products as soon as possible.

The rules the ACVM Group will apply  in determining the class of a trade name product can be found as an information sheet on the ACVM Group website ( www.maf.govt.nz/acvm/  ). If you are uncertain about the classification of your product(s) you can ask for a class determination from the ACVM Group.

EXTRA ISSUE

To inform readers who have many questions relating to implementation of the ACVM Act, an extra issue of AgVetLink will be published next month.

Meanwhile, keep checking the website ( www.maf.govt.nz/acvm ) for updates.