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the HSNO Act. Because there were no transitional provisions for animal remedies in the HSNO Act, the notification under the Toxic Substances Act (NOTS) has been used as the legal mechanism to 'capture' a product as a legally recognised substance during the transitional period.

If an animal remedy was not notified to ERMA NZ it may not be a legally recognised substance. If you are in any doubt about whether or not your product is a legally recognised substance, contact ERMA NZ. 

If your product is a legally recognised substance in the HSNO transitional period, then the ACVM Group must notify ERMA NZ of an application to vary or update the registration, but approving the variation is not dependent on confirming a HSNO approval.

This means that there will be no delay in processing applications for legally recognised substances. However, applicants will be advised that they must be aware of their responsibilities under the HSNO Act and that they should check with ERMA NZ.

On 1 July 2002 pesticide products were deemed to be registered under the Agricultural Compounds and Veterinary Medicines Act 1997 with an expiry date of 1 July 2004. The pesticide products that are not agricultural compounds (i.e. home garden products, public health pesticides, industrial and household pesticides) were not affected by the Regulations. Registrants have already been advised to notify the ACVM Group whether or not they consider their products to be agricultural compounds.

All pesticides will still have registrations under the Pesticides Act. Pesticides that are also agricultural compounds will have both pesticide registrations and ACVM registrations. This is necessary because the transitional provisions in the HSNO Act use the pesticide registrations as the legal mechanism by which the products remain legally recognised in the HSNO transitional period. If the registrations were cancelled, the products would become illegal under the HSNO Act.

Therefore, agricultural compound pesticide products are now registered under the ACVM Act, but the registrations must be updated before 1 July 2004 or they will expire. In the meantime the products can be imported, manufactured, sold and used under the same conditions that applied to their pesticide registrations, using the existing approved label.

What is the procedure for updating a registration?

The procedure for updating the registration of pesticide products is the same as that described above for animal remedy products.

The advice on when to update a pesticide registration is the same as that described above for animal remedy products.

As for animal remedies, if you have lodged a product data sheet with the ACVM Group you can refer to it and confirm that all the information in it is still current rather than submit a new product data sheet.

In all cases there will be changes in the label content, even if it is only to change the reference from the Pesticides Act to the ACVM Act. It is anticipated that the new conditions will prompt label changes as well so reference to the existing label will probably be inappropriate.

From now on the ACVM Group would prefer to handle any request for a variation as a request to update a registration. However, you may have a specific need to make some changes without prompting an update of the registration. Applications for variation of a registration without updating the registration will be dealt with on a case by case basis after discussion with the applicant.

Provisional registrations and research approvals are not affected by the Regulations. Those regis-trations and approvals continue without change. The expiry date for provisional registrations will not be extended beyond 1 July 2004. Any registrations will have to be dealt with as provisional registrations under the ACVM Act.

There are relatively few pesticide products that have been issued an ACVM registration. These registrations are not affected by the regulations and the 1 July 2004 expiry date does not apply. The registrations are considered to be updated already, so no action needs to be taken to apply to update them.

As from 1 July 2002, the ACVM Fees Regulations 2002 came into force. This means a change in fees and charges. See the article on page 4 for a detailed explanation.