The "three certificates" for pesticides refer to the pesticide production license or production approval document, the pesticide standard, and the pesticide registration certificate. These three documents are issued on a product-specific basis, meaning that each individual pesticide product, even if it is the same type produced by different manufacturers, must have its own set of "three certificates."
**1. National Pesticide Production Licensing System**
Pesticides are fine chemical products that require specialized equipment, facilities, technical conditions, and quality management systems to ensure their safety and effectiveness. The state regulates the establishment of pesticide manufacturing enterprises, including joint ventures, branch factories, or non-pesticide companies setting up pesticide production workshops. These entities must first be reviewed and approved by provincial-level chemical industry authorities before submitting their applications to the State Council's chemical industry administrative department.
Once an enterprise is approved to produce pesticides according to national or industry standards, it must apply for a pesticide production license from the State Council's chemical industry authority. For pesticides without established national or industry standards but with internal company standards, the enterprise must submit an application for a production approval document after being reviewed by the provincial chemical industry administration.
No entity or individual is allowed to produce pesticides without a valid production license or approval document.
**2. Pesticide Standards**
Pesticide product quality standards are technical specifications and testing methods that define the acceptable quality of the product. These standards are legally recognized and universally applicable, often included in purchase contracts between manufacturers and users. They also serve as the basis for quality inspections by regulatory bodies and as reference points for quality disputes.
Standards are classified into international, national, and enterprise levels. International standards include those set by the FAO (Food and Agriculture Organization) and WHO (World Health Organization). National standards are developed by individual countries, while enterprise standards are created internally and approved by local technical supervision departments.
Enterprise standards are essential for the pilot testing, registration, and commercialization of new pesticides. However, they are only valid for the company that created them. Once a product reaches mass production and quality improves, industry standards may be established. When industry standards are adopted, all domestic manufacturers must comply, and the original enterprise standards are no longer valid.
National standards represent the highest level of quality in the country and are comparable to international standards. Each pesticide formulation must have a corresponding standard number; otherwise, it cannot be sold in the market.
**3. National Pesticide Registration System**
As high-tech chemical products, pesticides must meet strict quality requirements to ensure efficacy and prevent phytotoxicity. They are also toxic substances, so their production, distribution, and use must be carefully regulated to protect human health, animal welfare, and the environment.
To this end, China implements a pesticide registration system. All domestic production and imported pesticides must go through the registration process before being sold. Manufacturers must apply for registration with the national pesticide registration authority, and only after approval can they proceed with production and sale.
The pesticide registration system was introduced in the U.S. in 1947, and most countries worldwide have similar regulations. In China, the system began in 1982, when six ministries jointly issued the "Pesticide Registration Regulations," which took effect in October of the same year.
Under the 1997 "Regulations on the Management of Pesticides" issued by the State Council, the Ministry of Agriculture’s pesticide testing institute is responsible for nationwide pesticide registration, with assistance from provincial agricultural verification agencies.
The registration process for the first domestically produced or imported pesticide includes three stages:
- **Field Trial**: The developer applies for field trials, and the product cannot be sold during this phase.
- **Temporary Registration**: After successful field trials and demonstration tests (covering over 150 mu), the product may be temporarily registered for special use. Temporary registration lasts one year and can be renewed, but the total duration cannot exceed four years.
- **Formal Registration**: To be sold as a commercial product, the pesticide must undergo formal registration, which is valid for five years and can be renewed.
Each commercial pesticide product must have three numbers on its label — the "three certificates." Using incorrect or fake certificates is considered illegal and constitutes counterfeiting. If a product lacks proper "three certificates" or is manufactured without following the technical requirements outlined in them, it is considered substandard and may result in legal consequences for the manufacturer.
On April 7, 1995, the State Administration for Industry and Commerce and the Ministry of Agriculture jointly issued the "Measures for the Examination of Pesticide Advertisements," requiring the inclusion of the "three certificates" in all pesticide advertisements. Media outlets should also verify these certificates when reporting on pesticide products. When reporting on new pesticide developments, even if they do not yet have "three certificates," the stage of development should be clearly stated to avoid misleading the public into believing the product is already commercially available.
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