Overview
On December 31, 2025, the US Environmental Protection Agency (EPA) released for public comment proposed updates to Pesticide Registration Notice (PRN) 98-10,“Notifications, Non-Notifications and Minor Formulation Amendments.” The draft guidance was announced in the Federal Register on January 5, 2026, 91 Fed. Reg. 271 (Jan. 5, 2026), and reflects EPA’s effort to modernize and streamline procedures for certain registration changes that do not raise substantive use, safety, or risk concerns or otherwise require extensive Agency review.
The proposed guidance—identified as Proposed PR Notice 2025-XX; Draft Guidance for Pesticide Registrants on Notifications, Non-Notifications, and Minor Formulation Amendments—would, when finalized, supersede PRN 98-10 in its entirety. In addition, the draft would supersede contrary guidance in section II of PRN 2000-5 by allowing certain additions, modifications, or deletions of mandatory or advisory labeling statements to be submitted by notification or non-notification rather than by formal amendment. EPA states that these changes align with Pillar 1 (“Clean Air, Land, and Water for Every American”) and Pillar 3 (“Permitting Reform”) of Administrator Zeldin’s Powering the Great American Comeback initiative.
The draft PRN provides updated guidance to pesticide registrants and applicants regarding the scope and processing of notifications, non-notifications, and minor formulation amendments. EPA explains that the proposal clarifies which registration changes qualify for streamlined review, expands the list of minor modifications eligible for these pathways, and shifts certain existing changes into less burdensome processes—such as moving some actions from notification to non-notification—without altering review procedures related to environmental or human health protections.
Among the notable changes proposed, EPA adds several new minor modifications and provides more detailed descriptions to enhance clarity. For example, the draft guidance would allow registrants to add placeholder text for certain symbols, pictures, logos, and graphics—such as distributor product logos—through notification and then add the actual graphics later through non-notification, once the placeholder appears on the stamped EPA master label. EPA believes that these updates will reduce the burden associated with completing, submitting, and processing applications for both registrants and the Agency while maintaining appropriate regulatory oversight.
EPA has specifically requested public comment on several aspects of the draft guidance, including the following: updated requirements for symbols, pictures, logos, and graphics or placeholder text; the use of placeholders for state-required fertilizer restrictions; certain label revisions for 100-percent repack registrations; the addition of referral statements and marketing claims; changes to sources of certain inert/other ingredients; the addition of certain packaging graphics and statements; changes in state registration status and warranty statements; and proposed adjustments to certain Endangered Species Act-related labeling language that would allow to be made by non-notification. EPA published a Summary Table of Significant Changes between PR Notice 98-10 and Proposed PR Notice 2025-XX to highlight significant proposed changes to existing PRN 98-10.
EPA emphasizes that PRNs are intended to provide guidance rather than impose binding legal requirements. While statutory and regulatory requirements remain legally enforceable, the draft PRN, if finalized, would not be binding on either EPA or pesticide registrants. EPA may depart from the guidance where circumstances warrant, and registrants may assert that the guidance is not appropriate generally or not applicable to a particular product or situation.
EPA is now accepting public comments, which are due to the Agency by February 19, 2026. This action may be of particular interest to companies seeking to amend pesticide registrations or streamline labeling and formulation changes for pesticide products. If your company is considering submitting comments or evaluating the implications of the proposed new guidance, experienced regulatory professionals at Steptoe are available to assist in assessing impacts and preparing comments.
