When there is a change in the product formula without prior authorization, the pesticide registration is canceled. However, it is possible to appeal with the assistance of Bracci & Avila.
Article 22 of Decree 4.074 / 02 is expressed in stating that the registration of pesticide product will be canceled if an unauthorized change occurs. The cancellation occurs after a survey of the registering agency in the company.
Art. 22. The registration of agrochemicals, its components and the like will be canceled whenever it is verified modification by federal agencies of the agriculture, health and environment sectors in terms of formula, dose, manufacturing conditions, indication of application and specifications stated in the label and package leaflet, or other modifications not in accordance with the registration granted.
It is offered time to manifest itself by presenting the pertinent defense, assuring the right of the ample defense and contradictory as foreseen in the Article 5, paragraph LV of the Federal Constitution as foreseen in the Art. 2 of Law 9,784 / 99.
The cancellation occurs with the publication in the Official Gazette of the Union – DOU through an act. After the cancellation is still possible to present the defense with the objective of keeping the record suspended until the alleged change is regularized.
If you have had your registration canceled based on Art. 22 of Decree 4.074 / 02, consult us to have an adequate defense with a greater probability of success.
transfer of agricultural registration by incorporation, merger or cison
Bracci & Avila assists in the transfer of ownership of the product registration, dealing with the change and obtaining the necessary licenses.
In a globalized world, more and more companies have adopted more commercial strategies aimed at their permanence in the market. Among these strategies, there is the incorporation, when one company buys the other; the merger, when two companies become one, joining efforts for a common goal; and the split, when a company divides and forms another company.
It happens that whenever the registration of the agrochemical product is in the name of one company and needs to pass to another, we call transfer of ownership, as provided in the Art. 22 § 1 of Decree 4.074 / 02.
However, prior to filing for title transfer, we must change or obtain other licenses for the company that takes over the registration.
