The permit-to-label project was initiated to improve access to agricultural and veterinary (agvet) chemical products by migrating uses from current Australian Pesticides and Veterinary Medicines Authority (APVMA) permits to a registered product label. This initiative aimed to provide greater certainty to industry through registration of eligible use patterns, removing the need for industry to periodically apply to the APVMA for renewal of permits.
Since commencement of the project in 2015, the APVMA has sent over 1,300 invitation letters to product registrants, offering discounted registration of uses from 203 permits and covering 64 active constituents. The APVMA received 257 applications to add eligible uses to product labels during the reduced fee period.
This page contains information on the APVMA permit scheme, a report on the permit-to-label project scope, and outcomes. The project was closed at the end of 2023; however, the APVMA intends to transition the permit-to-label project to business-as-usual work.
Permit-to-label outcomes to date are published on our website. Applicants can still apply for ‘permit-to-label uses’ if the elapsed invitation remains relevant for your product. The period of discounted registration will only be available for active permit-to-label invitations. Please note the discounted fee will not be applicable if the invitation period has expired.
APVMA permit scheme
The small size of some agricultural industries means the costs associated with registering an agvet chemical product for use in that industry is not feasible for product registrants. This means smaller industries may have limited access to registered agvet chemical products for the management of pests and diseases. Larger industries face a similar problem when managing uncommon or emerging pests and diseases.
The APVMA permit scheme provides a mechanism whereby industry can apply for a permit to legalise off-label use of agvet chemical products for use in these ‘minor use’ situations. Permits are issued for a limited duration, and permit holders must apply periodically to the APVMA to have their permits renewed.
Original scope of the permit-to-label project
The APVMA permit-to-label project was funded by the then Department of Agriculture’s Improved access to agricultural and veterinary chemicals program.
The APVMA completed scoping of permits for inclusion in the permit-to-label project in September 2017. Criteria for a permit to be included in the project included the following requirements:
- Permit is current (generally no expired permits)
- Primary industry use pattern on crops or livestock species, turf and forestry (generally no environmental weeds, rights of way, rodenticides, or research permits)
- An eligible registered product to which the use pattern can be transferred
- No (or little) further data are likely to be required for the efficacy, safety and trade criteria to be satisfied
Once identified as within scope, each permit was progressed through the following process:
- Phase 1 – Screen all current permits as in/out of scope
- Industry/states/territories were consulted on which permits should be progressed to label
- Phase 2 – Detailed assessment of in-scope permits
- Risk assessment of uses to determine the suitability of the permits for transferring to product labels
- Phase 3 – Consult with registrants, permit holders and state/territory regulators
- Phase 4 – Assess responses received
- Phase 5 – Migrate uses onto label
- Product registrants are invited to add uses from eligible permits to their product label (registration) at a discounted fee during the invitation period
- Product registrants submit a registration application to add the nominated use to their product label
- Permit lapses, or the permit holder requests cancellation of the permit. If a risk is identified during the risk assessment current permits may require cancellation prior to the use being transferred to an approved label with statements appropriate for risk mitigation
- Phase 6 – Progress reports
- Phase 7 – Final report