The provision is aimed at addressing the problem of citizen lawsuits that have added nothing to the actual protection of threatened and endangered species while tying up the court system and funneling millions of dollars in legal fees to plaintiffs’ attorneys.

“Real world experience suggests” this protection is being provided by EPA under FIFRA, CLA said.

FARRM also includes the following notable regulatory reform provisions: Regulatory Clarification for Imported Seed, Title 10, "Section 10014. Seed Not Pesticide or Device for Purpose of Importation."

“American farmers must have timely access to sufficient quantities of seed each planting season,” CLA said. “Seed produced in South America in the winter is delivered just-in-time for spring planting in the US. Any duplicative regulatory import requirements could delay planting.”


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This provision would amend FIFRA to clarify the roles of EPA and the US Department of Agriculture to ensure that unnecessary paperwork does not disrupt an adequate domestic seed supply, but does not change any other existing regulations or requirements for seed or pesticides.

All seeds are regulated by USDA. All imported seed must be accompanied by the appropriate forms required by Customs and Border Protection and USDA, allowing for electronic tracking of the shipments. EPA requires a Notice of Arrival (NOA) for all pesticides that enter the US. But, EPA officials have refused to allow entry of some seed shipments unless a separate Notice of Arrival form is presented to CBP. This duplicative, unnecessary paperwork threatens timely seed shipments, and is not appropriate or needed for seed, as it is designed for imports of commercial pesticides. The sheer volume of seasonal seed imports can quickly overwhelm the antiquated, NOA process. Even brief delays can result in delayed deliveries and plantings, and reduced yield for farmers.


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