ISLAMABAD: The Pakistan Crop Protection Association (PCPA) has raised alarm over what it calls systematic non-compliance and arbitrary practices at the Department of Plant Protection (DPP), Karachi, warning that the situation is crippling the country’s pesticide registration system and endangering Pakistan’s agricultural productivity.
In an urgent appeal to the Adviser and Director General of the DPP, the association accused registration officials of overruling binding decisions of the Agricultural Pesticides Technical Advisory Committee (APTAC) and statutory regulatory orders (SROs), while imposing subjective interpretations of the law. The PCPA said this regulatory paralysis had created a climate of uncertainty for agrochemical companies, discouraged investment in local formulation plants, and disrupted access to essential crop protection products for farmers.
As per the letter sent on August 16, 2025, the association pointed out several long-standing grievances, including excessive delays in processing applications despite Rule 4(8) of the Agricultural Pesticides Rules requiring disposal within 365 days. Instead, cases often linger far beyond a year, with applicants compelled to submit fresh Letters of Authorization (LoAs) and pay new fees even when delays are caused by the department. Products cleared by the 62nd APTAC meeting, after passing all required trials and recommendations, are still awaiting registration certificates without explanation. Registration files, including that of the product Schneider, have reportedly been misplaced at DPP. Even though duplicate and triplicate files exist, the department has refused to issue certificates, with applicants told that photocopies cannot be accepted.
Industry representatives also accused the DPP of imposing inconsistent and unjustified requirements, such as demanding eco-toxicity data for technical grade material, despite the rules restricting such requirements to formulated products. Similarly, registration officials reportedly refuse to accept manufacturing licenses as proof of production, instead insisting on registration certificates, a practice PCPA says is contrary to Rule 3 of the Agricultural Pesticides Rules, 1973.
The PCPA alleged that even after collecting registration fees under Form-16 and Form-17, the department is not processing the corresponding import permission cases. According to the association, this violates both the law and previous APTAC decisions, and has created a backlog that undermines the pesticide industry’s ability to supply essential products. It also noted that despite the 2014 amendment allowing technical grade material registration under Form-16—including for granules—the DPP has refused to process such cases, depriving local manufacturers of the ability to produce safer and modern formulations like WG, WDG, and SL.
The association emphasized that binding decisions of APTAC meetings and statutory provisions notified through SROs are being sidelined. For instance, APTAC decisions allowing mixture products under Form-17 have not been implemented. “Registration officials are unilaterally setting aside decisions of APTAC meetings and statutory instruments such as SRO 1017,” the association wrote. “This arbitrary enforcement contravenes Pakistan’s pesticide governance protocols and has brought the regulatory system to a standstill.”
The disruption, according to PCPA, is not just a bureaucratic matter but a direct threat to Pakistan’s agriculture sector. “The unjustified holds, lost files, and refusal to follow codified procedures are creating severe disruptions for pesticide companies,” it said. “This means delayed market access for safe and effective crop protection products, leaving farmers at risk of losing yields to pests.” The association added that the local pesticide industry has invested heavily in formulation plants to reduce reliance on imports, develop safer formulations, and even expand exports. “But instead of supporting these initiatives, regulatory hurdles are forcing industry players into uncertainty and financial losses,” the letter stated.
The PCPA has appealed directly to the Director General of the DPP to intervene, restore transparency, and ensure compliance with the established legal framework. “We urgently request your personal attention to enforce APTAC decisions and SRO provisions, expedite pending registrations, and reinstate rules-based procedures,” the letter said. The association stressed that it remained committed to constructive collaboration with DPP to uphold industry standards but warned that unless the deadlock was resolved, both the agrochemical industry and farmers across Pakistan would continue to suffer.
Insiders claim that the unwanted hurdles are created so the companies and applicants are forced to pay bribe for earlier processing of applications and registrations.
