How to Complete and Submit EPA Form 8570-4: Confidential Statement of Formula

To complete EPA Form 8570-4, the Confidential Statement of Formula, you fill in 15 numbered fields identifying the registrant, the producing establishment, the product, and every active and inert ingredient with its supplier, quantity, weight percentage, and certified upper and lower limits, then have an authorized representative sign and date it. The form is a single page, but it demands precise data you should collect before you start writing anything on it.

When the CSF Is Required

A completed Form 8570-4 must accompany every application for new pesticide registration and every amended registration that involves a formula change.¹ Each alternate formulation of the same product needs its own separate CSF.² You also file an updated CSF whenever you switch an ingredient supplier or adjust concentrations outside your certified limits, even if the active ingredient itself stays the same.

The CSF is one piece of a larger application package. Under 40 CFR 152.50, a complete registration application also requires an application form, five copies of draft labeling, a data summary, product-specific study data, and certifications for child-resistant packaging when applicable.³ Filing the CSF alone does not register a product.

What to Gather Before You Open the Form

Most rejections trace back to information the applicant didn’t have ready. Collect all of the following before starting:

The full legal name and U.S. mailing address of the person or company holding (or applying for) the registration. Foreign applicants also need the name and address of their authorized U.S. agent.
The name, address, and EPA establishment number of every facility where the product will be manufactured. Every producing establishment must be registered with EPA and assigned a number before production begins. Contract manufacturers count, and you need their establishment number too.⁴
The exact brand name as it will appear on the label.
Your EPA registration number if the product is already registered, or the file symbol assigned to a pending application.
The name and team number of the EPA Product Manager assigned to your product, if one has been assigned.
Physical properties: weight per gallon for liquids, bulk density for powders and granulars, pH for water-soluble or water-dispersible products, and flash point or flame extension data for flammable or pressurized products.
A full ingredient breakdown. For every component, active and inert, you need the chemical name, trade name, CAS number, supplier name and address, the quantity introduced per batch, the weight percentage in the finished product, and the upper and lower certified limits drawn from your quality-control data.
Each active ingredient’s EPA registration number, if the ingredient itself is registered.

If you use an unregistered active ingredient, its supplier must separately submit chemical specifications and any data required under 40 CFR Part 158 to the EPA.¹

Filling In the Identification Fields (Columns 1–9)

The top of the form identifies who you are, where the product is made, and its basic physical properties. Download the blank form from the EPA’s pesticide registration forms page.⁵

Column 1, Applicant/Registrant. Your firm’s full legal name and mailing address. Foreign applicants add their authorized U.S. agent.

Column 2, Producer. The name and physical address of the site where the product is formulated. It must match an EPA-registered establishment.

Column 3, Product Name. The brand name exactly as it appears on the label and on your application form. Small discrepancies between the CSF and the label are one of the first things reviewers catch.

Column 4, Registration Number or File Symbol. The EPA registration number for an existing product, or the file symbol for a new application.

Column 5, EPA Product Manager or Team Number. Fill this in if you know who has been assigned. Leave it blank for a first-time application if no manager has been assigned yet.

Column 6, Country Where Formulated. The country where the product is actually mixed or manufactured.

Column 7, Weight per Gallon or Bulk Density. Pounds per gallon for liquids; bulk density for powders or granulars; weight per unit for tablets, briquettes, or other uniformly shaped products.

Column 8, pH. Enter the pH for aqueous formulations and for products that are dispersible or soluble in water. Write “N/A” if it doesn’t apply.

Column 9, Flash Point or Flame Extension. Required for pressurized products and anything known or suspected to be flammable. Include flame extension test results for pressurized products, including any positive flashback results.

These nine fields rarely cause rejections on their own. The exception is a mismatch between the product name here and the product name on the label or application form.¹

Filling In the Formula Fields (Columns 10–15)

The lower half of the form is the actual recipe, and it’s where most errors happen. Work through it methodically.

Column 10, Components in Formulation. List every component as it is actually introduced into the formulation. For each one, provide the product name, commonly accepted chemical name, trade name, and Chemical Abstracts Service (CAS) number. List active ingredients first, then inert ingredients.

Column 11, Supplier Name and Address. The name and address of the supplier for each component.

Column 12, EPA Reg. No. The EPA registration number for each active ingredient, if one exists.

Column 13, Amount and Percent by Weight. Column 13 has two sub-fields. In 13a, enter the quantity of each component as actually introduced into the formulation (the batch amount). In 13b, enter the weight percentage of that component in the finished product.

Column 14, Certified Limits. Also two sub-fields. Column 14a is the upper limit, the maximum percentage of each active ingredient and each intentionally added inert ingredient. Column 14b is the lower limit, the minimum percentage. Base these limits on representative sampling and chemical analysis from your quality-control process, not theoretical calculations.

Column 15, Purpose in Formulation. State what each ingredient does: herbicide, synergist, surfactant, defoamer, sequestrant, and so on. This applies to both active and inert ingredients.

The weight percentages in Column 13b must add up to exactly 100 percent. Any discrepancy will prompt a deficiency notice. Check that your certified limits in Column 14 are realistic ranges drawn from actual production data. Limits set too tight invite violations when normal batch-to-batch variation occurs; limits set too wide may raise questions during review.¹

Signing the Form

An authorized representative of the registrant must sign and date the form, certifying that everything on it is true and accurate. The EPA flagged unsigned documents as a recurring problem in its analysis of common submission errors.⁶ Confirm the signer has authority to bind the company. Submitting false information on a CSF violates 18 U.S.C. § 1001 and can trigger enforcement action under FIFRA Sections 12 and 14.

Submitting the Completed Form

The CSF goes in as part of your complete registration application package, not as a standalone document. Two paths are available.

Electronic Submission Through the Pesticide Submission Portal

The EPA’s preferred method is electronic filing through the Pesticide Submission Portal (PSP), accessed through the Central Data Exchange (CDX) at cdx.epa.gov.⁷ You need a CDX account before you can use the portal. Once registered, add PSP to your account and build the submission package.⁸

Within PSP, documents attach at two levels. Package-level documents cover the whole submission: payment receipts, cover letters, transmittal documents. Application-level documents support a specific product: forms like the CSF, draft labels, supporting studies. At least one document must be attached at each level. PSP does not accept empty files, duplicate file names, or executable (.exe) files, and file names are capped at 200 characters.

Mail or Courier Delivery

A physical package goes to the Document Processing Desk at the Office of Pesticide Programs.⁹

For regular mail:
Document Processing Desk
Office of Pesticide Programs (7504P)
U.S. Environmental Protection Agency
1200 Pennsylvania Ave. NW
Washington, D.C. 20460

For courier deliveries:
Office of Pesticide Programs
One Potomac Yard
2777 S. Crystal Drive
Arlington, VA 22202

Physical submissions have to meet the EPA’s binding and formatting requirements; applications have been rejected for failing them. Electronic submissions through PSP offer faster acknowledgment of receipt and easier tracking.

Mistakes That Get CSFs Kicked Back

The EPA has identified several problems that recur across pesticide registration submissions:⁶

Weight percentages in Column 13b that do not total 100 percent.
The product name on the CSF not matching the label or the application form.
Missing forms in the package: the Certification of Data Compensation statement, Formulator’s Exemption statement, and Data Matrix Form are frequently left out.
A CBI statement that doesn’t follow the EPA’s formatting requirements.
A missing or incomplete Good Laboratory Practice Standards compliance statement on submitted studies.
Unsigned documents, including the CSF itself.
Data Matrix errors, such as incorrect MRID numbers or missing generic or product-specific data.
Improperly bound or formatted physical data submissions.

Any deficiency identified during the EPA’s initial content screen that you fail to correct can result in rejection, and the EPA keeps 25 percent of your PRIA fee even on rejected or withdrawn applications. Getting it right the first time saves money and months of delay.

Keeping the CSF Current After Registration

A registered CSF is not a one-time filing. You must submit an updated form whenever you change an ingredient supplier, adjust concentrations, add or remove a component, or modify the manufacturing process in a way that affects the formula. These amendments follow the same submission path, through PSP or by mail, and go through their own review. If EPA testing reveals that your product’s actual composition differs from the formula on file, the product may be considered misbranded under FIFRA Section 2(q)(1)(A), and the agency can issue a Stop Sale, Use, or Removal Order under FIFRA Section 13(a).¹⁰ Every number on the CSF has to match what is actually going into the product on the manufacturing floor.

1
U.S. Environmental Protection Agency. EPA Form 8570-4 – Confidential Statement of Formula
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US EPA. Tips for Avoiding Confidential Statement of Formula or Product Chemistry Issues
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eCFR. 40 CFR 152.50
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eCFR. 40 CFR Part 167 – Registration of Pesticide and Active Ingredient Producing Establishments
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Environmental Protection Agency. Pesticide Registration Manual: Blank Forms
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US EPA. Pesticide Registration Manual: Chapter 2 – Registering a Pesticide Product
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US EPA. Central Data Exchange
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US EPA. Pesticide Submissions Portal (PSP) Frequently Asked Questions
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US EPA. Completing and Submitting Pesticide Registration Forms
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US EPA. Stop Sale, Use, or Removal and Modification of the Order Issued to sBioMed, LLC