The Ministry of Agriculture and Farmers Welfare placed the Draft Pesticides Management Bill, 2025 in the public domain on 7 January 2026, inviting comments from stakeholders by 4^th February 2026. The draft Bill proposes to replace the Insecticides Act, 1968 and the Insecticides Rules, 1971. CropLife India filed its consolidated submission with the Ministry on 3 February 2026. CropLife India summarises the key recommendations made in that submission.

Protection of Regulatory Data

The submission notes that the draft Bill does not provide for protection of the extensive safety, efficacy, residue and environmental data generated for the registration of a new pesticide. CropLife India has recommended a limited, time-bound Regulatory Data Protection framework of about five years from the date of first registration for new molecules and new uses. During this period, subsequent applicants would not be able to rely on the originator’s data without consent or generation of independent data.

Confidential business information

Recommended inclusion of appropriate safeguards for confidential business information submitted to the regulator as part of registration dossiers, while maintaining applicable transparency requirements under law.

Regulation of online and e-commerce sale of pesticides

The submission flags that the draft Bill does not contain specific provisions regulating the sale of pesticides through e-commerce platforms and online marketplaces. CropLife India has recommended explicit statutory obligations on platforms, including verification of licensed sellers and valid Principal Certificates, product traceability, territorial compliance, maintenance of digital transaction records and notice-and-takedown responsibilities. A dedicated chapter on regulation of e-commerce has been proposed for inclusion in the Bill.

Offences by companies and nomination of responsible persons

Recommended that where a company has multiple manufacturing facilities, storage, branches or units, only the nominated person in-charge of the specific facility, storage, branch or unit be liable for an alleged contravention at that location. The submission cites the precedent under Section 66 of the Food Safety and Standards Act, 2006, which provides for such nomination at the time of licensing.

Decriminalisation framework and Schedule II offences

Recommended that the framework clearly distinguish between minor procedural lapses and wilful violations, that a statutory rectification mechanism be provided for minor non-compliances prior to penalty, and that the scope of scheduled offences be reviewed to ensure proportionality. The submission has also recommended that the quantum of penalties be fixed by the statute itself and not modified through executive action alone.

Emergency prohibition provisions (Section 34)

The draft Bill permits provisional prohibition of a pesticide for up to one year, extendable by a further 180 days, with restrictions continuing until the Registration Committee arrives at a final decision. CropLife India has recommended a shorter and time-bound emergency period of 60 to 120 days, followed by mandatory scientific review under the structured process already provided for in the Bill. The submission notes that under Section 27 of the Insecticides Act, 1968, emergency prohibitions were limited to 60 days, extendable to another maximum of 30 days.

Scientific basis for review, restriction or prohibition

Recommended that decisions concerning review, restriction or prohibition of a pesticide remain anchored in a structured scientific evaluation process, supported by expert inputs and defined timelines.

Independent expert review of molecule-level decisions

Recommended that molecule-level review decisions, which affect all existing registrations of a product, be supported by an independent expert committee constituted by the Central Government, with the committee’s technical report forming the basis of the final regulatory decision.

Statutory safeguards on sampling, testing and chain of custody

Recommended that core safeguards relating to sampling procedure, chain of custody, timelines and re-testing be incorporated within the Act itself, rather than left only to subordinate Rules, given that laboratory reports often carry conclusive evidentiary value in enforcement and prosecution.

Qualifications of Licensing Officers, Pesticide Inspectors and Pesticide Analysts

The draft Bill permits each State Government to prescribe the qualifications, and in some cases the powers and functions, of Licensing Officers, Pesticide Inspectors and Pesticide Analysts. CropLife India has recommended that these be prescribed centrally by the Central Government, to ensure uniform technical standards and consistent enforcement across States.

Accountability of Pesticide Inspectors and Pesticide Analysts

Recommended inclusion of statutory provisions for the accountability of officers exercising statutory powers under the Act, in line with corresponding provisions in the Drugs and Cosmetics Act, 1940 and the Food Safety and Standards Act, 2006.

Registration Committee – procedures and governance

Recommended greater clarity on the procedures and governance of the Registration Committee, including documented decision-making frameworks and indicative timelines, to support consistency, transparency and predictability while preserving scientific autonomy.

Provisional registration

Recommended that provisional registration be retained strictly for genuine exigencies, supported by clearly defined conditions and validity period, and that it not serve as a substitute for full scientific evaluation.

Laboratory accreditation and audit

Continued recognition of accredited laboratories, including qualified private laboratories, has been supported, subject to safeguards preventing any direct or indirect financial interest in pesticide manufacture or sale. Recommended that testing laboratories be subject to mandatory periodic third-party audit by independent agencies designated by the Central Government.

Digitisation of regulatory processes

The draft Bill’s emphasis on digitisation of registration, licensing, inspection and record-keeping has been welcomed. Greater clarity and consistency in implementation and processing timelines has been suggested to enhance predictability and transparency.

Preamble and regulatory objectives

Recommended that the Preamble expressly recognise quality as a core regulatory objective alongside safety and efficacy, and that all categories of crop protection products, including biologicals and products based on traditional knowledge, remain subject to a uniform scientific, quality, safety and efficacy framework.