UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460

OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION

January 27, 2020

Narasimha Rao Kothapalli Authorized Representative Coromandel International Limited c/o Parry America Inc. 1521 N Cooper St. Ste 350 Arlington, TX 76011 Subject: Non-PRIA (Pesticide Registration Improvement Act) Labeling Amendment – Addition of

New Use Site, Hemp, to Sublabels 1-9 Product Name: Neemazal T/S 1.2 EC EPA Registration Number: 71908-1 Application Date: September 30, 2019 OPP Decision Number: 556409 Dear Mr. Kothapalli: The amended labeling referred to above, submitted in connection with registration under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), as amended, is acceptable. This approval does not affect any terms or conditions that were previously imposed on this registration. You continue to be subject to existing terms or conditions on your registration and any deadlines connected with them. A stamped copy of your labeling is enclosed for your records. This labeling supersedes all previously accepted labeling. You must submit one (1) copy of the final printed labeling before you release this product for shipment with the new labeling. In accordance with 40 CFR § 152.130(c), you may distribute or sell this product under the previously approved labeling for 18 months from the date of this letter. After 18 months, you may only distribute or sell this product if it bears this new revised labeling or subsequently approved labeling. “To distribute or sell” is defined under FIFRA section 2(gg) and its implementing regulation at 40 CFR § 152.3. Should you wish to add/retain a reference to your company’s website on your label, then please be aware that the website becomes labeling under FIFRA and is subject to review the U.S. Environmental Protection Agency (EPA). If the website is false or misleading, the product will be considered to be misbranded and sale or distribution of the product is unlawful under FIFRA section 12(a)(1)(E). 40 CFR § 156.10(a)(5) lists examples of statements the EPA may consider false or misleading. In addition, regardless of whether a website is referenced on your product’s label, claims made on the website may not substantially differ from those claims approved through the registration process. Therefore, should

Page 2 of 2 EPA Reg. No. 71908-1 OPP Decision No. 556409 the EPA find or if it is brought to our attention that a website contains false or misleading statements or claims substantially differing from the EPA-approved registration, the website will be referred to the EPA’s Office of Enforcement and Compliance Assurance. Your release for shipment of this product constitutes acceptance of these terms. If these terms are not complied with, this registration will be subject to cancellation in accordance with FIFRA section 6. If you have any questions, please contact Menyon Adams by phone at (703) 347- 8496 or via email at adams.menyon@epa.gov. Sincerely,

Gina Burnett, Senior Regulatory Advisor Biochemical Pesticides Branch

Biopesticides and Pollution Prevention Division (7511P) Office of Pesticide Programs

Enclosure

1

Revised on 01/22/20

NeemAzal® T/S 1.2 EC

HEMP,

HEMP,

HEMP,

HEMP,

HEMP,

HEMP,

01/27/2020

71908-1

2

Revised on 01/22/20

HEMP,

HEMP,

HEMP,

972-325-1227

COROMANDEL INTERNATIONAL LIMITEDCoromandel House, Sardar Patel RoadSecunderabad 500 003Telangana India

3

Revised on 01/22/20

NeemAzal® T/S 1.2 EC , HEMP,

•••

••

COROMANDEL INTERNATIONAL LIMITEDCoromandel House, Sardar Patel RoadSecunderabad 500 003Telangana India

4

Revised on 01/22/20

•••

5

Revised on 01/22/20

•

•

•

•

6 Revised on 01/22/20

e

OTHER CROPS: Hemp

7

Revised on 01/22/20

.

8

Revised on 01/22/20

EcoGarden™

• HEMP,

• HEMP,

COROMANDEL INTERNATIONAL LIMITEDCoromandel House, Sardar Patel RoadSecunderabad 500 003Telangana India

972-325-1227

9

Revised on 01/22/20

••••

Coromandel International

10

Revised on 01/22/20

Other Crops Hemp

11

Revised on 01/22/20

12

Revised on 01/22/20

13

Revised on 01/22/20

14

Revised on 01/22/20

s, Hemp,

15

Revised on 01/22/20

••••

•

•

•

•••

••

•

16

Revised on 01/22/20

17

Revised on 01/22/20

18

Revised on 01/22/20

••

••

19

Revised on 01/22/20

a

20

Revised on 01/22/20

21

Revised on 01/22/20

•••••••••••

22

Revised on 01/22/20

• HEMP,

972-325-1227

COROMANDEL INTERNATIONAL LIMITEDCoromandel House, Sardar Patel RoadSecunderabad 500 003Telangana India

23

Revised on 01/22/20

24

Revised on 01/22/20

25

Revised on 01/22/20

a

Other Crops Hemp

26

Revised on 01/22/20

••

••

27

Revised on 01/22/20

,Hemp,

28

Revised on 01/22/20

COROMANDEL INTERNATIONAL LIMITED

29

Revised on 01/22/20

••••••••••••••••••••••••••••••••••••

30

Revised on 01/22/20

HEMP,

COROMANDEL INTERNATIONAL LIMITEDCoromandel House, Sardar Patel RoadSecunderabad 500 003Telangana India

972-325-1227

31

Revised on 01/22/20

••••

32

Revised on 01/22/20

33

Revised on 01/22/20

34 Revised on 01/22/20

a

Other Crops Hemp

35

Revised on 01/22/20

36

Revised on 01/22/20

,Hemp,

37

Revised on 01/22/20

38

Revised on 01/22/20

a

39

Revised on 01/22/20

NOTICE ON CONDITIONS OF SALE

COROMANDEL INTERNATIONAL LIMITED

40

Revised on 01/22/20

••••••••••• COROMANDEL INTERNATIONAL LIMITED••••••••••••••••••••••• •

41

Revised on 01/22/20

EcoGarden

972-325-1227COROMANDEL INTERNATIONAL LIMITEDCoromandel House, Sardar Patel RoadSecunderabad 500 003Telangana India

42

Revised on 01/22/20

43

Revised on 01/22/20

44

Revised on 01/22/20

a

Other Crops Hemp

45

Revised on 01/22/20

46

Revised on 01/22/20

The directions for use of this product are believed to be adequate and must be followed carefully. However, it is impossible to eliminate all risks associated with the use of this product. Plant injury, ineffectiveness or other unintended consequences may result because of such factors as weather conditions, presence of other materials, or the manner of use or application, all of which are beyond the control of COROMANDEL INTERNATIONAL LIMITED. To the extent consistent with applicable law, all such risks

shall be assumed by the user or buyer.

47

Revised on 01/22/20

Single Dose Sprayer System (Patent Pending) Just add water, attach Single Dose Delivery Cartridge, and spray Spray and Drench Organic Materials Review Institute (OMRI) Listed. Contains azadirachtin from COROMANDEL INTERNATIONAL LIMITED

♦ Tough Pests. Easy Solution Controls chewing and sucking insects Broad spectrum insect and mite control Can be applied up to and on the day of harvest for all food & non food use plants Can be used on a wide variety of trees, shrubs flowers, fruit and nut trees, garden vegetables and plants. Rose Spray For use on Rose and Flowers Vegetable Garden Spray For use on Tomatoes and Garden Vegetables Controls Japanese Beetle on Roses Insect and Mite Control for the Home Garden Vegetables Complete Insect and Mite Control for Flowers Three applications in 30 days provides complete plant protection Quadruple action insect control – Antifeedant, Insect Growth Regulator, Anti-ovipository, Repellant Single product; multiple action Single product; multiple pest control A proven botanical pesticide born out of a decade of intense global research Works effectively against a broad spectrum of pests on a stand alone basis on a variety of vegetable crops Controls insect pest during various stages of growth The Benefits to your insect control program are multiple Low Odor Formulation Controls Insects Systemically Taken up through the roots, controls insects on the leaves Insects stop feeding when they feed on treated plants Easy to Use For foliar and systemic insect control No Measuring Ready to Prepare and Use Single Dose Delivery Cartridges can be purchased separately Ready to Make and Spray Reusable Sprayer Bottle with 360 Degree Sprayer nozzle Three in one product – Insecticide, Miticide, and Nematicide Recommended by General Hydroponics – Bringing Nature and Technology Together (logo) For Organic Gardening

48

Revised on 01/22/20

EcoGarden

Read This Entire Label Before Use

972-325-1227COROMANDEL INTERNATIONAL LIMITEDCoromandel House, Sardar Patel RoadSecunderabad 500 003Telangana India

49

Revised on 01/22/20

50

Revised on 01/22/20

51

Revised on 01/22/20

a

Other Crops Hemp

52

Revised on 01/22/20

53

Revised on 01/22/20

The directions for use of this product are believed to be adequate and must be followed carefully. However, it is impossible to eliminate all risks associated with the use of this product. Plant injury, ineffectiveness or other unintended consequences may result because of such factors as weather conditions, presence of other materials, or the manner of use or application, all of which are beyond the control of COROMANDEL INTERNATIONAL LIMITED.

54

Revised on 01/22/20

Single Dose Sprayer System (Patent Pending) Just add water, insert Single Dose Delivery Sachet, and spray Spray and Drench Organic Materials Review Institute (OMRI) Listed. Contains azadirachtin from COROMANDEL INTERNATIONAL LIMITED Tough Pests. Easy Solution Controls chewing and sucking insects Broad spectrum insect and mite control Can be applied up to and on the day of harvest for all food & non food use plants Can be used on a wide variety of trees, shrubs flowers, fruit and nut trees, garden vegetables and plants. Rose Spray For use on Rose and Flowers Vegetable Garden Spray For use on Tomatoes and Garden Vegetables Controls Japanese Beetle on Roses Insect and Mite Control for the Home Garden Vegetables Complete Insect and Mite Control for Flowers Three applications in 30 days provides complete plant protection Quadruple action insect control – Antifeedant, Insect Growth Regulator, Anti-ovipository, Repellant Single product; multiple action Single product; multiple pest control A proven botanical pesticide born out of a decade of intense global research Works effectively against a broad spectrum of pests on a stand alone basis on a variety of vegetable crops Controls insect pest during various stages of growth The Benefits to your insect control program are multiple Low Odor Formulation Controls Insects Systemically Taken up through the roots, controls insects on the leaves Insects stop feeding when they feed on treated plants Easy to Use For foliar and systemic insect control No Measuring Ready to Prepare and Use Single Dose Delivery Sachets can be purchased separately Ready to Make and Spray Reusable Sprayer Bottle with 360 Degree Sprayer nozzle Three in one product – Insecticide, Miticide, and Nematicide Recommended by General Hydroponics – Bringing Nature and Technology Together (logo) For Organic Gardening

55

Revised on 01/22/20

EcoGarden

Read This Entire Label Before Use

COROMANDEL INTERNATIONAL LIMITEDCoromandel House, Sardar Patel RoadSecunderabad 500 003Telangana India

972-325-1227

56

Revised on 01/22/20

57

Revised on 01/22/20

58

Revised on 01/22/20

a

Other Crops Hemp

59

Revised on 01/22/20

60

Revised on 01/22/20

The directions for use of this product are believed to be adequate and must be followed carefully. However, it is impossible to eliminate all risks associated with the use of this product. Plant injury, ineffectiveness or other unintended consequences may result because of such factors as weather conditions, presence of other materials, or the manner of use or application, all of which are beyond the control of COROMANDEL INTERNATIONAL LIMITED.

61

Revised on 01/22/20

Spray and Drench Contains azadirachtin from COROMANDEL INTERNATIONAL LIMITED Organic Materials Review Institute (OMRI) Listed. Tough Pests. Easy Solution Controls chewing and sucking insects Broad spectrum insect and mite control Can be applied up to and on the day of harvest for all food & non food use plants Can be used on a wide variety of trees, shrubs flowers, fruit and nut trees, garden vegetables and plants. Rose Spray For use on Rose and Flowers Vegetable Garden Spray For use on Tomatoes and Garden Vegetables Controls Japanese Beetle on Roses Insect and Mite Control for the Home Garden Vegetables Complete Insect and Mite Control for Flowers Three applications in 30 days provides complete plant protection Quadruple action insect control – Antifeedant, Insect Growth Regulator, Anti-ovipository, Repellant Single product; multiple action Single product; multiple pest control A proven botanical pesticide born out of a decade of intense global research Works effectively against a broad spectrum of pests on a stand alone basis on a variety of vegetable crops Controls insect pest during various stages of growth The Benefits to your insect control program are multiple Low Odor Formulation Controls Insects Systemically Taken up through the roots, controls insects on the leaves Insects stop feeding when they feed on treated plants Easy to Use For foliar and systemic insect control No Measuring Ready to Prepare and Use Ready to Make and Spray Three in one product – Insecticide, Miticide, and Nematicide Recommended by General Hydroponics – Bringing Nature and Technology Together (logo) For Organic Gardening

62

Revised on 01/22/20

EcoGarden

Read This Entire Label Before Use

COROMANDEL INTERNATIONAL LIMITEDCoromandel House, Sardar Patel RoadSecunderabad 500 003Telangana India972-325-1227

63

Revised on 01/22/20

64

Revised on 01/22/20

65

Revised on 01/22/20

a

Other Crops Hemp

66 Revised on 01/22/20

For Hemp

67

Revised on 01/22/20

68

Revised on 01/22/20

The directions for use of this product are believed to be adequate and must be followed carefully. However, it is impossible to eliminate all risks associated with the use of this product. Plant injury, ineffectiveness or other unintended consequences may result because of such factors as weather conditions, presence of other materials, or the manner of use or application, all of which are beyond the control of COROMANDEL INTERNATIONAL LIMITED.

69

Revised on 01/22/ 20

Spray and Drench Contains azadirachtin from COROMANDEL INTERNATIONAL LIMITED Can be used in Organic Gardening Tough Pests. Easy Solution. Organic Materials Review Institute (OMRI) Listed. Controls chewing and sucking insects Broad spectrum insect and mite control Can be applied up to and on the day of harvest for all food & non food use plants Can be used on a wide variety of trees, shrubs flowers, fruit and nut trees, garden vegetables and plants. Rose Spray For use on Rose and Flowers Vegetable Garden Spray For use on Tomatoes and Garden Vegetables Controls Japanese Beetle on Roses Insect and Mite Control for the Home Garden Vegetables Complete Insect and Mite Control for Flowers Three applications in 30 days provides complete plant protection Quadruple action insect control – Antifeedant, Insect Growth Regulator, Anti-ovipository, Repellant Single product; multiple action Single product; multiple pest control A proven botanical pesticide born out of a decade of intense global research Works effectively against a broad spectrum of pests on a stand alone basis on a variety of vegetable crops Controls insect pest during various stages of growth The Benefits to your insect control program are multiple Low Odor Formulation Controls Insects Systemically Taken up through the roots, controls insects on the leaves Insects stop feeding when they feed on treated plants Easy to Use For foliar and systemic insect control No Measuring Ready to Prepare and Use Ready to Make and Spray Three in one product – Insecticide, Miticide, and Nematicide Recommended by General Hydroponics – Bringing Nature and Technology Together (logo)

70

Revised on 01/22/20

EcoGarden

Read This Entire Label Before Use

COROMANDEL INTERNATIONAL LIMITEDCoromandel House, Sardar Patel RoadSecunderabad 500 003Telangana India972-325-1227

71

Revised on 01/22/20

72

Revised on 01/22/20

73

Revised on 01/22/20

a

Other Crops Hemp

74

Revised on 01/22/20

75

Revised on 01/22/20

The directions for use of this product are believed to be adequate and must be followed carefully. However, it is impossible to eliminate all risks associated with the use of this product. Plant injury, ineffectiveness or other unintended consequences may result because of such factors as weather conditions, presence of other materials, or the manner of use or application, all of which are beyond the control of COROMANDEL INTERNATIONAL LIMITED.

76

Revised on 01/22/20

ed on the retail container label he Product

♦ Contains Azadirachtin from COROMANDEL INTERNATIONAL LIMITED♦ Tough Pests. Easy Solution

Organic Materials Review Institute (OMRI) Listed. Controls chewing and sucking insects Broad spectrum insect and mite control Can be applied up to and on the day of harvest for all food & non food use plants Can be used on a wide variety of flowers, garden vegetables and plants. For use on Rose and Flowers For use on Tomatoes and Garden Vegetables Controls Japanese Beetle on Roses Insect and Mite Control for the Home Garden Vegetables Complete Insect and Mite Control for Flowers Quadruple action insect control – Antifeedant, Insect Growth Regulator, Anti-ovipository, Repellant Single product; multiple action Single product; multiple pest control A proven botanical pesticide born out of a decade of intense global research Works effectively against a broad spectrum of pests on a stand alone basis on a variety of vegetable crops Controls insect pest during various stages of growth The Benefits to your insect control program are multiple Controls Insects Systemically Taken up through the roots, controls insects on the leaves Insects stop feeding when they feed on treated plants Easy to Use No Measuring For Organic Gardening Three in one product – Insecticide, Miticide, and Nematicide Recommended by General Hydroponics – Bringing Nature and Technology Together (logo)

77

Revised on 01/22/20