Re-evaluation Decision RVD2021-05, Imidacloprid and Its Associated End-use Products

Pest Management Regulatory Agency
19 May 2021
ISSN: 1925-1025 (PDF version)
Catalogue number: H113-28/2021-5-PDF (PDF version)

Summary

To obtain a full copy of Re-evaluation Decision RVD2021-05, Imidacloprid and Its Associated End-use Products please contact our publications office.

Health Canada’s Pest Management Regulatory Agency will host a webinar to provide an overview of the decision for imidacloprid. For more information and to register, select the following link: Health Canada webinar.

Should you require further information please contact the Pest Management Information Service.

Table of contents

Re-evaluation decision for imidacloprid and associated end use products

Under the authority of the Pest Control Products Act, all registered pesticides must be re-evaluated by Health Canada's Pest Management Regulatory Agency (PMRA) to ensure that they continue to meet current health and environmental standards and continue to have value. The re-evaluation considers data and information from pesticide manufacturers, published scientific reports and other regulatory agencies, as well as comments received during public consultations. Health Canada applies internationally accepted risk assessment methods as well as current risk management approaches and policies.

Imidacloprid is a broad spectrum neonicotinoid insecticide. It is used to manage insects on a large number of agricultural crops, ornamental plants, trees, turf, indoor and outdoor structural sites, and as spot-on application to pets. Imidacloprid products are applied using ground, aerial and seed treatment equipment, tree injection applicators, granular spreaders, pressurized spray cans, brush or paint rollers, spot-on applicators to pets, and as a bait and in bait stations. Currently registered products containing imidacloprid can be found in the Pesticide Label Search and in Appendix I.

The Proposed Re-evaluation Decision PRVD2016-20, Imidacloprid,Footnote 1 containing an evaluation of imidacloprid and proposed decision, underwent a 120 day consultation period ending on 23 March 2017. PRVD2016-20 proposed the phase-out of all the agricultural and a majority of non-agriculture uses of imidacloprid due to risks to aquatic organisms. Since publication of PRVD2016-20, Health Canada received comments and information relating to the health, environmental and value assessments of imidacloprid. Commenters are listed in Appendix III of RVD2021-05 and the comments are summarized in Appendix IV of RVD2021-05 along with the Health Canada responses. The comments and new data/information received resulted in revisions to the occupational and environmental risk assessments (see Science Evaluation Update), and resulted in changes to the proposed re-evaluation decision as described in PRVD2016-20.

Risks to bees and other pollinators were not a part of this re-evaluation as they were addressed in Health Canada's final re-evaluation decision specifically examining the effects of imidacloprid on pollinators RVD2019-06, Imidacloprid and Its Associated End-use Products: Pollinator Re-evaluation. The mitigation measures put in place as a result of the pollinator re-evaluation are taken into consideration in this re-evaluation decision. The environmental risk of imidacloprid resulting from tree injection uses was previously assessed (ERC2011-03, PRD2016-16 and RD2016-28).

A reference list of information used as the basis for the proposed re-evaluation decision is included in PRVD2016-20, and further information used in the final re-evaluation decision is listed in Appendix XII of RVD2021-05. Therefore, the complete reference list of all information used in this final re-evaluation decision includes both the information set out in PRVD2016-20 and the information set out in Appendix XII of RVD2021-05.

This document (Re-evaluation Decision RVD2021-05, Imidacloprid and Its Associated End-use Products) presents the final re-evaluation decisionFootnote 2 for the re-evaluation of imidacloprid, including the required amendments (risk mitigation measures) to protect human health and the environment, as well as label amendments required to bring labels to current standards. All products containing imidacloprid that are registered in Canada are subject to this re-evaluation decision.

Science evaluation summary

An evaluation of the human health risks associated with imidacloprid has concluded that all uses are acceptable for continued registration with revised label instructions. Some occupational scenarios require revised label directions. Also, some spot-on pet product labels must be brought to current standards. Updates to the assessment can be found in the Science Evaluation Update and Appendix V of RVD2021-05.

Extensive comments and data related to the aquatic invertebrate risk assessment were received. New information included additional toxicity studies and water monitoring data from across Canada. There has been no change to the environmental risk conclusions for turf and lawn uses, and these uses are cancelled. Updates to the assessment of agricultural uses resulted in changes to some of the previous conclusions. Certain uses were not shown to be acceptable and are cancelled. Details are presented in the Science Evaluation Update as well as Appendices VII, VIII, IX and X of RVD2021-05.

Updates were made to the bird and mammal risk assessment based on comments and new information received. Details are presented in the Science Evaluation Update and Appendix VI of RVD2021-05. Risks related to the consumption of imidacloprid-treated seeds by birds and mammals were not shown to be acceptable for some exposure scenarios. Changes to the registrations of some seed treatment uses are required.

Imidacloprid has value as an insecticide used in agriculture, around structures and on pets. Health Canada heard from a number of Canadians on the value of products containing imidacloprid, including information on alternatives which were considered when making the final decision.

Re-evaluation decision for imidacloprid

Health Canada has completed the re-evaluation of imidacloprid. Under the authority of the Pest Control Products Act, Health Canada has determined that continued registration of most products containing imidacloprid is acceptable. An evaluation of available scientific information found that most uses of imidacloprid products meet current standards for protection of human health and the environment and have acceptable value when used according to revised conditions of registration, which includes new mitigation measures. However, certain uses of imidacloprid are cancelled to address potential risks of concern to the environment. Cancelled uses are listed in the Risk mitigation measures Section below. Label amendments, as summarized below and listed in Appendix XI of RVD2021-05, are required.

Risk mitigation measures

Registered pesticide product labels include specific directions for use. Directions include risk mitigation measures to protect human health and the environment and must be followed by law. The required amendments, including any revised/updated label statements and mitigation measures, as a result of the re-evaluation of imidacloprid, are summarized below. Refer to Appendix XI of RVD2021-05 for details.

Cancelled uses due to risks to the environment:

Human health

To protect workers and those entering treated areas, the following risk-reduction measures are required for continued registration of imidacloprid in Canada:

To better inform the consumer as to the possible effects that may occur following product use, and to clarify the use directions on product labels, the following risk-reduction measure is required for continued registration of imidacloprid in Canada:

Environment

To protect the environment, the following changes to the conditions of use of imidacloprid are required for the following crops:

Greenhouse uses (soil drench, transplant tray plug drench) are permitted to continue provided that measures are in place to prevent releases, effluent or runoff from greenhouses containing this product from entering lakes, streams, ponds, or other waters. In addition, greenhouses using closed recirculation system (for example, closed chemigation system), the following is required:

To protect the environment, the following risk-reduction measures are also required on the label:

Required label amendments for all products, where applicable:

Next steps

Refer to Appendix I for details on specific products impacted by this decision.

Amended products

To comply with this decision, the required amendments (mitigation measures and label updates)
must be implemented on all product labels no later than 24 months after the publication date of RVD2021-05. Accordingly, both registrants and retailers will have up to 24 months from the date of this decision document to transition to selling the product with the newly amended labels.

Similarly, users will also have the same 24-month period from the date of this decision document to transition to using the newly amended labels, which will be available on the Public Registry.

Cancelled products

Products that are cancelled will be phased out following the implementation timeline outlined below.

The transition periods for required amendments and product cancellations will allow for an orderly and safe implementation of these new restrictions and should reduce the risk of product misuse or the improper disposal of products as users switch to alternatives, where required. The risks identified are not considered imminent and serious because they are not expected to cause irreversible harm over these phase-out periods. This approach is consistent with Health Canada's current policy and practice with respect to phase out of uses and products as a result of a re-evaluation (Regulatory Directive DIR2018-01, Policy on Cancellations and Amendments Following Re-evaluation and Special Review).

Cancelled use with extended phase-out

European chafer on the root vegetable ginseng (soil drench) was found to lack suitable alternatives. The effective date of the re-evaluation decision for this use will be delayed for 24 months pursuant to subsection 21(3) of the Pest Control Products Act.

The environmental risks have been determined to be acceptable over this time period on the basis of the current relatively small and fragmented growing areas associated with this crop. Therefore, the continued use for 24 additional months for this imidacloprid use with no suitable alternatives is considered acceptable.

Other information

Any person may file a notice of objectionFootnote 3 regarding this decision on imidacloprid and its associated end-use products within 60 days from the date of publication of this Re-evaluation Decision. For more information regarding the basis for objecting (which must be based on scientific grounds), please refer to the Pesticides section of the Canada.ca website (Request a Reconsideration of Decision) or contact the PMRA's Pest Management Information Service by phone (1-800-267-6315) or by e-mail (hc.pmra-info-arla.sc@Canada.ca).

The relevant confidential test data on which the decision is based (as referenced in PRVD2016-20 and in Appendix XII of RVD2021-05) are available for public inspection, upon application, in the PMRA's Reading Room. For more information, please contact the PMRA's Pest Management Information Service.

Appendix I Registered products containing imidacloprid in Canada

Table 1 Registered products containing imidacloprid in CanadaFootnote 1 requiring label amendmentsFootnote 2
Registration number Marketing class Registrant Product name Formulation type Guarantee

28936

Technical grade active ingredient

Nufarm Agriculture Inc.

Nufarm Imidacloprid Technical

Solid

Imidacloprid 98%

32242

Manufacturing concentrate

Nufarm Agriculture Inc

Mallet 20 MC

Solution

Imidacloprid 20%

32243

Manufacturing concentrate

Nufarm Agriculture Inc

NUP-14001 MUP

Solution

Imidacloprid 19.19% Lambda-cyhalothrin 3.84%

32645

Technical grade active ingredient

Sharda Cropchem Limited

Imidacloprid Technical Insecticide

Solid

Imidacloprid 98.53%

24468

Technical grade active ingredient

Bayer CropScience Incorporated

Bay NTN 33893 Technical Insecticide

Solid

Imidacloprid 98%

25390

Manufacturing concentrate

Bayer CropScience Incorporated

Merit 75% Concentrate Insecticide

Wettable powder

Imidacloprid 75%

24094

Commercial

Bayer CropScience Incorporated

Admire 240 Flowable Systemic Insecticide

Suspension

Imidacloprid 240 g/L

25636

Commercial

Bayer CropScience Incorporated

Merit 60 WP Greenhouse And Nursery Insecticide

Wettable powder

Imidacloprid 60%

26124

Commercial

Bayer CropScience Incorporated

Gaucho 480 FL Insecticide

Suspension

Imidacloprid 480 g/L

27170

Commercial

Bayer CropScience Incorporated

Gaucho 600 FL Insecticide

Suspension

Imidacloprid 600 g/L

27357

Commercial

Bayer CropScience Incorporated

Intercept 60 WP Greenhouse Insecticide

Wettable powder

Imidacloprid 60%

29609

Commercial

Bayer CropScience Incorporated

Stress Shield For Cereals

Suspension

Imidacloprid 480 g/L

29610

Commercial

Bayer CropScience Incorporated

Stress Shield For Cereals and Soybeans

Suspension

Imidacloprid 480 g/L

29611

Commercial

Bayer CropScience Incorporated

Concept Liquid Insecticide

Suspension

Imidacloprid 75 g/L Deltamethrin 10 g/L

30513

Commercial

Bayer CropScience Incorporated

Maxforce Quantum Ant Bait

Paste

Imidacloprid 0.03%

30668

Commercial

Bayer CropScience Incorporated

Stress Shield 600

Suspension

Imidacloprid 600 g/L

30972

Commercial

Bayer CropScience Incorporated

Sepresto 75 WS

Wettable Powder

Imidacloprid 18.75%

Clothianidin 56.25%

31068

Commercial

Bayer CropScience Incorporated

Acceleron IX-409 Insecticide Seed Treatment

Suspension

Imidacloprid 600 g/L

32234

Commercial

Bayer CropScience Incorporated

Quickbayt Granular Fly Bait

Granular

Imidacloprid 0.5% Muscalure 0.09%

32493

Commercial

Bayer CropScience Incorporated

Maxforce Fly Spot Bait

Granular

Imidacloprid 10% Muscalure 0.01%

32523

Commercial

Bayer CropScience Incorporated

Temprid Readyspray

Pressurized products

Imidacloprid 0.05%

Beta-cyfluthrin 0.025%

32524

Commercial

Bayer CropScience Incorporated

Temprid SC

Suspension

Imidacloprid 21%

Beta-cyfluthrin 10.5%

33014

Commercial

Bayer CropScience Incorporated

Credo SC Insecticide

Suspension

Imidacloprid 526 g/L

33305

Commercial

Bayer CropScience Incorporated

Quickbayt Spot Spray

Wettable granules

Imidacloprid 10%

Muscalure 0.1%

29703

Commercial + Restricted

Bayer CropScience Incorporated

Confidor 200 SL

Solution

Imidacloprid 17.1%

30374

Technical grade active ingredient

Adama Agricultural Solutions Canada Limited

MANA Imidacloprid Technical

Solid

Imidacloprid 98.3%

28475

Commercial

Adama Agricultural Solutions Canada Limited

Alias 240 SC Systemic Insecticide

Suspension

Imidacloprid 240 g/L

30505

Commercial

Adama Agricultural Solutions Canada Limited

Sombrero 600 FS

Suspension

Imidacloprid 600 g/L

33562

Commercial

Sharda Cropchem Limited

Sofast Granular Fly Bait

Granular

Imidacloprid 0.5% Muscalure 0.1%

31375

Commercial + Restricted

Arborjet Incorporated

IMA- Jet

Solution

Imidacloprid 58.5 g/L

31479

Commercial + Restricted

Arborjet Incorporated

IMA-Jet 10

Solution

Imidacloprid 117 g/L

25127

Domestic

Elanco Canada Limited

Advantage 55 Flea and Lice Adulticide for Dogs 8 Weeks and Older Weighing between 11 and 25 Kg

Solution

Imidacloprid 9.1%

25128

Domestic

Elanco Canada Limited

Advantage 9 Flea Adulticide for Cats 8 Weeks and Older Weighing 4 Kg and Under

Solution

Imidacloprid 9.1%

25129

Domestic

Elanco Canada Limited

Advantage 18 Flea Adulticide for Cats 8 Weeks and Older Weighing Over 4 Kg

Solution

Imidacloprid 9.1%

25130

Domestic

Elanco Canada Limited

Advantage 10 Flea and Lice Adulticide for Dogs 8 Weeks and Older Weighing 4.5kg & Under

Solution

Imidacloprid 9.1%

25131

Domestic

Elanco Canada Limited

Advantage 100 Flea and Lice Adulticide for Dogs 8 Weeks and Older Weighing More Than 25 Kg

Solution

Imidacloprid 9.1%

25132

Domestic

Elanco Canada Limited

Advantage 20 Flea and Lice Adulticide for Dogs 8 Weeks and Older Weighing Between 4.6 and 11 Kg

Solution

Imidacloprid 9.1%

27581

Domestic

Elanco Canada Limited

Advantage II Small Dog

Solution

Imidacloprid 9.1% Pyriproxifen 0.46%

27582

Domestic

Elanco Canada Limited

Advantage II Large Dog

Solution

Imidacloprid 9.1% Pyriproxifen 0.46%

27583

Domestic

Elanco Canada Limited

Advantage II Medium Dog

Solution

Imidacloprid 9.1% Pyriproxifen 0.46%

27584

Domestic

Elanco Canada Limited

Advantage II Extra Large Dog

Solution

Imidacloprid 9.1% Pyriproxifen 0.46%

27585

Domestic

Elanco Canada Limited

Advantage II small Cat/Rabbit/Ferret

Solution

Imidacloprid 9.1% Pyriproxifen 0.46%

27586

Domestic

Elanco Canada Limited.

Advantage II large Cat/Rabbit

Solution

Imidacloprid 9.1% Pyriproxifen 0.46%

27658

Domestic

Elanco Canada Limited

K9 Advantix 10 Flea, Tick, Mosquito, and Lice Adulticide

Liquid

Imidacloprid 8.8% Permethrin 44%

27659

Domestic

Elanco Canada Limited

K9 Advantix 100 Flea, Tick, Mosquito, and Lice Adulticide

Liquid

Imidacloprid 8.8% Permethrin 44%

27660

Domestic

Elanco Canada Limited

K9 Advantix 55 Flea, Tick, Mosquito, and Lice Adulticide

Liquid

Imidacloprid 8.8% Permethrin 44%

27661

Domestic

Elanco Canada Limited

K9 Advantix 20 Flea, Tick, Mosquito, and Lice Adulticide

Liquid

Imidacloprid 8.8% Permethrin 44%

29777

Domestic

Elanco Canada Limited

K9 Advantix II Small Dog

Solution

Imidacloprid 8.8% Pyriproxifen 0.44% Permethrin 44%

29778

Domestic

Elanco Canada Limited

K9 Advantix II Medium Dog

Solution

Imidacloprid 8.8% Pyriproxifen 0.44% Permethrin 44%

29779

Domestic

Elanco Canada Limited

K9 Advantix II Extra Large Dog

Solution

Imidacloprid 8.8% Pyriproxifen 0.44% Permethrin 44%

29780

Domestic

Elanco Canada Limited

K9 Advantix II Large Dog

Solution

Imidacloprid 8.8% Pyriproxifen 0.44% Permethrin 44%

31517

Domestic

Elanco Canada Limited.

Advantage II Kittens

Liquid

Imidacloprid 9.1% Pyriproxifen 0.46%

31307

Domestic

Fusion Animal Health Incorporated

Primidacide <4 Kg

Solution

Imidacloprid 9.1%

31308

Domestic

Fusion Animal Health Incorporated

Primidacide <4.5 Kg

Solution

Imidacloprid 9.1%

31309

Domestic

Fusion Animal Health Incorporated

Primidacide 4.6-11 Kg

Solution

Imidacloprid 9.1%

31310

Domestic

Fusion Animal Health Incorporated.

Primidacide >4 Kg

Solution

Imidacloprid 9.1%

31311

Domestic

Fusion Animal Health Incorporated

Primidacide >25 Kg

Solution

Imidacloprid 9.1%

31312

Domestic

Fusion Animal Health Incorporated

Primidacide 11-25 Kg

Solution

Imidacloprid 9.1%

33626

Domestic

Fusion Animal Health Incorporated

Primidacide Flea & Tick For Dogs Under 4.5KG

Liquid

Imidacloprid 8.8% Permethrin 44%

33627

Domestic

Fusion Animal Health Incorporated

Primidacide Flea & Tick For Dogs 4.6-11kg

Liquid

Imidacloprid 8.8% Permethrin 44%

33628

Domestic

Fusion Animal Health Incorporated

Primidacide Flea & Tick For Dogs 11-25kg

Liquid

Imidacloprid 8.8% Permethrin 44%

33629

Domestic

Fusion Animal Health Incorporated

Primidacide Flea & Tick For Dogs 25kg And Over

Liquid

Imidacloprid 8.8% Permethrin 44%

31507

Domestic

Brite Ridge Pharmaceuticals Incorporated

Barrier 9

Solution

Imidacloprid 9.1%

31508

Domestic

Brite Ridge Pharmaceuticals Incorporated

Barrier 10

Solution

Imidacloprid 9.1%

31509

Domestic

Brite Ridge Pharmaceuticals Incorporated

Barrier 18

Solution

Imidacloprid 9.1%

31510

Domestic

Brite Ridge Pharmaceuticals Incorporated

Barrier 55

Solution

Imidacloprid 9.1%

31511

Domestic

Brite Ridge Pharmaceuticals Incorporated

Barrier 100

Solution

Imidacloprid 9.1%

31512

Domestic

Brite Ridge Pharmaceuticals Incorporated

Barrier 20

Solution

Imidacloprid 9.1%

31980

Domestic

Wellmark International

Zodiac Infestop Topical Solution For Cats 4 Kg and Under

Solution

Imidacloprid 9.1%

31982

Domestic

Wellmark International

Zodiac Infestop Topical Solution For Dogs 4.5 Kg and Under

Solution

Imidacloprid 9.1%

31983

Domestic

Wellmark International

Zodiac Infestop Topical Solution For Dogs Between 4.6 And 11 Kg

Solution

Imidacloprid 9.1%

31984

Domestic

Wellmark International

Zodiac Infestop Topical Solution For Cats Over 4 Kg

Solution

Imidacloprid 9.1%

31985

Domestic

Wellmark International

Zodiac Infestop Topical Solution For Dogs Over 25 Kg

Solution

Imidacloprid 9.1%

31986

Domestic

Wellmark International

Zodiac Infestop Topical Solution For Dogs Between 11 And 25 Kg

Solution

Imidacloprid 9.1%

32567

Domestic

Virbac Corporation

Preventic Topical Solution Extra Large Dog

Liquid

Imidacloprid 8.8%

Permethrin 44%

32573

Domestic

Virbac Corporation

Ectoshield Topical Solution Medium And Large Cat

Solution

Imidacloprid 9.1%

32574

Domestic

Virbac Corporation

Ectoshield Topical Solution Small Cat

Solution

Imidacloprid 9.1%

32581

Domestic

Virbac Corporation

Ectoshield Topical Solution Small Dog

Solution

Imidacloprid 9.1%

32584

Domestic

Virbac Corporation

Ectoshield Topical Solution Extra Large Dog

Solution

Imidacloprid 9.1%

32585

Domestic

Virbac Corporation

Ectoshield Topical Solution Medium Dog

Solution

Imidacloprid 9.1%

32586

Domestic

Virbac Corporation

Preventic Topical Solution Large Dog

Liquid

Imidacloprid 8.8%

Permethrin 44%

32588

Domestic

Virbac Corporation

Preventic Topical Solution Medium Dog

Liquid

Imidacloprid 8.8%

Permethrin 44%

32589

Domestic

Virbac Corporation

Preventic Topical Solution Small Dog

Liquid

Imidacloprid 8.8%

Permethrin 44%

32590

Domestic

Virbac Corporation

Ectoshield Topical Solution Large Dog

Solution

Imidacloprid 9.1%

33173

Domestic

Can-Vet Animal Health Supplies Limited

Bugwacker Flea Protector 9

Solution

Imidacloprid 9.1%

33738

Domestic

Evergreen Animal Health, LLC

Evergreen II Spot on For Extra Large Dogs

Solution

Imidacloprid 7.12%

Permethrin 35.6%

Pyriproxyfen 0.36%

33739

Domestic

Evergreen Animal Health, LLC

Evergreen II Spot on For on For Large Dogs

Solution

Imidacloprid 7.12%

Permethrin 35.6%

Pyriproxyfen 0.36%

33740

Domestic

Evergreen Animal Health, LLC

Evergreen II Spot On For Medium Dogs

Solution

Imidacloprid 7.12%

Permethrin 35.6%

Pyriproxyfen 0.36%

33741

Domestic

Evergreen Animal Health, LLC

Evergreen II Spot On For Small Dogs

Solution

Imidacloprid 7.12%

Permethrin 35.6%

Pyriproxyfen 0.36%

33789

Domestic

Evergreen Animal Health, LLC

Parapet K9 Praventa 360 for Extra Large Dogs

Solution

Imidacloprid 7.12%

Permethrin 35.6%

Pyriproxyfen 0.36%

33790

Domestic

Evergreen Animal Health, LLC

Parapet K9 Praventa 360 for Large Dogs

Solution

Imidacloprid 7.12%

Permethrin 35.6%

Pyriproxyfen 0.36%

33791

Domestic

Evergreen Animal Health, LLC

Parapet K9 Praventa 360 for Medium Dogs

Solution

Imidacloprid 7.12%

Permethrin 35.6%

Pyriproxyfen 0.36%

33792

Domestic

Evergreen Animal Health, LLC

Parapet K9 Praventa 360 for Small Dogs

Solution

Imidacloprid 7.12%

Permethrin 35.6%

Pyriproxyfen 0.36%

Footnote 1

as of 11 February 2021, excluding discontinued products or products with a submission for discontinuation

Return to footnote 1 referrer

Footnote 2

for products co-formulated with other active ingredients, the most restrictive label amendments apply

Return to footnote 2 referrer

Table 2 Registered products containing imidacloprid in CanadaFootnote 1 cancelled as a result of re-evaluation
Registration number Marketing class Registrant Product name Formulation type Guarantee

25932

Commercial

Bayer CropScience Incorporated

Merit Solupack Insecticide

Wettable powder

Imidacloprid 75%

25933

Commercial

Bayer CropScience Incorporated

Merit Granular

Granular

Imidacloprid 0.5%

29130

Commercial

Adama Agricultural Solutions Canada Limited

Quali-Pro Imidacloprid 75 WSP Insecticide

Wettable powder

Imidacloprid 75%

29185

Commercial

Adama Agricultural Solutions Canada Limited

Quali-Pro Imidacloprid 0.5 Granular Insecticide

Granular

Imidacloprid 0.5%

29738

Domestic

SBM Life Science Corporation

BioAdvanced Science-Based Solutions Season Long Grub Control

Granular

Imidacloprid 0.25%

Footnote 1

as of 11 February 2021, excluding discontinued products or products with a submission for discontinuation

Return to footnote 1 referrer

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