EPA has announced a new process whereby Gold Seal letters will be issued electronically with the insertion of a seal that is digitally rendered rather than embossed. The electronic process for issuing Gold Seal letters was developed by OPP staff in response to the challenges of working remotely during the ongoing COVID-19 pandemic restrictions.
The Gold Seal letter certifies that a product being exported is legally registered with EPA in the United States. Gold seal letters are covered by PRIA category (M006) with a 30-day processing time (in addition to the 21-day front end screen applicable to all PRIA product actions). Due to the low fee (i.e., $291 in FY 2020-21 for up to five letters of certification for one actively registered product) and short one-month turnaround time, Gold Seal letters are not eligible for small business waivers, nor are distributor products eligible for Gold Seal letters. To obtain a Gold Seal letter, a company must submit a written request to the Agency identifying the company name, EPA Registration Number, and the country to which the product will be exported. Gold Seal letters will be emailed to companies in digital form rather than physically mailed in paper form. The letters will be signed electronically by the product managers, consistent with signature practices for other regulatory actions such as notifications, amendments, petitions, new uses, and new product registrations.
OPP staff expect that the electronic system will allow for quicker processing and better tracking of Gold Seal submissions within EPA. OPP staff report that during the transition from a paper to electronic system, a backlog of as many as 150 Gold Seal actions awaiting action was created. This backlog, however, has now been eliminated.
Further details on how to request a Gold Seal certificate letter, including information on how registrants should present the letters to the U.S. Department of State when authentication is needed, is available on EPA’s web site and may be accessed by clicking here. Posted on the Agency’s web site is an example of of a digital Gold Seal letter.