In January 2020, Copper Development Association (CDA) elected not to renew its EPA FIFRA public health registrations for antimicrobial copper alloys (EPA Reg. Nos. 82012-1 to 82012-7). This action does not impact the ability of companies with active “Me-Too” EPA registrations and their supply chain partners to continue offering EPA-registered antimicrobial copper alloy materials and products. CDA’s position is supported by the following principles:
- CDA is a not-for-profit industry trade association that does not manufacture or sell any physical products. EPA registrations are traditionally held by commercial entities with antimicrobial product sales revenues that offset annual registration fees.
- CDA members that produce copper alloy materials and products advertised with antimicrobial public health claims continue to maintain and renew separate and independent “Me-Too” EPA registrations at the federal and state level. “Me-Too” registrations are secured by licensing the use of CDA’s proprietary dossier of efficacy testing and toxicological data.
- CDA members with “Me-Too” registrations may continue to seek amendments to their independent registrations (e.g. for additional claims) using the existing CDA database, or by generating their own new data to support the desired amendments.
- CDA continues to execute its EPA-mandated Stewardship Plan which includes maintaining this website. CDA remains committed to fulfilling its Stewardship responsibilities indefinitely which were established to protect consumers and to educate the marketplace about the proper use and care of antimicrobial copper alloy materials.
- CDA maintains an active dialog with its EPA-registered member companies to support their respective Stewardship efforts which are reflected in antimicrobial copper alloy product labels and marketing collateral.
- There is no specific EPA provision or regulation that requires CDA to maintain its primary registrations to support “Me-Too” registrations secured by independent businesses.
- CDA is an independent source of precompetitive technical and market information on copper and copper alloy materials and products, including antimicrobial applications.