Are you sure that the EPA requires efficacy testing for aquatic herbicides?
"Are there any data requirements for making plant health and yield increase claims on a pesticide label? LC09-0271; 6.26.09
Currently there are no data submission requirements specified for claims related to plant health or yield increases. EPA considers these types of claims to be efficacy claims and does not routinely require applicants to submit efficacy data for pesticides intended to control plant pathogens, non-public-health insect pests or weeds."
