Label Review Manual
Chapter 15: Company Name and Address

I. Introduction

The company name and address of the registrant, the producer, or the person for whom the product was produced must appear on the pesticide product label.  40 CFR 156.10(a)(1)(ii). For the purposes of this Chapter, the detail required for company name and address is, at a minimum, the company name or qualified company name and the address (including street address and /or P. O. Box plus ZIP code, or unique ZIP code) of the location at which a particular organization or person may be found or reached.

II. Company Name

1. Location and Size

   The name and address must be displayed prominently and within the range of type size that is required for all label text. 40 CFR 156.10(a)(2).  The company name and address may be placed anywhere on the label, however; the preferred placement for the company name and address is on the front panel.

2. Qualifying a Company Name
   
   

   When the registrant’s name appears on the label and the registrant is not the producer of the product, the registrant’s name must be qualified by phrases such as “Manufactured for…” or “Produced for…” to show that the registrant is not the producer of the product.  40 CFR 156.10(c). 

   The need to qualify the name of a non-producer company also applies to pesticide products distributed under a supplemental registration agreement under 40 CFR 152.132 (i.e., “distributor agreement”). If the distributor is not the producer and the distributor name appears on the label, the name and address on the supplementally registered or “distributor brand” pesticide product must be qualified by phrases such as “Manufactured for...” Distributed by...” or “Available exclusively from...”              

   A company name appearing on the label without a qualifying phrase, such as those listed above, shall be considered as the name and address of the producer.  40 CFR 156.10(c).

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III. Telephone Numbers

The Agency encourages each registrant to include a company telephone number or toll‑free hotline number along with its name and address.  This number can be used by the pesticide product user to obtain additional product information.  Registrants may also include the National Pesticide Information Center (NPIC) hotline number for emergency information on the pesticide product label.  The NPIC number, alone or along with a company phone number, should be placed on the front panel of the pesticide product label using the following statement:

“For information on this pesticide product (including health concerns, medical emergencies, or pesticide incidents), call the National Pesticide Information Center at 1-800-858-7378, Monday through Friday, 9 a.m. to 5 p.m. After 5:00 p.m. call your poison control center at 1-800-222-1222.”

Note:  The National Pesticide Information Center (NPIC) was previously called the National Pesticide Telecommunications Network (NPTN).

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IV. Foreign Registrants

All applicants for pesticide registrations must provide a U.S. address for correspondence.   40 CFR 152.50(b)(2).  All correspondence concerning the pesticide product or any subsequent registration actions will be mailed to the address of record in the U.S. for foreign registrants. Generally a registrant not located in the United States will designate an authorized agent who resides in the United States.  See 40 CFR 152.50(b)(3).   When a U.S. agent is designated, the agent’s U.S. address is considered to be the U.S. address of record for the foreign registrant.

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V. Name of Record

In order to accurately track pesticide registrations the Agency must be able to link company names appearing on product labels with company names appearing on registration documents. Therefore, if a company changes its label to reflect that it is “a division of”, “a subsidiary of” or “doing business as” (DBA) another company, the Agency asks that the company also change its registration documents on record at the same time.

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VI. Company Name and Address Changes

Registrants are required to inform the Agency when there are changes to its company’s name or address.  40 CFR 152.122.  If a company changes its name or address, it must inform the Agency of the change by sending a letter to the Document Processing Desk (Distribution Code COADR), Office of Pesticide Programs, 7504C, U.S. Environmental Protection Agency, Ariel Rios Building 1200 Pennsylvania Ave. NW, Washington, D.C. 20460-0001.  This allows the Agency to accurately track ownership of pesticide registrations, which is critical to agency oversight of pesticide products.  In practice, the Agency allows a registrant to start using the new name as soon as EPA approves the change.  A registrant may use the existing label with the old name label until the next label printing or for 18 months, whichever comes first.  40 CFR 152.130.  If the registrant is also a producer, the registrant must also inform the Office of Enforcement and Compliance Assurance (OECA) (for foreign Establishments) and the EPA Regional Office where the company headquarters is located (for domestic Establishments) of the change of address in order to meet its obligations under Section 7 of FIFRA and 40 CFR Part 167.

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