Label Review Manual
Chapter 16: Graphics & Symbols on Labels

I. Introduction

Graphics or symbols in addition to written text are permitted on pesticide product labels if they are accompanied by explanatory text, are clear in their meaning to the reader, do not obscure or crowd required label language, and are not false and misleading or otherwise cause the product to be misbranded.  Symbols may not be used in place of required text.  Refer to the sections below for guidance in determining whether graphics and symbols are acceptable or unacceptable based on applicable regulatory standards.  Consultation with the PM/Team Leader and/or Branch Chief may be necessary. The regulations at 40 CFR 156.10(a)(5) provide examples of statements and representations that may be false and misleading; see also FIFRA 2(q)(1)(A) which provides that a pesticide is misbranded if its labeling bears “false and misleading” designs or graphic representations.

II. Acceptable Graphics & Symbols

1. Acceptable graphics and symbols on product labels should serve to enhance the understanding of the accompanying text.  Acceptable examples of graphics and symbols, which may be added by notification if they are not false or misleading (see PR Notice 98-10 for the procedure), include the following.  Note, however, that the label reviewer must carefully evaluate the graphics and symbols to ensure they are not potentially false or misleading and should not be added through notification.

   1. Diagrams of how to open product containers.
   2. Pictures illustrating proper pesticide use.
   3. Graphics which display spray patterns of nozzles and/or application patterns.
   4. Pictograms located near the precautionary labeling statements that illustrate the different exposure routes (oral, inhalation, and/or dermal) to pesticides. 
   5. Pictures consistent with the label text showing examples of places where the pesticide may be used, such as in a household or on a specific commercial site.
   6. Child hazard drowning pictogram and labeling (a picture showing a bucket with a child turned upside down in the bucket negated with the universal nonverbal symbol for negation: a circle with a diagonal slash through it).  The pictogram cannot be accompanied by the word "WARNING", as it may be confused with the human hazard signal word for the pesticide product.   To avoid such confusion the Agency recommends the registrants use the word “precaution” or “notice.”
   7. The “Mr. Yuk” symbol on the label and/or outer container of the pesticide product.  The “Mr. Yuk” symbol consists of a green frowning face with its tongue hanging out.  This symbol may be used with the Skull & Crossbones when the product is a Toxicity Category I product used in or around the home or pool where children may be present.
   8. Pictures illustrating appropriate protective gear.
   9. Kosher symbols.
   10. Hazardous Materials Identification System/National Paint & Coatings Association/National Fire Protection Association (HMIS/NPCA and NFPA) ratings systems for hazard codes.
   11. Use of a logo to indicate absence of chlorofluorocarbons (CFCs) in a pesticide product.  The logo must consist of the universal nonverbal symbol for negation - a red circle with diagonal red slash through the circle  with:
       1. wording as discussed in PR Notice 92-2 immediately next to the logo; and,
       2. text set in type size of at least 6 points (the minimum type size permitted on labels by 40 CFR 156.10(a)(2)).

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III. Unacceptable Graphics & Symbols

1. If the draft label under review contains graphics or symbols that violate FIFRA 12(a)(1)(F) and 2(q)(1)(A)  or the applicable regulations describing potential false and misleading statements in 156.10(a)(5), then the label reviewer must advise the registrant to remove these from the label.  Examples have included the following (note: these examples are based on case-by-case determinations and may not apply to every similar situation): 

   1. A food or flower pictured on a label which bears no directions for use on that food or flower.  For example, a picture of cherries may not appear on a label if the product is not registered for use on cherries, or a picture of roses may not appear on a label if the product is not registered for use on roses.
   2. Pictures of people using a product without the required personal protective equipment.  Pictures of users must be consistent with personal protective equipment (PPE) requirements on the label.  For example, if the label requires that the applicator wear full chemical-resistant coveralls with goggles, the label illustration cannot show a person wearing shorts and no protective eyewear.
   3. Pictures of a pest not claimed to be controlled by the product.
   4. Pictures that depict the fragrance of the product, except for antimicrobial products.
   5. Pictures depicting food or food contact utensils even in some cases where food-handling-area treatments are allowed on the label.  Directions for use generally require that food items and food contact utensils be covered or removed before the pesticide is applied.
   6. Pictures of persons applying pesticides in areas accessible to children, pets, and other non-target organisms when such products may only be applied in areas inaccessible to children.
   7. Pictures of children unless the product is registered for use on children or the product is registered for use in swimming pools.
   8. Pictures of candy.  Similarly, containers that look like food or candy have been prohibited.
   9. Symbols implying safety or non-toxicity, such as a medical seal of approval (caduceus).
   10. Pictures of residential use sites when the label limits use of the product to commercial or industrial sites.
   11. The Mobius Loop (a recycling symbol in the shape of three chasing arrows forming a triangle) or any other symbol on the printed label implying that the product could be recycled when in fact it cannot be.  If the packaging can be recycled, then it is appropriate for a recycling symbol to be shown in an inconspicuous location on the container or package with the word “package” printed near the Loop.
   12. The EPA logo or any other Agency logo which implies endorsement by a government agency, such as the Circle and Statement "In Compliance With WPS."
   13. Symbols which contain the words "Slow Release Nitrogen" and "Organic" are not permitted if the prominence of the symbol, large type size of the word "organic" and its position relative to the words "Slow Release Nitrogen" make it unclear whether the word "organic" refers to the fertilizer component or to the entire product.

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IV. Other Graphics and Symbols which are Acceptable

1. The following graphics and symbols are considered acceptable and may be ignored during, and are not part of, the label review. 

   1. The “Good Housekeeping Seal of Approval” is a limited warranty to consumers and promises to refund the purchase price or replace the product if defective.  While the Agency allows this symbol to be placed on products, the agency does not endorse the warranty message provided by this symbol.
   2. Department of Transportation symbols indicating the hazard and flammability of a particular pesticide product.
   3. Bar codes which allow for easier scanning of prices in retail stores.

V. Logos for Organic Pesticides

As discussed in Chapter 12 of this manual, if the criteria described in Pesticide Registration (PR) Notice 2003-1 are met, a pesticide product may bear the following phrases in logo format:

 “For Organic Production,”
 “For Organic Gardening,”
“For Organic Lawn Care,” and
“For Use in Organic Production.” 

Logos from other groups that review materials proposed for organic agriculture may also be considered (E.g. OMRI).  The reviewer needs to determine if this information is false or misleading.   Label reviewers should consult with the National Organic Program Liaison in the Biopesticides and Pollution Prevention Division for an evaluation of the product’s proposed labeling before approving any organic labeling or logos.