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Label Review Manual
Chapter 17: Content/Net Weight Statement

Table of Contents
Chapters:
  1. Purpose of Manual
  2. What is a Pesticide?
  3. General Labeling Requirements
  4. Types of Label Reviews
  5. Ingredient Statement
  6. Use Classification
  7. Precautionary Labeling
  8. Environmental Hazards
  9. Physical or Chemical Hazards
  10. Worker Protection Labeling
  11. Directions for Use
  12. Labeling Claims
  13. Storage and Disposal
  14. Identification Numbers
  15. Company Name and Address
  16. Graphic & Symbols on Labels
  17. Content/Net Weight Statement
  18. Unique Product Labeling
  19. The Consumer Labeling Initiative and Pesticide Labels


On this page

  • I. Introduction
  • II. Location of Net Contents/Net Weight Statement
  • III. Types of Products/Measurement
  • IV. Expression of the Statement


    • I. Introduction

    The Net Contents/Net Weight statement indicates how much pesticide product is in the container and must appear on the pesticide label pursuant to FIFRA 2(q)(C)(iii). Usually draft labels include the phrase "Net Weight:” or "Net Contents:" as a means of identifying where the statement will actually appear on the final printed label. The applicable regulation at 40 CFR 156.10(d) does not require the term/heading "Net Weight" or "Net Contents" to be stated on the label. Even so, the Agency strongly recommends that the terms "Net Weight" or "Net Contents" be placed on the label because it describes the amount of pesticide product in the container as opposed to the total weight of the pesticide product plus the weight of the container.

    II. Location of Net Contents/Net Weight Statement

    There is no required location for the Net Contents/Net Weight statement. The preferred location is the bottom of the front panel below the company name and address. If the draft label under review shows the Net Contents/Net Weight statement in some other location, the reviewer should suggest that the statement be placed at the bottom of the front panel. The Net Contents/Net Weight should be exclusive of any wrappers or other materials. 40 CFR 156.1(d)(1).

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    III. Types of Products/Measurement

    1. Check the draft label to determine if the Net Contents/Net Weight statement is expressed correctly. See 40 CFR 156.10(d)

      1. Dry Formulations (includes solids or semisolids such as dusts, granulars, pelleted or tableted baits, wettable powders, microencapsulated product, impregnated materials). The net weight must be expressed as pounds or ounces.

      2. Liquid Formulations. The net contents must be expressed in terms of liquid measure at 68 F(20 C): gallons, quarts,

      3. Pressurized Products (includes gases and aerosols). The net contents must be expressed as pounds and ounces.

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    IV. Expression of the Statement

    Review the draft label to make sure that it meets the following requirements:

    1. Units of Measure. Conventional U.S. units of measurement are used on pesticide labels. Pesticide labels may also declare net contents in metric units (liters, kilograms, etc.), so long as U.S. units of measurement are declared. For example, "Net Contents: 1 gallon (3.785 liters)." It is not acceptable to declare net contents ONLY in metric units. Directions for Use are treated the same way. For example, in addition to expressing the application rate(s) in the required U.S. units of pound per acre, the registrant may also elect to express the application in equivalent metric units: kilograms per hectare.

    2. Expression of Net Contents. The Net Contents must be stated in terms of the largest suitable units. For example, for a package containing 26 ounces of pesticide product, the label must state: “Net Contents: 1 pound (lb.) 10 ounces” rather than “Net Contents: 26 ounces.”

    3. Consistency with Directions for Use. The Directions for Use on the label must not require a quantity of pesticide product that exceeds the Net Contents/Net Weight of the package. An example would be a granular product with the following label language: "Net Contents: 1 pound," that requires an application rate 5 lbs/acre. This problem often occurs with baits used to control rodents.

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