Pesticide Labeling Questions & Answers - Labeling from Web Sites
If you don't find an answer to your question on this page, submit your question here. You may also use this form to report any problems you encounter with the Label Review Manual.
Provide your contact information if you need a reply. We may add your question to this page, if it is of general interest.
(Note: Contact your Pesticide Product Registration Ombudsman for specific label issues about a single product).
These answers are not intended to create significant new guidance or require any changes to previously accepted labeling. The Agency will contact registrants directly about how to correct problematic labels as appropriate. Changes to EPA accepted labeling will only be required in accordance with standard agency procedures. These answers are primarily based on federal law, regulations and policies implemented by EPA. States, tribes, territories, and other federal agencies may have additional requirements relevant to their jurisdictions.
- Advertising Claims
- Antimicrobial Claims
- Contract Manufacture
- Use Sites
- Definitions of Terms
- Distributor Product Labeling
- Exception to Use in a Manner Not Permitted (FIFRA Sec 2ee)
- Existing Stocks
- General Labeling
- Labeling from Web Sites
- Multiple Products Packaged Together
- NAFTA Labeling
- Pesticide Exemption (FIFRA 25B)
- Pictures and Logos
- Repacked Products
- Service Containers
- Subject to FIFRA
- Superlative Terms
- Supplemental Labeling (NOT distributor products)
One of our customers is requesting that we add a QR code to the product so that the retail customers can scan it and view a web page with complete info. Can we add the QR code, and do we do it by Notification? LC11-0436; 10.6.11
A Quick Response (QR) code that allows easy access to websites or other text from portable devices can be added to a pesticide label. With some listed exceptions for official government publications, written, printed or graphic matter that is referenced on a pesticide label is considered “labeling” as defined in FIFRA § 2(p)(1)(2). Therefore, if a QR code is added to a label, the content it references is considered labeling and is subject to review by the Agency.
If a URL to a web page is already on the label, then the addition of a QR code that takes customers directly to the same web page can be done through notification per PR Notice 98-10 Section II. H (23 pp, 242k, about PDF), which allows the use of graphics in conjunction with approved text to be added through notification. If the URL is not already present on the approved labeling, the QR code needs to be added by an amendment.
Currently pesticide users must use the label on the container, or use an official Supplemental Label (for example a new crop use was recently added). What is EPA's stance on growers downloading entire Section 3 labels from a web site such as CDMS, and using those directions? (LC07-0090)
EPA directs users to follow the use directions found on the label of the container and in any EPA-approved supplemental labeling of the pesticide they are applying that accompanies the pesticide. Labels acquired from web sites may not be the most current label or may conflict with the label on the container. Because the label on the container is the label that must be followed along with any EPA-approved supplemental labeling which must accompany the user at the time of application, users should not download entire section 3 labels for use.