Pesticide Labeling Questions & Answers - NAFTA Labeling
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)
We have the same source of a technical grade product registered in both the US and Canada. The product is used to manufacture products in both Canada and the US. May the package (a large bag) have both the US and the Canadian label on it, the accepted US on one side of the bag, and the accepted Canadian label on the other? Would the Canadian label be considered "collateral labeling" and require EPA acceptance first? (LC08-0147, 1/31/08)
Generally, a pesticide package may not have both a U.S. and Canadian label on it because conflicting requirements between the two countries lead to conflicting labels which may mislead users. Section 2(p)(1) of FIFRA defines “label” as “the written, printed, or graphic matter on, or attached to, the pesticide or device or any of its containers or wrappers.” This definition encompasses all the written matter on a product and thus in the example described above, the Canadian label could not be distinguished from the U.S. label. Because the Canadian label would be part of the product’s U.S. label, it must be reviewed and approved by EPA and must meet all U.S. labeling requirements including a careful review of how the two formerly separate labels might conflict. In the case of NAFTA labels, there is a single NAFTA label which has been approved in both countries. EPA encourages registrants to develop a NAFTA label for products that are sold or distributed in both the U.S. and Canada because the format of NAFTA labels provides solutions for dealing with potentially conflicting labeling requirements. EPA also encourages registrants in this situation to consult with Canada’s Pest Management Regulatory Agency in addition to EPA. For more information on NAFTA labels see http://www.epa.gov/oppfead1/international/naftatwg/labels/implem-labels.htm.