Pesticide Labeling Questions & Answers - Contract Manufacture
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.
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(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)
Our company is looking at a repackaging project that involves receiving end-user household-type pesticides that have been returned to the retailer from which they were purchased. Assuming permission has been granted from the original registrant, can the product be repackaged and labeled with a trade name other than the original product/trade name without having to re-register the formulation? (LC06-0053)
A repackaged product may be labeled with a trade name other than the original product trade name without having to re-register the formulation only if the registrant has registered the alternate brand name for that particular product registration and your company is operating under a contract with the registrant that allows you to relabel with an alternate brand name. In addition, repackaging must occur at a registered establishment in accordance with 40 CFR Part 167.
- Is it true that all product produced at a contract manufacturer should carry a statement 'Produced for Company X? Or since the contract manufacture is working for the registrant, is the 'producer' really the registrant - meaning that the label does not need to carry the 'Produced for Company X'? (LC06-0022)
As stated in the Code of Federal Regulations section 156.10(c) "If the registrant's name appears on the label and the registrant is not the producer, or if the name of the person for whom the pesticide was produced appears on the label, it must be qualified by appropriate wording such as "Packed for * * *," "Distributed by * * *," or "Sold by * * *" to show that the name is not that of the producer."
In this case, the registrant is not the producer, irrespective of the contract manufacturing arrangement. The contract manufacturer is the producer of the pesticide, and therefore the registrant's name must be qualified with either the statement "Produced for * * *" or "Manufactured for * * *."