Label Review Training: Module 1: Label Basics, Page 20
Section 5: What are the types of labels and labeling?
Supplemental labeling includes labels that contain newly approved uses, use directions, or other instructions that have been added since the last accepted master label. These new uses and directions are incorporated into the EPA master label, but because they are not on those products already in the channels of trade, they are distributed with the product by the registrant or distributors. Because these are partial labels, they must include a statement referring the user to the product label for complete directions and precautions, and a statement that the labeling must be in the possession of the user. The user must follow the supplemental label, the product’s container label, and all other labeling that comes with the product in order to apply it in a way that reduces risk and maximizes efficacy.
The supplemental labeling must be submitted and stamped “accepted” by EPA prior to distribution. EPA requires that these labels include the following information:
- Misuse statement: “It is a violation of federal law to use this product in a manner inconsistent with its labeling.”
- “The labeling must be in possession of the user at the time of application.”
- “Read the label affixed to the container for [pesticide X] before applying.”
- “Use of [pesticide X] according to this labeling is subject to the use precautions and limitations imposed by the label affixed to the container for [pesticide X].”
- Product name.
- EPA registration number.
- Restricted use statement (if required).
Normally, supplemental labeling will be incorporated into the affixed label at the next printing of the product label or within 18 months. The Agency recommends an expiration date of 18 months after acceptance on supplemental labels. However, this might not be done in all cases, for example, if the directions for use are subject to continual, frequent change.
See example supplemental labeling below.
For more details about supplemental labeling, see Chapter 3, Section IV.D of the Label Review Manual.