Label Review Training: Module 1: Label Basics, Page 23

Section 6: Which labels require review?

Labels That Do Not Require Review

The following do not require EPA review:

No.	Labels	Requirement
1	Supplemental distributor labeling	As discussed in Section 5 of this module, this type of submission involves labels for a product that is registered to one company, but distributed by another company. EPA reviews the parent company's labeling, but not the distributor's labeling. Supplemental distributor products are still subject to FIFRA. EPA can review distributor company names to ensure that they are not misleading.
2	Labels for products exempted from FIFRA by regulations at 40 CFR 152.20 and 152.25	Certain types of products are exempt from FIFRA because EPA determined them to be 1) adequately regulated by another federal agency, or 2) of a character that is unnecessary to be subject to FIFRA, such as insect pheromones or products containing only certain listed ingredients EPA determined to pose minimum risks.
3	Labels for modified products requiring notification and non-notification	This type of submission involves product modifications that do not require EPA approval. These modifications must have no potential to cause unreasonable adverse effects to the environment. Some of these modifications can be made simply by notifying EPA (known as notification). Examples include: Adding or changing alternate brand names. Changing primary product name. Changing symbols and graphics (except skull and crossbones). Other modifications may be made without notifying EPA (known as non-notification). Examples include: Correcting typographical and printing errors. Changing package size and net contents (with some exceptions). Changing name or address of registrant.

No.

Labels

Requirement

Supplemental distributor labeling

As discussed in Section 5 of this module, this type of submission involves labels for a product that is registered to one company, but distributed by another company. EPA reviews the parent company's labeling, but not the distributor's labeling. Supplemental distributor products are still subject to FIFRA. EPA can review distributor company names to ensure that they are not misleading.

Labels for products exempted from FIFRA by regulations at 40 CFR 152.20 and 152.25

Certain types of products are exempt from FIFRA because EPA determined them to be 1) adequately regulated by another federal agency, or 2) of a character that is unnecessary to be subject to FIFRA, such as insect pheromones or products containing only certain listed ingredients EPA determined to pose minimum risks.

Labels for modified products requiring notification and non-notification

This type of submission involves product modifications that do not require EPA approval. These modifications must have no potential to cause unreasonable adverse effects to the environment. Some of these modifications can be made simply by notifying EPA (known as notification). Examples include:

Adding or changing alternate brand names.
Changing primary product name.
Changing symbols and graphics (except skull and crossbones).

Other modifications may be made without notifying EPA (known as non-notification). Examples include:

Correcting typographical and printing errors.
Changing package size and net contents (with some exceptions).
Changing name or address of registrant.

Resources

For more information about labels that do not require review, see Chapter 4, Section II of the Label Review Manual.
For more information about products that require notification and non-notification, see PR Notice 98-10.

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