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Label Review Training: Module 3: Special Issues, Page 38

Section 8: How should I review labeling claims?

Claims Associated With the Product Name

Product names cannot constitute false and misleading claims. An example of a misleading product name is “SAF–T–OIL,” because it makes an implied safety claim. The following outlines EPA's current guidance on false or misleading product names:

  1. Product names that express or imply a level of antimicrobial activity that is higher than demonstrated by testing are not acceptable.
  2. General superlative terms such as “super,” “superior,” and “ultra” no longer need to be qualified by the term “brand” in a product name. However, this determination still does not allow terms or claims like those which clearly imply heightened efficacy (e.g., “hospital strength,” &ldq professional strength,” etc.). (See Pesticide Registration [PR] Notice 93-6.)
  3. EPA is under no obligation to ensure registrants use the correct trademark (™ or ®) and copyright (©) symbols on labels. Registrants are encouraged to use the correct symbols.


For more information about claims associated with the product name, see Chapter 12, Section VI of the Label Review Manual.

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