Ways to Obtain Assistance on Pesticide Labeling Issues
The label on a pesticide package or container and the accompanying instructions are a key part of pesticide regulation. The label provides critical information about how to handle and safely use the pesticide product and avoid harm to human health and the environment. It has been said that “The label is the law.” This means that using a pesticide in a manner that is inconsistent with the use directions on the label is a violation of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and can result in enforcement actions to correct the violations.
EPA reviews the product label as part of the licensing/registration process for pesticides. The Office of Pesticide Programs' (OPP) Label Review Manual and various Pesticide Registration (PR) Notices provide guidance to companies who write, and OPP staff who review and ultimately approve, product labels.
Pesticide product manufacturers, applicators, state regulatory agencies and other pesticide stakeholders often raise questions or issues about pesticide labels. The Pesticide Product Registration Ombudsmen are responsible for addressing questions that are specific to a particular product (see examples of such questions below). Other questions might relate to multiple products or address inconsistencies among product labels. EPA has established a process for dealing with such broad, cross-cutting questions (see explanations below). Before submitting an issue or question, please see if it has already been addressed in:
- the list of Pesticide Labeling Questions & Answers or
- other committee resources:
Contact the Pesticide Product Registration Ombudsman for specific label issues that:
- Are limited to a specific product and the question has no broader implications for other products.
- Deal with an enforcement case.
- Are related to a case in litigation.
- Deal with the status of a pending FIFRA registration action.
- Address unregistered pesticides, FIFRA Section 18 emergency exemptions, Experimental Use Permits, Minimum Risk Pesticides under the FIFRA section 25(b) exemption, etc.
Use the Label Consistency Question Form for cross-cutting issues that are:
- Generic to all product labels.
- Germane to a type of pesticide (i.e., antimicrobials, insecticides, etc.).
- Relevant to a broad range of use sites.
- Related to a specific crop (that might be on many labels).
- Relevant to a class of pesticides.