Pesticides Information

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Federal EPA
Pesticide Registration Manual:

View the entire manual and other resources at http://www.epa.gov/pesticides

Supplemental Registrations

Supplemental registration allows a company to market an already-registered EPA product under its own company and brand name. For example, Claire insecticide, disinfectant and germicidal products are available for supplemental registration using a distributor’s company name, logo, label design (within EPA guidelines) and unique product name.

The Process

Both Claire and the supplemental distributor have responsibilities:


Refer to Chapter 9 for detailed instructions on how to submit an application for supplemental distribution of a pesticide product.

State Registration

EPA-registered products must be registered in each state where the products will be sold or used. Every state has unique requirements. For your convenience, there is a central website that links to all state pesticide regulatory agencies http://npic.orst.edu/reg/state_agencies.htm

Once the product is registered in a state, your company will receive a renewal request annually. It is the company's responsibility to renew the registration annually or notify the states of discontinuance.

Discontinuing a Registered Product

When a company discontinues the sale of a product, whether in one state or in all registered states, it is the company's responsibility to notify each state.

Each state has its own policy. Typically, discontinuance fees are the same cost as annual renewal fees. Depending on the state requirement, a company must pay discontinuance fees for 1 to 3 years.

To find out the policy and fees for each state, visit http://npic.orst.edu/reg/state_agencies.htm


Frequently Asked Questions

What is an EPA Company Number?

A Company Number is a unique identifier assigned to a company that registers a pesticide, including insecticides, disinfectants, germicidals, with the U.S. Environmental Protection Agency (EPA).

How do I get an EPA company number?

Your company (the supplemental distributor) must submit a signed letter to the EPA on your company's letterhead. For complete details, click here and follow the procedures: How to Obtain a Company Number and Register an Official Address (PDF). Please note, there are additional requirements for non-U.S .-based companies.

What is the cost to obtain an EPA company number?

There is no cost to establish a company number. However, when the product is registered in states where it will be sold or used, there are fees charged by each state.
View the current fees for each U.S. state http://npic.orst.edu/reg/state_agencies.html

Where do I request a company number?

Detailed information is available at How to Obtain a Company Number and Register an Official Address (PDF)

How does my company report changes in company name, address or agent to the EPA?

Changes to any of the following must be reported to the EPA

  • Company name
  • Address
  • Withdrawal of an agent
  • New Agent
  • Contact information

Refer to How to Obtain a Company Number and Register an Official Address (PDF) for details.

I'm confused! What are the steps in becoming a supplemental distributor?

Don't worry! Claire will help you with the process. Contact Nicholas Georges at ngeorges@plzaeroscience.com with any questions you may have.

When you receive you EPA company number, follow these steps:

  • Claire completes and forwards the required 8570-5 form for your signature
  • Your company's representative signs the form and returns it to Claire by mail to the attention of Nicholas Georges
  • Claire forwards completed form to the EPA
  • EPA sends your company a stamped and approved copy of the form for your company's records
  • You register the product in the states where it will be sold and can begin sales per each states policy

What happens if my company no longer wants to sell a product in a particular state?

When a company discontinues the sale of a product, whether in one state or in all registered states, it is the company's responsibility to notify each state.

Each state has its own policy. Typically, discontinuance fees are the same cost as annual renewal fees. Depending on the state requirement, a company must pay discontinuance fees for 1 to 3 years. To find out the policy and fees for each state, visit http://npic.orst.edu/reg/state_agencies.htm

Can I include my company's website address on the product label?

If a company has their website address or a QR code on the product label, EPA considers the content of the website or the QR information to be part of the product label. The EPA can bring enforcement actions and apply potential fines if the information is not consistent with the content of the product label.

To protect Claire and our customers, it is our policy to not allow website addresses or QR codes on product labels.

Do I need to do 6(a)(2) reports?

We place our emergency number on all the labels and have a service that handles the calls and evaluates the severity, frequency, etc... to determine if a 6(a)(2) report is necessary for a product. We will file a report if necessary.

 Additional Information

Claire Translation Policy: Whenever a translation is desired for a portion of a label, then the minimum additional translation on the label is for the name of the product on the front and the back panel hazard text to be translated. In addition it should be recommended that the principle hazard warnings on the front and the product directions on the back be translated. If there is not sufficient room on the label or if the customer does not want the principle hazard and directions translated, then the following statement must be added to the front of the label in the language and in English following it: Example "Si usted no entiende la etiqueta, busque a alguien para que se la explique a usted en detalle. (If you do not understand the label, find someone to explain it to you in detail.)" We know that this policy may not cover every situation that is possible. In the event that we encounter special circumstances we will handle them on a case by case basis.

Label Updates

In the event that your pesticide label changes, below is the cover letter that we will send with it explaining your responsibility to notify the states.

When EPA mandates a label change, then the new label must be used on product within 12 months of the mandate or at the next printing of the labels or litho cans whichever occurs first. Many times we make the label changes on demand which means when they are needed in order to print labels for a product order. As you can see from the letter above, this means that some states must be notified soon after you receive the new label.

Contacts

EPA Contacts:
For Company Numbers: Adrienne Turner (turner.adrienne@epa.gov), 703-308-4983
For Official Address Changes: Kathleen O'Malley (omalley.kathleen@epa.gov), 703-305-5411

Claire Contact:
Nicholas Georges ngeorges@plzaeroscience.com