Labels that do not require review

- With supplemental distributor labeling, EPA reviews the parent company’s labeling, but not the distributor’s labeling.
- Certain types of products are exempt from FIFRA because EPA determined them to be adequately regulated by another federal agency or of a character that is unnecessary to be subject to FIFRA.
Supplemental distributor labeling — This type of submission involves labels for a product that is registered to one company, but distributed by another company. The Environmental Protection Agency (EPA) reviews the parent company’s labeling, but not the distributor’s labeling. Supplemental distributor products are still subject to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). EPA can review distributor company names to ensure that they are not misleading.
Labels for products exempted from FIFRA by 40 CFR 152.20 and 152.25 — Certain types of products are exempt from FIFRA because EPA determined them to be:
- Adequately regulated by another federal agency, or
- 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, or
- 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), and
- Changing name or address of registrant.