• Master label, sub-label, supplemental distributor labeling, and supplemental labeling are the four types of pesticide labels and labeling.

There are four types of pesticide labels and labeling:

• Master label,
• Sub-label (split-label),
• Supplemental distributor labeling, and
• Supplemental labeling.

Master label

The master label displays the claims and directions for the approved uses of a given product and all associated required labeling. All other labeling for the product must not contain any text beyond that which is approved in the master label (with the exception of the supplemental label).

This label is filed with the Environmental Protection Agency (EPA) once it is stamped “accepted.”

Sub-label (split-label)

A sub-label or split-label displays the claims and directions for only a portion of the approved uses under a given master label. The label is complete, listing all of the required label elements, but the company may want the label displayed differently for marketing purposes. EPA allows registrants to distribute or sell a product under a sub-label or split-label provided that no changes would be necessary to the precautionary statements, use classification, or packaging of the product.

A sub-label or split-label only contains labeling text that also appears on the master label. When a sub-label is submitted with additions not on the accepted master label, a new master label containing all the uses currently approved under the product’s registration is required. Only the master label will be stamped “accepted.”

Supplemental distributor labeling

Supplemental distributor labeling includes labels for a product that is registered to one company but distributed by another company (sometimes referred to as a “sub-registrant”) under that company’s name. These labels must be the same as the labels for the registered product, with the following exceptions:

• Product name
• Name and address
• Registration number (EPA Reg. No. xxxx-xx-xxxx, where the third set of numbers refers to the distributor’s company number)
• Establishment

In addition, claims may be deleted, but new claims that differ from the parent label cannot be added to a distributor label.

The parent company must notify EPA before distribution by submitting a Notice of Supplemental Distribution (EPA Form 8570-5).

EPA does not receive or review supplemental distributor labeling, but EPA can review the distributor company names to ensure that they are not misleading. The parent company is responsible for ensuring that the supplemental distributor is in compliance with these requirements.

Supplemental labeling

Supplemental labeling includes labels that contain newly approved uses, use directions, or other instructions that have been added since the last accepted master label. These new uses and directions are incorporated into the EPA master label, but because they are not on those products already in the channels of trade, they are distributed with the product by the registrant or distributors.

These are partial labels, so they must include a statement referring the user to the product label for complete directions and precautions, and a statement that the labeling must be in the possession of the user. The user must follow the supplemental label, the product’s container label, and all other labeling that comes with the product in order to apply it in a way that reduces risk and maximizes efficacy.

The supplemental labeling must be submitted and stamped “accepted” by EPA prior to distribution. EPA requires that these labels include the following information:

• Product name
• EPA registration number
• Restricted use classification statement (if applicable)
• “It is a violation of Federal law to use this product in a manner inconsistent with its labeling.”
• “The labeling must be in possession of the user at the time of application.”
• “Read the label affixed to the container for [product name] before applying.”
• “Use of [product name] according to this labeling is subject to the use precautions and limitations imposed by the label affixed to the container for [product name].”

Normally, supplemental labeling will be incorporated into the affixed label at the next printing of the product label or within 18 months. The agency recommends an expiration date of 18 months after acceptance on supplemental labels. However, this might not be done in all cases, such as if the directions for use are subject to continual, frequent change.