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- Federal EPA
- State Registration
- Product Discontinuance
- Frequently Asked Questions
- Additional Information
Supplemental RegistrationsSupplemental 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 ProcessBoth Claire and the supplemental distributor have responsibilities:
- Both parties must enter into an agreement with one another
- Complete and file a Notice of Supplemental Distribution of a Registered Pesticide Product (EPA Form 8570-5) (PDF)(2 pp, 506k) with EPA, (you will need a Company EPA# for this) and
- Ensure that the supplemental product bears the identical label language apart from the exceptions listed at 40 CFR 152.132(d) (PDF) (1 pp, 131.94 k About PDF)
Two of the exceptions include the supplemental label utilizing a different product name and the supplemental distributor's name and address instead of the registrant's.
Refer to Chapter 9 for detailed instructions on how to submit an application for supplemental distribution of a pesticide product.
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.
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
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
- 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 firstname.lastname@example.org 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.
"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 UpdatesIn 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.
For Company Numbers: Adrienne Turner (email@example.com), 703-308-4983
For Official Address Changes: Kathleen O'Malley (firstname.lastname@example.org), 703-305-5411
Nicholas Georges email@example.com