Standard build a bear packaging

Standard build a bear packaging DEFAULT

How to Ship Stuffed Animals and Plushies

With COVID continuing to wreak havoc on our social practices, many of us are struggling to feel connected with our friends and families. Step up your virtual hugs by sending out stuffed animals to your loved ones! Toy businesses are booming with all the kids (and adults) stuck at home, so learning how to ship stuffed animals and plushies is important to those businesses as well. Whether it&#;s to a customer or a loved one, learn how to send a smile and a squeeze here.

Package Your Stuffed Animals Thoughtfully

For a basic, smaller-size stuffed animal shipment, all you&#;ll really need to worry about is protecting your item. You can do this either by using a waterproof poly mailer or wrapping the toy in plastic wrap. The only thing after is to add bubble wrap around the stuffed animal to protect it during transit.

Anything beyond this requires a little more thought, but that&#;s okay! Here are the ways you can level up this basic shipment to fit your needs:

  • If you&#;re shipping out a bulkier plushy, consider popping it into a space-saver ziplock to make it more compact. This will only really matter if you&#;re shipping something weighing over a pound. If you&#;re under a pound, you&#;ll just need to find a poly mailer that fits the item.
  • If you&#;re shipping out a large amount of stuffed animals, a box might be a better way to ship. Basically, you&#;ll line a box with bubble wrap, and toss your toys in from largest to smallest. Add a layer of bubble wrap at the top and seal your box with waterproof packing tape. Depending on what you&#;re sending out, consider poking some small holes into your box to allow air circulation during transit.
  • If you&#;re shipping out anything of high value or with a battery compartment, do not skimp on packaging! Be sure to use a waterproof bag with bubble wrap, then put that into a box for extra protection.

The main thing to worry about is packaging your stuffed animal in a way that protects the toy without damaging it.

Pro Tip: If you&#;re shipping out larger boxes, watch out for dimensional weight charges! If you&#;re shipping anything weighing more than a pound and larger than your standard teddy bear, be sure to double-check your shipment for dimensional weight and vacuum pack your shipments to reduce its size. The smaller your package is, the more likely you&#;ll be to avoid any dimensional charges, which can be very expensive.

Match a Shipping Service to Your Stuffed Animal Shipment

When choosing a shipping carrier, you&#;ll be best shipping stuffed animals and plushies with the Postal Service. USPS is the premier carrier smaller, lighter shipments, and will always offer the cheapest shipping rates. There are a couple of different USPS service options to consider here, which do have an impact on what kind of packaging you&#;ll use for your shipment:

  • First Class Package Service will be great for anything less than 18&#; in any direction and weighing less than a pound. For these shipments, a bit of bubble wrap and a poly mailer will do the trick.
  • Priority Mail will be the next option for anything over a pound. The only thing to watch for is larger, more lightweight shipments. These might incur dimensional weight charges after you buy postage, so the best way to avoid this is by vacuum sealing your larger stuffed animals and keeping your package as small as you can make it.

In any case, keep in mind that a standard box will weigh between ounces. If your item is hovering below a pound, opt for a poly mailer to meet First Class Package Service requirements. Anything over a pound will ship well with Priority Mail, at which point using a box won&#;t affect the cost of postage for your shipment.

Use Online Shipping Software to Save the Most Cash

We chatted about First Class Package Service and Priority Mail above, but there&#;s lot more to those services if you choose to use online shipping software to buy postage for your stuffed animal shipments!

With First Class Package, the first thing to note is that you can ship up to 16 ounces if you&#;re using online software that allows access to commercial discounts through USPS. On top of that higher limit, you can save up to 59% on postage. What&#;s not to like there?

Priority Mail is a little more juicy here, with a whole new service available with the help of online shipping software: Priority Mail Cubic. This service is based on the dimensions of your shipment, rather than the weight. This will be a huge help if you ship small, heavier plushies, like Beanie Babies for instance (remember those?). Priority Mail Cubic will save you up to 90% on what you pay at the Post Office. On top of that, you&#;ll save up to 40% on what you pay for regular weight-based Priority Mail Services by buying postage online.

One more thing &#; with online shipping software, you can schedule contactless, free pickups from the comfort of your home. This way, you can take care of yourself and continue to run your business or connect with your loved ones. All that said, buying postage online is a huge tool to use during this time of quarantine and social-distancing. With these savings through USPS, you can send out boxes of happiness to those in your life without breaking the bank.

When in Doubt, Take it Step by Step

This guide is stuffed (stuffed&#;animals, get it?) with information, but as long as you take things step-by-step, you&#;ll pick this up quick. Just remember to think about what you&#;re shipping and the service you&#;d like to use, and the way you package your shipment will naturally fall into place.


Pesticide Labeling Questions & Answers

These answers are not intended to create significant new guidance or require any changes to previously accepted labeling. The Agency will contact registrants directly about how to correct problematic labels as appropriate. Changes to EPA accepted labeling will only be required in accordance with standard agency procedures. These answers are primarily based on federal law, regulations and policies implemented by EPA. States, tribes, territories, and other federal agencies may have additional requirements relevant to their jurisdictions.

HINT: Use the browser search function (control+F) to locate keywords related to the issue you are researching.

If your question is not answered here, use the labeling consistency question form to submit a question. See guidance on how to obtain assistance with labeling issues.

  1. Advertising claims
  2. Antimicrobial claims
  3. Chemigation
  4. Contract manufacture
  5. Use sites
  6. Definitions of terms
  7. Distributor product labeling
  8. Exception to use in a manner not permitted (FIFRA Sec 2ee)
  9. Existing stocks
  10. General labeling
    1. Use classification
    2. Product name
    3. Name and address of producer/registrant
    4. Product registration
    5. Establishment
    6. Misuse statement
    7. Ingredient statement
    8. Precautionary
    9. Environmental hazards statement
    10. Directions for use
    11. Worker protection statement
    12. Storage and disposal
    13. Unattached or attachment issues
  11. Labeling from websites
  12. Miscellaneous
  13. Multiple products packaged together
  14. NAFTA labeling
  15. Notifications
  16. Packaging
  17. Pesticide exemption(FIFRA 25B)
  18. Pictures and logos
  19. Repacked products
  20. Service containers
  21. Subject to FIFRA
  22. Superlative terms
  23. Supplemental labeling (NOT distributor products)
  24. Termiticides
  25. Import/Export

1. Advertising Claims

Can a manufacturer advertise that their product does not contain a certain active ingredient (e.g., “DEET free”)? LC; 10/14/21 

Claims such as “free of [active ingredient]” or “contains no [active ingredient]” may constitute misbranding and may need to be removed. EPA is concerned that users might understand these types of statements to be safety claims. This could give users the impression that products without a certain active ingredient are safe or safer than products with the active ingredient, which may be false or misleading. Safety claims are considered false or misleading statements that constitute misbranding under 40 CFR (a)(5)(ix) and (x). Misleading comparative claims about the safety of the product versus other products also constitute misbranding under 40 CFR (a)(5)(iv) and (vii). These claims are therefore disallowable under FIFRA sections 2(q)(1)(A) and 12(a)(1)(E).  

Consumers can readily determine if a pesticide product contains an active ingredient (e.g., DEET) by reviewing the active ingredients listed on the front panel of the label in accordance with 40 CFR (g). Because all active ingredients must be listed, the absence of an active ingredient in the ingredient statement would indicate it is not in the product.

If my clear waterbased roof coating contains the EPA-recommended maximum dosage of an already EPA-registered fungicide/mildewcide, can I claim on my marketing pieces that my coating contains an EPA-registered fungicide/ mildewcide as long as I do not specify the kinds of fungus/ mildew it prevents growth of on the film? Also, would I need to list that EPA-registered fungicide/ mildewcide on my label and literature? LC; 08/30/13

40 CFR (a) provides an exemption from the requirements of registration for qualified treated articles or substances. The exemption provision states that “an article or substance treated with, or containing, a pesticide to protect the article or substance itself (for example, paint treated with a pesticide to protect the paint coating, or wood products treated to protect the wood against insect or fungus infestation), [is exempt] if the pesticide is registered for such use.”

If your product otherwise qualifies for the treated article exemption, you may make claims about the pesticide in your product so long as each of the requirements cited above continues to be met and none of your claims or statements state or imply in any way that the pesticide provides any benefit beyond mere protection of the treated product itself.

If any of the above-cited requirements are not met or if any of the statements or claims state or imply in any way that the pesticide is protecting more than the treated product itself, the treated product would need to be registered.

May a FIFRA-exempt 25(b) label state:“Bedbugs are small parasitic insects that feed on the blood of humans. Useto eliminate infestation."? LC; 08/02/12

Pesticides qualify for an exemption from registration requirements as described at 40 CFR (f) [promulgated under the authority of FIFRA 25(b)] if they:

  • contain only active ingredients listed at 40 CFR (f)(1);
  • contain only permitted inerts as described in 40 CFR (f)(2); and
  • meet all of the conditions listed in 40 CFR (f)(3).

One of the conditions in 40 CFR (f)(3) is that such product "must not bear claims either to control or mitigate microorganisms that pose a threat to human health, including but not limited to disease transmitting bacteria or viruses, or claims to control insects or rodents carrying specific diseases, including, but not limited to ticks that carry Lyme disease.” While the Agency does consider bedbugs to be pests of significant public health importance (see PR Notice ), the claim “bedbugs are small parasitic insects that feed on the blood of humans. Use to eliminate infestation” does not indicate that bedbugs carry specific diseases and therefore does not itself disqualify a pesticide product from the exemption.

Another condition in 40 CFR (f)(3) is that the pesticide labeling not include any false and misleading statements. To meet this condition, all claims, such as a claim that the product will eliminate bedbug infestation, should be substantiated in accordance with the Federal Trade Commission’s guidelines for substantiating advertising. More information on FTC's guidelines. 

Does the Agency distinguish between repellency claims and resistance claims for purposes of determining whether a product is a pesticide? For example, if a mulch product claimed to “resist insects” would that constitute a pesticide claim? If “resists insects” is considered a pesticide claim would the mulch in this example require registration prior to being offered for sale? LC; 05/24/12

FIFRA section 2(u) defines pesticide, in part, as “any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest.” As explained in 40 CFR (a), when a person distributes or sells a substance with claims that it can or should be used for a pesticidal purpose (e.g. preventing, destroying, repelling or mitigating pests), the substance must be registered unless it has otherwise been exempted from the requirement for registration in 40 CFR Subpart B.

Product claims are considered to be pesticidal if they are synonymous with “preventing, destroying, repelling, or mitigating pest.” Claims are judged on a case-by-case basis considering the context in which they are made, but it is likely that a claim that mulch “resists insects” would be considered a pesticidal claim because "resisting" pests is similar to "preventing, destroying, repelling or mitigating" pests.

One exception is products containing no toxicants that are intended to exclude pests only by providing a physical barrier against pest access are not considered pesticides because EPA has determined they are not intended for a pesticidal purpose. 40 CFR (c). Unless the mulch fits this exception or is otherwise exempt, it would need to be registered to be sold or distributed in the United States. For more detail on what pesticide products are exempt from registration requirements see Pesticide Registration Manual: Chapter 1.

The Department of Pesticide Regulation's Legal Office is currently reviewing the label of a pool filter product that contains diatomaceous earth. The company is claiming that the product is not a pesticide. However, their packaging states the product "removes dirt, harmful pathogens and microbes down to 2 microns." On one hand, the diatomaceous earth filter could be seen as a physical barrier, which would not require registration. On the other hand, the reference to "harmful pathogens" seems to be getting into the arena of a public health claim. Would U.S. EPA consider this product to be a pesticide requiring registration? LC; 10/6/11

The label statement “removes pathogens and microbes down to 2 microns” is a pesticidal claim. In order for the product to qualify as a barrier product under 40 CFR (c), the product the following conditions must be met:

  • The product is not intended to prevent, destroy, repel, or mitigate a pest, or to defoliate, desiccate or regulate the growth of plants.
  • The product or article does not make a pesticidal claim on the labeling or in connection with sale and distribution.
  • The product is intended to exclude pests only by providing a physical barrier against pest access, and contains no toxicants.

Based on the criteria listed above, this product does not appear to qualify as a barrier because it makes a pesticidal claim and is intended to mitigate a pest (the pathogens) . The product would also not be classified as a pesticidal device since it contains a substance “diatomaceous earth,” which is contained in a number of EPA registered products. Therefore, this product would be a pesticide and subject to regulation under FIFRA.

Can you put on the label of a registered pesticide a statement that is a "new and improved" or "next generation" version of a previously unregistered pesticide? LC; 05/07/10

Historically, EPA has allowed the claim "new" to be used on labeling for a period of six months following approval of a new registration. "New" has not historically been allowed as part of a product name. Terms or marketing claims such as "improved," "next generation," etc. are reviewed on a case-by-case basis to determine whether they are false or misleading and therefore not allowable. A review of the complete label is needed to determine the acceptability of such terms. See Label Review Manual, Chapter 12, Section VII.

May a label contain advertising for a registrant's other products? For example, may it show pictures of fertilizer and other pesticide products the registrant distributes and say "For More Lawn and Garden Products visit. . .(website)"? LC; 11/4/09

Yes, this is allowed as you have described so long as the reference to other products is (1) not false or misleading and (2) does not detract from required label information. See FIFRA 2(q)(1)(A); (2)(q)(1)(E. If either condition is not met, the product is misbranded and cannot be sold or distributed. FIFRA 12(a)(1)(E). To avoid a product being misbranded, EPA suggests the following guidance for registrants when adding references (including pictures and/or website addresses) to other products including pesticides on a label:

  • It should be very clear that those products are separate and distinct from the subject product, ie. such references to these other products should be clearly distinct from the required labeling of the subject product. It is especially important that reference to other products does not distract users from reading the labeled product's Directions for Use.
  • The advertising should not contain mandatory language saying another specified product must be used in order to achieve control/relief. Any requirement that products be used in combination to achieve efficacy for a pesticide product must be part of the Directions for Use and must be evaluated by EPA as part of the granting of a registration.
  • The registrant should understand that any reference to a website makes that website labeling and therefore subject to more searching EPA review than if it were not referenced.  Future versions of a website referenced on a label will also subject to the same review, though at this time the Agency does not require notification or approval of such changes.

Please note that distributor products are not allowed to add claims to the label that have not been approved on the parent product's label. 40 CFR (d). Therefore, a distributor may not add advertising for its other products unless such advertising is also on the parent product's label.

A lawn care operator (LCO) has advertising in a local newspaper advertising its service, claiming mosquito and other pest elimination from customer yards. At the bottom of the ad, it states "Safe." Is stating a service using a registered product is “safe” in an advertisement a violation of FIFRA or its associated regulations? (LC)

Section 12(a)(1)(B) of FIFRA makes unlawful any sale or distribution of “any registered pesticide if any claims made for it as a part of its distribution or sale substantially differ from any claims made for it as a part of the statement required in connection with its registration.” The statement required for registration must include “a statement of all claims to be made for [the pesticide].” FIFRA 3(c)(1)(C).

EPA generally has not allowed the use of “safe” in labeling because it has been considered to be false or misleading. 40 CFR § (a)(5)(ix). False and misleading claims make a product misbranded and sale and distribution of such product unlawful. See FIFRA §§ 2(q)(q)(A); 12(a)(1)(E). If use of the term “safe” has not been allowed in labeling and use of the term hasn’t been otherwise approved, use of “safe” in advertising the sale or distribution of a pesticide product would generally be considered to substantially differ from what was approved in the registration and sale or distribution of the pesticide would be unlawful under section 12(a)(1)(B) of FIFRA.

It is important to point out, however, that Section 12(a) is limited to unlawful sale or distribution, which is defined in FIFRA 2(gg) to exclude "the holding or application of registered pesticides by any applicator who provides a service of controlling pests without delivering any unapplied pesticide to any person so served." See also FIFRA 2(e)(1). This limits EPA's authority to regulate advertising claims made by certain home lawn care service companies that do not sell or distribute pesticides but merely apply them. To the extent EPA lacks regulatory authority over advertising of services, however, the Federal Trade Commission's (FTC's) broad authority to regulate advertising provides a means to regulate and enforce against excessive or misleading claims made by lawn care operators. Therefore, lawn care operators that do not sell or distribute pesticides but make false or misleading claims about their services, may be subject to enforcement by the FTC.

Antimicrobial Claims

Can an antimicrobial product to be used as a hard surface disinfectant have a contact time of greater than 10 minutes? There currently don't appear to be any guidance documents prohibiting contact times of greater than 10 minutes for hard disinfectants. LC; 12/08/11

While the Agency reviews proposed contact times for disinfectant products on a product-by-product basis, in general, the Agency does not accept a hard surface disinfectant contact time of greater than 10 minutes unless the material to be disinfected is to be immersed in the disinfectant product solution as part of the disinfection process. Disinfectants that are applied to surfaces that are not immersed in the disinfectant product solution will dry out and therefore contact with the disinfectant product solution will generally not last longer than 10 minutes.

The Agency recommends the use of the AOAC International Use-Dilution Methods or the AOAC International Hard Surface Carrier Test Methods (distilled water only) to develop efficacy data to support a disinfectant claim. These methods specify a contact time of 10 minutes or less. In addition, on January 27, the Agency made available to the public for comment its draft proposed Series Product Performance Guidelines which included draft proposed guidelines for disinfectant treatment of hard surfaces. The proposed disinfectant guidelines for use of antimicrobials on hard surfaces () would, once they are final, specify that disinfection of hard surfaces be achieved within a disinfectant product contact time of 10 minutes or less.

Is it allowable to have a statement on an unregistered cleaning product that makes a claim saying "Compare to the Cleaning Performance of " a specific EPA registered antimicrobial pesticide product? LC;

EPA does not have jurisdiction over cleaning products that make no pesticidal claims. However, a label that compares properties of a cleaning product to those of a registered pesticide product appears to make a pesticidal claim, which would likely result in the need to register the cleaning product bearing such claim.

What are the standard levels of Quaternary Ammonium for sanitation? ppm is accepted as the minimum, is there a maximum level that is acceptable or a range, say - ppm? LC; 10/6/11

There are no “standard levels” of a quaternary ammonium that can be used for sanitization. The dosage rate for a sanitization claim is determined by efficacy data that are required to be submitted since sanitization is a public health claim. There are limits established in 40 CFR (tolerance exemptions for food contact sanitizers) regarding the ppm level of a solution containing a quaternary ammonium that can be used on a food contact surface. For some quaternary ammonium compounds the maximum level is ppm while for other quaternary ammonium compounds the solution can contain up to ppm. The rate specified on the product label determines the ppm level that can be used in a sanitizing solution whether it is used on non-food or food-contact surfaces.

Sodium hypochlorite is commonly used in drinking water as a disinfectant. Can you tell me what the current sodium hypochlorite levels that are allowed for drinking water use and who has a label approved for such use? LC; 5/19/11

Residues of sodium hypochlorite in water are measured as available chlorine. In , the Office of Water (OW) working with the Office of Pesticide Programs (OPP) established a maximum residual disinfectant level (MRDL) of mg/L (ppm) for chlorine (40 CFR ) that is allowable in community water systems (CWSs) and nontransient noncommunity water systems (NTNCWs) from either a primary or secondary disinfectant treatment. View the Federal Register Notice for the final rule(88 pp, 1,K, About PDF).

In general, the Agency does not identify and/or recommend specific pesticide products. Therefore, we suggest that you contact your local water utility to determine what disinfectant products they may be using.

When is the "General Precautions" statement required on an antimicrobial label? Is the statement required when it is marketed for a hospital or medical facility? If it does not have a hospital or medical claim or the label is for residential do they need the "General Precautions" paragraph? LC; 5/19/11

In general, there are no differences in the precautionary statements required for a hospital product versus a residential product. Precautionary statements may vary among specific products due to the hazards that may be posed by the particular product in question. The major differences between product labels for hospital products versus residential products are differences in the use directions including the use sites and pests.

A “General Precautions” statement is not a required label statement and thus does not have to be used on either a hospital or a residential product. Many companies choose to use that format to organize the precautionary information provided to the user. The precautionary statements required on a label are specified in Subparts D and E of 40 CFR Part Further, EPA may require product specific precautionary label statements on a case-by-case basis through the registration process.

Several customers have requested confirmation of what is allowed concerning claims for antimicrobial products. The question has arisen due to the fact that the Agency has allowed claims of effectiveness against H1N1 when the product has a claim against any Influenza A strain. For example, if a product is registered as effective against a single Salmonella species can it be claimed that the product is effective against Salmonella in general? LC; 08/13/10

In general, the Agency requires registrants to submit efficacy data to support all public-health-related label claims. If a registrant wants to list a specific public-health microorganism on their product label, they would need to generate and submit efficacy data showing the product is effective against that specific microorganism.

In the case of H1N1, the Agency believed a different approach was needed due to the emerging threat posed by the spread of Pandemic H1N1 Influenza A Virus. Thus, the Agency used an approach based on the determination that data submitted to support a claim for control of any Influenza A virus was sufficient to support a label claim against Pandemic H1N1 Influenza A virus. This determination was in part based on the fact that efficacy data that support use against Influenza A also support use against different strains within the same type of virus. See Guidance for Testing and Labeling Claims against Pandemic H1N1 Influenza A Virus. Search EPA Archive

However, in the case of Salmonella, 1) the pandemic scenario is not present and 2) the genus of Salmonella is a much broader category of organisms than is encompassed by the Influenza A virus type. Species of Salmonella include those that are resistant to antibiotics as well as those associated with food-borne illness or typhoid fever. Efficacy data on a singles species are not adequate to support a general Salmonella claim; therefore, data must be submitted to support each Salmonella species listed on the label.

I work for a state regulatory agency that regulates Day and Home care operations. We have a rule that requires our operations to use specific disinfecting solutions, one of them being a "commercial grade product that meets the EPA's standards for "hospital grade" germicide". In reviewing your website, it seems you do not use this term often. The term you use in "disinfectant". Are these two terms inter-changeable? Secondly, do you have a list of EPA- approved hospital grade germicides available? Is there another term our inspectors should be looking for? (LC; )

EPA does not categorize disinfectants as “commercial grade” or “hospital grade.” In fact, those types of descriptors are generally considered as misleading with respect to the chemical’s composition and effectiveness ((a)(5)(i) and (ii)) because such statements could lead purchasers to believe they are getting a more effective product which is not necessarily the case.

On the other hand, an antimicrobial product label may bear instructions for use in the hospital or medical environment if, among other things, the product passes efficacy testing for such use(s). The efficacy testing guidelines for such products are contained in (d)(3) of Subdivision G of the Pesticide Assessment Guidelines. Specifically, to be registered for use in a hospital or medical setting (such as a nursing home, day care center, doctors office), the product must be approved as a broad spectrum disinfectant and also must be proven through efficacy testing to be effective against the nosocomial bacterial pathogen Pseudomonas aeruginosa. Additional claims may be made if testing against other specified microorganisms demonstrates that the product is efficacious. Information on efficacy testing for such products can be found in the Subdivision G testing guidelines and at Disinfectants for Use on Hard Surfaces.

We do not keep a list of EPA registered antimicrobial products that have been registered for use in hospitals.

To assess whether products can be used in hospitals, your inspectors should look for disinfectant products with directions for use in hospitals.

An antimicrobial sanitizer label contains directions for use on food-contact surfaces that require a one-minute contact time although the data requirement for such products specifies only a second performance test. The FDA Food Code, which is used by state and local jurisdictions to develop their own food safety rules, allows as little as a 7-second exposure time under certain circumstances. Is it a violation of the EPA label to use the described sanitizer product in a commercial dishwasher with a second final rinse time (the only contact time with the sanitizer is during the second rinse)? LC;

It is a violation to use a registered pesticide in a manner inconsistent with its labeling, FIFRA § 12(a))(2)(G). Therefore, it would be a violation of the label to use a registered sanitizer product at less than the contact time specified on the product label. The Food Code may provide a minimum exposure time where it applies but it does not supersede a pesticide’s labeling. In your example, the second final rinse time is the only time during which the sanitizer contacts the surfaces it is sanitizing, therefore the sanitizer is being used inconsistently with its labeling which requires a one-minute contact time.

Can a sanitizer spray be considered to be effective against microorganisms other than those specifically listed on the label if the manufacturer has data to back up the claims? (LC; )

FIFRA section 12(a)(1)(B) makes it unlawful for any person to distribute or sell any registered pesticide “if any claims made for it as a part of its distribution or sale substantially differ from any claims made for it as a part of the statement required in connection with its registration.” Accordingly, to make lawful claims, including providing or referencing data in connection with the product's sale or distribution, that a sanitizer spray is effective against specific pests, a registrant must submit those proposed claims and supporting data to EPA for approval as a part of its registration package and obtain EPA approval of the proposed claims.

FIFRA section 2(ee) does allow a user to apply “a pesticide against any target pest not specified on the labeling if the application is to the crop, animal, or site specified on the labeling, unless the Administrator has required that the labeling specifically state that the pesticide may be used only for the pests specified on the labeling after the Administrator has determined that the use of the pesticide against other pests would cause an unreasonable adverse effect on the environment.” It must be noted that with respect to antimicrobial pesticides targeted against human pathogens, 40 CFR Part (b)(5) states that EPA will regard as unlawful the placement or sponsoring of advertisements which recommend or suggest the purchase or use of a registered pesticide for an unregistered use even if the use would be permitted by FIFRA section 2(ee).

An antimicrobial product uses materials from renewable resources. Will EPA permit labeling to make claims regarding renewable, naturally derived, or biodegradable materials? (LC)

  •  ____ material made from X% biodegradable _____
  •  ____ made from X% biodegradable _____
  •  ____ made from X% biodegradable materials
  •  Made with biodegradable ______
  •  Biodegradable ____ material
  •  This product is biodegradable (with supporting data for the liquid _________)
  •  ____ made from X% naturally derived ______
  •  ____ material made from X% naturally derived ______
  •  ____ material made from X% renewable ______
  •  ____ made from X% renewable ______
  •  ____ made from X% renewable materials

Label claims are evaluated on a case-by-case basis when individual product labels are reviewed and registered. Claims regarding renewable, naturally-derived or biodegradable materials have historically been found to be not acceptable. While these terms may be factually correct in describing some of the attributes of a product, these terms can be misinterpreted as claims that relate to the safety of the product and therefore may be misleading. The terms “naturally” and “renewable” suggest that a particular product contains certain ingredients that are safer than other products that contain other ingredients. EPA does not approve claims that suggest a pesticide is safe, and does not approve claims that could be considered misleading comparative claims about the safety of a product versus other products that do not contain these same ingredients. LC;

In September , EPA initiated a pilot program to allow claims of biodegradability for products meeting certain criteria. The criteria are posted on the Agency's website at: the Pilot Criteria for Biodegradability Claims On FIFRA Registered Products On FIFRA Registered Products.

Can a pathogen name (or any portion of a pathogen name) be included in the product name of a registered pesticide? (LC; 11/8/07)

A pathogen name may be included in a product name if its inclusion does not make the product misbranded because the labeling is false or misleading. See FIFRA § 2(q)(1)(A). Although the Agency discourages the use of pathogens in a product name, product names are reviewed on a case-by-case basis. If there is a concern that a name may be misleading (such as presenting a heightened efficacy claim), the Agency may require evidence that it is not misleading before we accept it.

Many antimicrobial products labeling indicate use on "highchairs" and "toys" but are ambiguous as to use directions. Are "highchairs" and "toys" a food-contact surface or are they a non-food-contact surface? If "highchairs" and "toys" are a food-contact surface should there be indication in the label? Since "highchairs" and "toys" come in direct contact with infants/small children hands and mouths, there should be specific directions in antimicrobial product labels to reduce the possibility of contact and ingestion of pesticides. Infants/small children exposure to antimicrobial pesticides is not equivalent to adult. Defining "highchairs" and "toys" as a food-contact surface is a minor definition issue which could reduce "potential" pesticide exposure in a potentially vulnerable population (infants/small children). (LC; 9/24/07)

The use of an antimicrobial on highchairs is considered to be a food use. However, the use of an antimicrobial on toys is treated as a non-food-contact use. The Agency has not typically required a separate set of use directions for use of antimicrobials on highchairs or toys because the rate, method of treatment, target pests and other parameters are the same as for treatment of other hard non-porous surfaces that are typically found on antimicrobial labels.

The Agency does assess indirect dietary exposure for uses such as counter tops, appliances, tables, utensils, food packaging and other areas where there may be incidental contact such as high chairs. The Agency uses an FDA model (Chemistry recommendations, appendix I, II, III, IV, V) that takes into account application rates, residual solution, area of the treated surface that comes into contact with food, pesticide migration fraction and body weight. In this assessment, the Agency determines whether an additional margin of safety for infants and children is needed.

The Agency also evaluates the use of antimicrobial pesticides on toys taking into account the mouthing contact (i.e., incidental oral contact) and the completeness of the data base on toxicity and exposure. If the available data indicate that an additional margin of safety for infants and children is needed (susceptibility and sensitivity issues) then the Agency will apply it.

In regards to claims made by antimicrobial type pesticides, certain statements on labels require EPA registration (such as “kills,” “disinfects” and “sanitizes”). Does EPA consider the term “sanitary” (as in “leaves surfaces sanitary”) to be a pesticidal claim? (LC)

The Agency considers the appropriateness of the use of the term “sanitary” on product labels on a case-by-case basis. The Agency has generally interpreted the use of this term as implying a state of cleanliness. However, if, among other things, the use of the term implies a claim of antimicrobial properties, the term may be considered a pesticidal claim, and if so, the product must be registered in order for the product to retain the claim and be able to be lawfully sold or distributed in the United States. Other factors that may imply that a product’s intended use is for antimicrobial effect include whether the product is similar in composition to FIFRA-registered products that make antimicrobial claims and whether the product contains an ingredient at levels for which there is no functional reason other than pesticidal activity.


Is an apparatus of a pump connected to a bottle of concentrated pesticide, which in turn is hooked into a residential lawn irrigation system (sprinkler system) considered a chemigation device? Can chemigation be referred to in a residential setting? The pesticide used in this case is a 25(b) exempt product. Could other registered conventional pesticides be used? (LC)

The apparatus in question is application equipment that turns a residential lawn irrigation system into a chemigation system by introducing the pesticide into the irrigation system. Chemigation is defined in 40 CFR as “the application of pesticides through irrigation systems.” While this regulatory definition is exclusive to agricultural settings, it is reasonable for the Agency to apply it to similar situations outside of agricultural settings such as in residential lawn irrigation systems. Thus the Agency would consider use of the apparatus described above as a chemigation application. To the extent that a label prohibits the use of a product in a chemigation system, the label prohibition must be followed.

Chemigation has also been addressed in the agricultural setting through PR Notice , but this notice specially states that it does not apply to any pesticide product intended solely for residential setting. However, the scope of the PR Notice was limited based on the information the Agency had on the extent of chemigation as a practice at the time. The agency is currently reviewing PR Notice to update in accordance with changing practices and will be putting a draft out for public comment.

Contract Manufacture

Our company is looking at a repackaging project that involves receiving end-user household-type pesticides that have been returned to the retailer from which they were purchased. Assuming permission has been granted from the original registrant, can the product be repackaged and labeled with a trade name other than the original product/trade name without having to re-register the formulation? (LC)

A repackaged product may be labeled with a trade name other than the original product trade name without having to re-register the formulation only if the registrant has registered the alternate brand name for that particular product registration and your company is operating under a contract with the registrant that allows you to relabel with an alternate brand name. In addition, repackaging must occur at a registered establishment in accordance with 40 CFR Part

Is it true that all product produced at a contract manufacturer should carry a statement 'Produced for Company X? Or since the contract manufacture is working for the registrant, is the 'producer' really the registrant - meaning that the label does not need to carry the 'Produced for Company X'? (LC)

As stated in the Code of Federal Regulations section (c) "If the registrant's name appears on the label and the registrant is not the producer, or if the name of the person for whom the pesticide was produced appears on the label, it must be qualified by appropriate wording such as "Packed for * * *," "Distributed by * * *," or "Sold by * * *" to show that the name is not that of the producer."

In this case, the registrant is not the producer, irrespective of the contract manufacturing arrangement. The contract manufacturer is the producer of the pesticide, and therefore the registrant's name must be qualified with either the statement "Produced for * * *" or "Manufactured for * * *."

Use Sites

For commercial seed treatments, is the treated seed considered a pre-harvest use? BPPD has taken a position that commercial seed treatments are a post-harvest use, and we are looking for some clarity.

In a generic example, if the active ingredient and all the inert ingredients in a pesticide formulation are exempt from the requirement of a tolerance under 40 CFR , and , is it necessary to use a dye for commercial seed treatments? What if an ingredient is only cleared in (preharvest use only), is a dye required for commercial seed treatment? LC; 12/15/14

In accordance with 40 CFR § (a), “[p]esticide products intended for use in treating seeds must contain an EPA-approved dye to impart an unnatural color to the seed, unless appropriate tolerances or other clearances have been established under the Federal Food, Drug and Cosmetic Act for residues of the pesticide.” Seeds can either be planted in order to derive a food commodity that is grown from the seed, or can be a food crop if they are to be used directly as food or feed. The inert tolerance exemptions found in 40 CFR for pre-harvest uses apply to formulations applied to growing crops only. Because seed is not a growing crop when it is treated, an exemption under 40 CFR is not sufficient to escape the requirement to include a dye in the pesticide product used for the treatment.

How is "greenhouse," as a use site, defined by EPA? Would EPA consider cold frames to be greenhouses? (LC; 3/3/11)

For the purposes of the Worker Protection Standard (WPS), 40 CFR defines "greenhouse" as "any operation engaged in the production of agricultural plants inside any structure or space that is enclosed with nonporous covering and that is of sufficient size to permit worker entry. This term included, but is not limited to, polyhouses, mushroom houses, rhubarb houses, and similar structures." EPA has not defined "greenhouse" in the context of use sites but the WPS definition is instructive. If a cold frame is enclosed with nonporous covering and is large enough to permit worker entry, it would likely be considered a greenhouse.

Cleanout and disinfection of crawl spaces (area underneath houses) is a new service being provided by a number of PCO companies. We are having difficulty determining whether disinfectants can legally be used in crawl spaces. Often the sites on disinfectant labels are very broad and seem to allow treatment in any area of a structure (including the crawl space), but then the specific directions only cover areas with non-porous surfaces inside of a structure. It would be helpful for EPA to address this new use pattern and in the meantime we would appreciate some guidance on when disinfectants with current labels can be used in crawl spaces. (LC; 10/18/08)

The Agency does not have a standard definition for crawl spaces. As a result, the user must refer to the label of the disinfectant product to determine whether the product can be used to treat crawl spaces. Typical components of a crawl space include ground and bare wood. The Agency considers these surfaces to be porous surfaces. These types of surfaces cannot be treated unless the label contains directions that would allow the product to be used to disinfectant porous surfaces. If the label has language limiting applications to hard non-porous surfaces, application to a crawl space with porous surfaces would not be permitted.

Definitions of Terms

In a preplant and planting soil treatment: is a band treatment the same as an in-furrow treatment? (LC; 6/3/10)

In-furrow treatments are always done at-plant where the granules or liquid is applied into an open seed furrow just before it is closed by the presswheel. The pesticide resides only at the bottom of the seed furrow.

Banded applications are done at-plant over a closed seed furrow, postplant over the row, or post-emergent often as a side-dress application. They are usually superficially soil incorporated with drag chains or tines.

A banded application at-plant over an open seed furrow, is called a T-band.

Preplant applications are usually broadcast over the entire field and incorporated. They are usually referred to as Preplant Incorporated or PPI.

I am trying to find the definition or examples for the areas allowed in food-handling establishments versus the non-food areas. I am also searching for the definition of spot treatment. (LC; )

EPA published definitions and policies related to food-handling establishments in the Federal Register on August 10, , available at 38 FR The notice defined a food handling establishment as “an area or place other than a private residence in which food is held, processed, prepared and/or served.”

  • Food areas "include areas for receiving, serving, storage (dry, cold, frozen, raw), packaging (canning, bottling, wrapping, boxing) preparing (cleaning, slicing, cooking, grinding), edible waste storage, enclosed processing systems (mills, dairies, edible oils, syrups).
  • Non-food areas include garbage rooms, lavatories, floor drains (to sewers), entries and vestibules, offices, locker rooms, machine rooms, boiler rooms, garages, mop closets, and storage (after canning or bottling).”

The notice also defines spot treatment as “application to limited areas on which insects are likely to occur, but which will not be in contact with food or utensils and will not ordinarily be contacted by workers. These areas may occur on floors, walls, and bases or undersides of equipment. For this purpose, a ‘spot’ will not exceed 2 square feet.”

Can you provide a definition of high level and low level disinfection. I have looked all over your site. There is the disinfectant definition, but it does not explain this. (LC; )

EPA does not have a definition for high and low level disinfection. These are terms used by FDA. More information on high and low level disinfectants. Also see guidance on review by FDA.

Does EPA recognize 29 CFR and (by reference) as the standard for labeling required safety glasses? (i.e., safety glasses need to be ANSI-approved and carry an ANSI number). If not, do you recognize any standard for safety glasses or can users use any type of glasses that have brow and temple protection? (LC; )

According to the worker protection standard and 40 CFR §(7) (Protective Eyewear): “When “protective eyewear” is specified by the product labeling, one of the following types of eyewear must be worn: (i) goggle; (ii) face shield; (iii) safety glasses with front, brow, and temple protection; (iv) full face respirator.”

If no more specific instructions are included in the directions for use, any safety glasses with front, brow, and temple protection would be allowed. While the OSHA regulations you cite do not technically apply to pesticide users, EPA strongly recommends following the OSHA guidelines when choosing safety glasses.

Distributor Product Labeling

Registrant R and Company A have entered into a supplemental distribution agreement for a pesticide product. May Company A sell the pesticide product exclusively through another distributor, Company B? If so, can the label state "Manufactured for Company A" and "Distributed by Company B"? LC; 01/15/13

In accordance with 40 CFR , a registrant, and only the registrant, may sell and distribute its registered pesticide product under another person's name (i.e., the "supplemental distributor" or "subregistrant"). A supplemental distributor may not sell or distribute the registrant's product under another person's name.

For the scenario above, in order for the product to be sold or distributed under Company B’s name, Registrant R must enter a supplemental distributor agreement with Company B using EPA Form , which must be submitted to EPA prior to distribution.

We are a producer of a registered pesticide. We wish to sell the product in bulk to a refiller (distributor). The distributor then wishes to repackage our product into smaller refillable containers for re-sale. Can we:

  • use our label but remove our product name from the label;

  • add the distributor name and address and distributor registration number to the label; and

  • change the storage and disposal language to reflect storage and disposal requirements of a refillable product? (LC) 08/10/10​

You cannot do any of the activities you describe without the consent of the registrant. Even with the consent of the registrants, there are limitations.

In accordance with 40 CFR , the registrant may enter in a supplemental distributor agreement with another party to distribute a registered product under another person’s name and address instead of or in addition to the registrant’s own. For a supplemental distributor to distribute a pesticide, the registrant must notify EPA and the distributor must complete a Notice of Supplemental Distribution of a Registered Pesticide Product (EPA form ) signed by both the registrant and the distributor. 40 CFR limits what can differ about a distributor product from the registered product. The distributor may only package the registrant’s product if the distributor is the same producer (or under contract in accordance with 40 CFR ) as the producer who produces, packages, and labels the registered product. See 40 CFR (b). Further, the distributor product may not be repackaged (i.e. it remains in the producer’s unopened container). See 40 CFR (c).

The label of the supplemental registrant’s product must be the same of the registrant with the exception that:

  • the product name may be different; 
  • the name and address of the distributor may appear instead of that of the registrant; 
  • the registration number of the registered product must be followed by the distributor’s company number; 
  • the establishment number must be that of the final establishment where the product was produced; and
  • specific claims may be deleted provided no other changes are necessary.

The registrant must ensure that the EPA-approved labeling of the registered product includes appropriate statements for refillable containers in accordance with 40 CFR Subpart H.

Because you are the producer of the pesticide and the distributor is not, the distributor would not be able to repackage the product into smaller containers even with a supplemental distributor agreement with the registrant. Under a supplemental distributor agreement you may be able to change the product name and the distributor name, address and number. But without a change to the EPA-approved label of the registered product, you cannot change the storage and disposal language.

Can a marketing statement be placed on a label that identifies the retail outlet that is offering the product for sale? If so, what are the parameters of an acceptable statement, and must the statement be submitted as an amendment" (LC, LC) 3/11/10

In accordance with 40 CFR Section (c), “An unqualified name and address given on the label shall be considered as the name and address of the producer. If the name of the person for whom the pesticide was produced appears on the label, it must be qualified by appropriate wording such as “Packed for …” “Distributed by … ,” or “Sold by …” to show that the name is not that of the producer.” FIFRA 2(p)(1) defines “label” as “the written, printed, or graphic matter on, or attached to, the pesticide or device or any of its containers or wrappers.” Thus any writing appearing on the pesticide label is considered part of the label that must be approved by EPA and may not be false or misleading. Changes to the label specifying “Packed for….Distributed by…or Sold by…” are not specified in PR Notice (PR) Notifications, Non-Notifications and Minor Formulation Amendments and therefore these label changes are considered amendments.

We recently are putting together a label for supplemental distribution. The primary registrant is telling us to avoid using any parentheses on our label (even though theirs has some). Our particular statement where we use parentheses is dosages. We typically state use x to y ppm (a to b gals per gallons).

Where a and b are simply converted values of x and y. Is this wrong? (LC) 3/11/10

In general, EPA allows the use of parentheses on a label unless:

  • the parentheses are used in such a way that the labeling becomes false and/or misleading; or
  • the use of the parentheses causes confusion making the directions for use inadequate to protect human health or the environment.

The example you cite where you provide correct ppm information to the user based on the rate on the label would generally be an acceptable use of parentheses on a label.

Please note, however, that the label of a distributor product must be identical to the master label of the parent product, except as provided in 40 CFR (d). A supplemental distributor may not present statements in parentheses on a label unless the master label of the parent product also contains the same statements in parentheses. Further, the supplemental distributor may not delete statements in parentheses that appear on the parent product's label unless they involve one of the changes allowed in 40 CFR (d).

40 CFR (d) says "the label of the distributor product is the same as that of the registered product" Does that mean the label must be identical in layout, verbiage, design, etc. or does it mean the information required in 40 CFR (other than excepted in (d)) must remain unchanged? (LC) 3/11/10

The supplementally distributed product must bear the same information as the parent product with the exception of the information listed in 40 CFR (d). Except for the pieces that may change, the wording must be identical. The layout and format of the label of the supplementally distributed product may differ from that of the parent product so long as the change in layout or format doesn’t make the label false or misleading.

Can the registrant of a product whose company name and address appear on the primary label add a second label to the container indicating a distributor company name? Essentially this would avoid the supplemental distribution and subsequent state pesticide registration fees associated with supplemental distribution. (LC) 3/11/10

Primary Container label
Manufactured for
ABC Company

Distributed by or sold by:
XYZ Company

A registrant could add the suggested language you propose as a second label indicating a distributor company name, if the change were reflected on the master label for the product. See (c). Generally, all information on labeling needs to be approved by EPA in what is collectively referred to as the "master" label. Products can be sold or distributed with a subset of the master labeling provided no changes would be necessary to precautionary statements, use classifications or packaging. To add an alternate distributor name, a registrant could list the standard company name on the master label and include alternates that would be used as appropriate on products depending on how they are distributed. If added as alternative language on the master label, EPA would not treat this scenario as a supplemental distribution as described in 40 CFR FIFRA 2(p)(1) defines "label" as "the written, printed, or graphic matter on, or attached to, the pesticide or device or any of its containers or wrappers." Thus any writing appearing on the pesticide is considered part of the label that must be approved by EPA and may not be false or misleading. Adding distributor information to the master label, however, may have no effect on state registration fees, which are governed by state laws.

If a supplemental distributor obtains NSF registration for the distributor product but the basic registrant does not have NSF registration, can the distributor submit a notification to EPA to have the NSF logo added to the distributor label? (LC) 12/10/09

40 CFR § states: “the label of the distributor product is the same as that of the registered product” with listed exceptions. One listed exception is that the distributor may delete specific claims that are found on the basic registrant’s label. Distributors may not add claims that don't appear on the basic registrant's label. EPA considers placement on the label of a third-party certification such as the NSF logo to be a claim, and therefore a distributor may not add it to the distributor label unless it also exists on the label of the basic registrant’s product. For guidance on the use of the NSF label generally, see NSF Logo Letter.

Does the Agency allow the use of the GHS corrosive symbol on supplemental distributor labeling without the symbol being on an approved stamped label? (LC) 8/28/08

40 CFR (d) requires that "the label of the distributor product is the same as that of the registered product" with certain listed exceptions such as the product name, registration number and establishment number. Inclusion of additional symbols or graphics on a distributor label is not one of the exceptions. Thus the basic registrant would have to add the GHS corrosive symbol to their label first before a distributor could use it.

A pesticide dealer copies mixing directions from a product label, puts them on a sticker, and puts the sticker on the products he sells. He also puts a sticker with his business address on the containers. Does either sticker misbrand the products? (LC) 2/26/09

Both activities are unlawful presuming the dealer is not acting with the permission of the registrant and in accordance with various regulatory requirements. FIFRA § 12(a)(2)(A) states that it is unlawful “to detach, alter, deface, or destroy, in whole or in part, any labeling required [under FIFRA].” Putting the copied mixing directions on another product is considered labeling and must be done in a registered establishment and in accordance with the registration of the product to which the sticker is added. If the product getting stickered doesn’t include the sticker information as part of its approved labeling, the product would be misbranded.

Pesticide/fertilizer labels in certain states must have a label attached to the package, which includes an acceptable Internet statement (e.g., "Information regarding the contents and levels of metals in this product is available on the Internet at:") Is it legal for a supplemental distributor to add the Internet statement on their supplemental distributor fertilizer/pesticide product labels when the master EPA label does not have this statement? (LC) 10/30/08

The label of a distributor product must be identical to the master label of the parent product, except as provided in 40 CFR (d). A supplemental distributor may not add statements such as that proposed in the question unless the master label of the parent product is amended to include the statement

If a registered pesticide label is distributed in both the USA and in another country does the Agency allow both the USA Distributor Company's Division Name & address and the International Distributor Company's Division Name and address on the same supplemental label? (LC)

40 CFR (a)(1)(ii) requires that the name and address of the producer, registrant, or person for whom produced appear on the label. Further 40 CFR (c) requires that if the producer is not the company listed in the name and address on the label, the name and address must be qualified by a phrase such as “Distributed by,” “Produced for,” or “Sold by” to show that the name appearing on the label is not that of the producer. So long as the qualification is not false or misleading, the international distributor’s name and address may be added to the label if it is properly qualified by a phrase such as “Distributed Internationally by” or “International Distributor:”. See FIFRA sec. 2(q)(1)(A).

In a situation where a registrant voluntarily cancels a registration, the registrant generally has 18 months to continue to sell product in channels of trade. When a basic registrant terminates a supplemental registration, does the sub-registrant (the supplemental distributor) have the same month period to sell product? (LC) 3/20/08

EPA interprets 40 CFR (c) to generally permit a supplemental distributor 18 months to sell and distribute existing stocks after the basic registrant terminates the supplemental registration. In this context, the supplemental registrant's existing stocks are only those affected pesticide products that have been released for shipment as of the effective date of termination of the subject supplemental registration. Sale or distribution of any quantities of the affected distributor product produced after the effective date of termination would be considered illegal under FIFRA.

It is important to note that while EPA regulations may permit such distribution or sale of existing stocks for 18 months following termination of the supplemental distribution, the contractual arrangement between the basic registrant and the supplemental distributor may contain terms that further limit or preclude sale and distribution by the supplemental distributor (although such contractual arrangements would be enforceable through the courts, and not by EPA).

Must a subregistrant use the warranty statement that is on the Basic Registration label? The subregistrant wants to substitute its own warranty statement. (LC) 12/13/07

40 CFR § (c) generally limits the changes that can be made between a registrant’s label and a supplemental distributor’s label to the:

  • name of the product;
  • name and address of the distributor; 
  • registration and establishment numbers; and
  • deletion of claims on the distributor product.

However, because warranty statements are not required by EPA to be on pesticide labels, the Agency will allow supplemental distributors to use their own warranty statements so long as such a change to the labeling is allowed by contract between the registrant and the distributor and the substitute warranty statement is not false or misleading. See FIFRA Compliance Program Policy No. (May 10, ). Any revised warranty statement on a distributor's label cannot expand upon, either explicitly or implicitly, the uses allowed on the registrant's label and cannot conflict with the claims stated on the label. For help in developing an acceptable warranty statement, see the guidance available at the Guidance on Warranty Statements

We are a supplemental distributor registrant for a product. One of our customers would like to buy our subregistered product, but they would like to have their name and logo on the packaging. Can we label the product with our customer's name, address and logo on the front panel, qualified by "Sold by"; and still put our name, address, Reg. No., and Est. No. on the back panel, qualified by "Distributed by"? (LC) 1/31/08

40 CFR (d) requires that the labeling of the distributor product be the same as that of the registered product with the following exceptions:

  • The product name of the distributor product may be different (but may not be misleading).
  • The name and address of the of the distributor may appear instead of that of the registrant.
  • The registration number of the registered product must be followed by a dash, followed by the distributor’s company number (obtainable from the Agency upon request).
  • The establishment number must be that of the final establishment at which the product was produced.
  • Specific claims may be deleted, provided that no other changes are necessary.

These exceptions do not allow for the supplemental distributor to put a customer’s information on the label. However, the supplemental distributor could incorporate the customer’s name into the product name (e.g. X’s insecticide) so long as the new product name is not misleading and the registrant allows the subregistrant to make such a change under any applicable contracts between the registrant and subregistrant.

Our company imports a commodity chemical from outside the United States into a public warehouse. One end-use of the chemical is as an EPA-registered pesticide. The quantity of this chemical that we currently have in stock at the public warehouse is not labeled. When we receive an order for the EPA-registered pesticide, the warehouse labels packages of the product with the registrant’s label and ships it to the customer. The registrant provides the necessary labels for the warehouse to affix to each package. Do we as the distributor need to be registered in order to direct our third-party public warehouse (physically in possession of the product) to affix the labels on the registrant's behalf? Or does the warehouse need to be registered, or both? (LC)

The person doing the labeling must be doing so under the instruction of the registrant but does not have to be registered. In contrast, the warehouse where the labeling is taking place must be registered as a pesticide producing establishment since labeling is defined as production of a pesticide and all pesticide production must take place in a registered establishment. See 40 CFR Part The establishment number of the warehouse where the labeling is taking place must appear on the label of the product. 40 CFR (a)(1)(v). You may obtain an establishment registration for the warehouse by contacting the EPA Regional office which has jurisdiction over the state where the warehouse is located. See more information on establishment registration process and reporting obligations.

Is it acceptable for a Supplemental Distribution of a Registered Pesticide Product form to have two distributor product names listed in the box (e.g., XXX Algae Relief and Algae Pond Relief)? In the past, each distributor product has had its own form. (LC)

In accordance with 40 CFR (a) each distributor must complete a signed Notice of Supplemental Distribution of a Registered Pesticide Product (EPA form ), however, the form can contain more then one brand name. So, it is possible for a distributor to list two product names on the form. The names would have to be for the same registered product and be submitted by the same distributor.

My questions are in regard to a combo product, a fertilizer with a pesticide on it. When sub-registering a product, and the primary label mentions "spreader settings" on the label, is it a requirement for the sub-registered label, to carry this same statement about what the settings should be, or is it permissible to include a general statement of contacting the spreader manufacture for up to date settings for the product, due to the large amount of spreaders and possible changes, and also since "spreader settings" is not a FIFRA or 40 CFR label requirement? (LC)

A distributor label under Supplemental Distribution must be the same as that of the registered product except for a limited set of exceptions, 40 CFR (d). Directions for Use are not excepted and must be identical to those of the registered product. Therefore, the “spreader settings” of the parent registered product must be used on the Distributor label, being a part of the Directions for Use. If the distributor label included any additional text not included on the registered product label, it would not be the same as the registered label, and thus in violation of the regulations.

May distributor labels differ from EPA-accepted labels? (LC)

40 CFR (d) requires that "the label of the distributor product is the same as that of the registered product" with certain listed exceptions such as the product name, registration number and establishment number. In addition, claims may be deleted for the distributor label provided no other changes are necessary (40 CFR (d)(5)).

In situations where a product is produced by a contract manufacturer as well as the registrant, could the registrant preface his name and address on the label with the term "produced for" regardless of whether he is the producer or the contract manufacturer is the producer of the pesticide? (LC)

A registrant may qualify his name and address with the term "produced for" regardless of who is the producer of the product. The registrant may also qualify his name and address with the terms "Sold by" or "Distributed by," which are equally acceptable. See, generally, 40 CFR (c).

Can a product label list the distributor's name and address on the packaging label in the absence of the distributor's company number appended to the product registration number? The product is not "sub-registered" to the distributor, but is an alternate brand name, with the ABN including the distributor's name. (LC)

A product label may list a distributor's name and address on the label without the distributor's company number appended to the product registration number. If the distributor is not the producer of the pesticide, the distributor's name and address must be qualified as required in 40 CFR part (c).

Is it a violation of FIFRA if the literature accompanying a supplemental distributor label lists more microorganisms than those listed on the distributor label even if the organisms listed in the literature are also listed on the EPA-approved master label? (LC)

No, it would not be a violation of FIFRA. With some exceptions, not relevant here, 40 CFR (d) requires that the label of the distributor product be the same as that of the registered product. The term "label" is defined as "the written, printed, or graphic matter on, or attached to, the pesticide or device or any of its containers or wrappers." FIFRA sec. 2(p)(1). The more expansive term "labeling" is defined as "all labels and all other written, printed or graphic material" that accompanies a pesticide or device at any time or to which reference is made on the label or in literature accompanying the pesticide or device. FIFRA sec. 2(p)(2). As long as the EPA-approved master label for the registered product lists these pests, the supplemental distributor can market its product with those approved uses, claims, etc.

A company is proposing to distribute a pesticide product which currently has an EPA registration number. On the front of the label, they would like to indicate their brand and on the back of the label, they would like to indicate a "Distributed by" notation with the address of the distributor. First, can they do this without reregistering the product? Second, does a distributor number need to be included and if so, how does a distributor become registered (and is it a per-product registration)? (LC)

The distribution or sale of a registered product under a distributor's name and address is called "supplemental distribution." The requirements for supplemental distribution are set out in 40 CFR The product can be distributed as a distributor product without a separate FIFRA section 3 registration. The distributor would need to be a registered company with their own company number - that company number would be used on all their distributor products. Their EPA Registration number on the distributor products would look something like this: EPA Reg. No. xxx-xxx-xxx or [parent company, number]-[product number]-[distributor company number]. The company numbers may be acquired through the nearest EPA regional office, or by written request to OPP. The Label Review Manual provides a more detailed explanation of supplemental distribution process in Chapter , Section III.

If a distributor sells a pesticide with another registrant's name and EPA information on the container, can that distributor apply a tag or label stating:

Sold By:
XYZ Distributors
Anywhere, USA

This information would only be used to identify where the consumer may have purchased the product. An example might be a garden center selling "Round-Up" Weed Killer and applying a small sticker to the side of the container with his name and phone number on it. (LC)

A distributor may not place a tag or sticker to a product as this is considered labeling and the product would be considered misbranded.

Can a box of 12 pesticides be shipped by a formulator to a private-label distributor unlabeled? EPA-approved private labels are affixed by the distributor upon receipt? Would the box need to be relabeled? (LC)

A formulator may ship unlabeled pesticides to a private label distributor provided the pesticides are transferred to a registered establishment and the conditions of 40 CFR Part (b) are met. The private label distributor may label the products under a contract manufacturing agreement with the registrant of the pesticide product. The container the unlabeled pesticides are shipped in must bear the label of the registered product.

Exception to Use in a Manner Not Permitted (FIFRA Sec 2ee)

Do all states have to comply with the FIFRA section 2(ee) opinion stating: "The Agency’s current position on greenhouse application is that in accordance with FIFRA section 2(ee) a label does not have to specify greenhouse as a site, provided the crop is on the label, in order to use the product in a greenhouse.", or are states allowed to decide that on an individual basis? LC; 3/11/10

States may further restrict the use of pesticides by enacting state requirements that do not contradict the federal labeling. For example a state could ban the use of a product at less than the labeled use rate, which FIFRA section 2(ee) normally would allow. A state could also place additional restrictions on the use of the product within the state to protect sensitive use sites such as greenhouses.

Do FIFRA 2(ee) recommendations generally include rate of application requirements or is the user bound by label directions? For example, if a 2(ee) recommendation for a product applied to a pest includes a 2% use dilution recommendation, can it be applied at 5% use dilution if 5% is an allowable rate on the label? LC;

A FIFRA 2(ee) recommendation may be made for a number reasons, one being the application of the pesticide at less than the label dosage, concentration or frequency. An applicator may apply the product at the use dilution listed on the label or at a lesser use dilution listed in the 2(ee) recommendation. A FIFRA 2(ee) recommendation is just that, a recommendation. An applicator has the option of applying a product at less than the use dilution listed on the label unless the label specifically prohibits such dilution. Note that for antimicrobial pesticides targeted against human pathogens, it is unlawful for any person selling or distributing these products to advertise uses permitted by FIFRA 2(ee). See 40 CFR (b)(5).

Is placing mothballs outside on the grass along a fence line to repel cats an illegal use of mothballs? LC and LC;

Generally, it is unlawful to use any registered pesticide in a manner inconsistent with its labeling under FIFRA sec. 12(a)(2)(G). At present, there are no registered pesticides containing the active ingredients in moth balls that are approved for use in repelling cats. The FIFRA section 2(ee) definition of "to use any registered pesticide in a manner inconsistent with its labeling" provides for certain exceptions under which use is lawful. For example, it is not unlawful to use a registered pesticide "against any target pest not specified on the labeling if the application is to the crop, animal, or site specified on the labeling" This exception would not allow application of mothballs along a fence line because registered mothballs products specify the use site as "air-tight containers and storage closets." Because applying mothballs to a fence line would not be applying them to a site specified on the labeling, such use is unlawful.

Our specific question is in regards to the use of mothballs as a general animal repellent. We frequently encounter people who use mothballs (in an attic, in a crawl space, in the garden, etc.) to repel such animals as skunks, raccoons, opossums, etc. We inform them that this manner of control does not consistently work, and therefore, we cannot recommend it. We also would like to be able to tell them if using this chemical in this manner is illegal - in reference to the terminology found on any chemical/pesticide product that "It is a violation of Federal law to use this product in a manner inconsistent with its labeling." We are having trouble sorting through the information you provide on Use in a Manner Inconsistent with Its Labeling (FIFRA Sec 2ee). This question can also apply to such things as ammonia, bleach, kerosene, gasoline, etc. that people pour in or around such described areas (aside from the obvious that using flammable chemicals in such fashion is dangerous) - the ultimate question is "Is it illegal?" Please advise, as we are anxious to provide our cooperators with the most accurate information. (LC)

Using a registered pesticide like mothballs against a pest not listed on the label is legal unless (1) the pesticide is used on a site not specified on the labeling or (2) the label specifically restricts the pests against which the pesticide may be used (e.g. “for use only against ants”). This is an exception to the definition of “use of a pesticide in a manner inconsistent with its labeling” in FIFRA section 2(ee)(2) which reads in part: “…except that the term shall not include…(2) applying a pesticide against any target pest not specified on the labeling if the application is to the crop, animal, or site specified on the labeling, unless the Administrator has required that the labeling specifically state that the pesticide may be used only for the pests specified on the labeling after the Administrator has determined that the use of the pesticide against other pests would cause an unreasonable adverse effect on the environment,” The other substances you list may be both registered for pesticidal use or available unregistered for non-pesticidal uses. While the Agency does regulate the sale and distribution of unregistered pesticides, it does not regulate the personal use of unregistered pesticides. The personal use of products that are not registered pesticides – such as ammonia, bleach, kerosene, gasoline – may be dangerous, but it is not a violation of FIFRA.

A rodenticide label says a block weighs one pound and is scored to be broken into eight pieces, which means only one 2oz piece of the block is to be used per bait placement. Most of the time, 2 oz. is too much. The manufacturer says it can be used in smaller quantities based on FIFRA 2(ee). Is this correct? (LC)

Section 2(ee)(1) allows applying a pesticide at any dosage, concentration, or frequency less than that specified on the labeling unless the labeling specifically prohibits deviation from the specified dosage, concentration, or frequency. So if the label at issue does not prohibit breaking the 2 oz pieces into smaller pieces, lesser amounts may be used.

Section 2(ee) states an application of "a pesticide against any target pest not specified on the labeling" is allowed as long as the site is identified on the label. This text and meaning is very straightforward. However, EPA's interpretation and action in this regard appears to be based on tighter, unknown criteria or restrictions. Section 2(ee) says one thing but EPA appears to act differently. An example is Sevin / carbaryl that is labeled for turfgrass. EPA interpretation is that “turf-sited” Sevin / carbaryl cannot be used for the control of earthworm pests in turf? Why not? FIFRA Section 2(ee) text allows this usage. Thank you." (LC; 9/24/07)

Section 2(ee) allows the use of a pesticide against any target pest not specified on the labeling as long as the site is identified on the label and there are no other label restrictions that would preclude use against the pest.

Are there any stipulations on who can make a FIFRA 2(ee) recommendation? Can a user make a recommendation? Can the manufacturer make a recommendation to use a pesticide in a manner that would be allowed under 2(ee)? Is there any entity that cannot make a 2(ee) recommendation? (LC06 - )

On October 22, , EPA published a notice in the Federal Register (46 FR ) entitled "Advocacy of Pesticide Uses Which Do Not Appear on Registered Pesticide Label; Statement of Policy," which addresses who may legally recommend or advertise uses under section 2(ee)() of FIFRA. The notice states the any person can make a recommendation under FIFRA section 2(ee)(). A subsequent FR Notice (51 FR ) dated May 28, , amended the Agency's previous position by stating that persons may not make claims under section 2(ee) for antimicrobial pesticide products targeted against microbial human pathogens.

Regarding FIFRA section 2(ee) recommendations; is there a recommended expiration period (e.g., 1 year, 5 years)? Does this need to be added to the recommendation? (LC)

There is no recommended expiration period for a FIFRA section 2(ee)(1)-(5) recommendation.

What is the proper/legal way that FIFRA section 2(ee) bulletins can be distributed by extension services, universities or others? Can they be displayed with the product? (LC)

FIFRA section 2(ee) bulletins are recommendations, allowed by section 2(ee)(2) of FIFRA, advocating use of a product on a pest not specified on the labeling if the pest is on a site listed on the label and the agency has not required labeling that only allows use on specified pests. FIFRA section 2(ee) bulletins may be distributed by virtually any means; i.e., through extension personnel, industry representatives, at the point of sale, displayed with the product, or downloaded off the Internet, provided the bulletin is factually correct and conforms to the restrictions of section 2 (ee). EPA does not allow 2(ee) bulletins for antimicrobial products with public health claims (i.e., targeted against human pathogens, 40 CFR (b) (5)) or other products with such claims. FIFRA section 2(ee) reads as follows:

"(ee) TO USE ANY REGISTERED PESTICIDE IN A MANNER INCONSISTENT WITH ITS LABELING.After March 31, , the term shall not include the use of a pesticide for agricultural or forestry purposes at a dilution less than label dosage unless before or after that date the Administrator issues a regulation or advisory opinion consistent with the study provided for in section 27(b) of the Federal Pesticide Act of , which regulation or advisory opinion specifically requires the use of definite amounts of dilution. "

Is there a required permit/process for an applicator to use, or a dealer to recommend the use of, a pesticide in accordance with FIFRA Section 2(ee)? (LC)

There is no required permit or process to obtain or undergo in order to use a product or recommend use of a product under Section 2(ee)(1)-(5) of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA).

Existing Stocks

40 CFR and the Existing Stocks Policy (56 FR ) create a general month period to distribute or sell products with existing labeling following approval of a voluntarily amended label. Frequently EPA’s approval of the voluntarily amended label will direct the registrant to use this newer language at the next production or within 18 months. New production after the month window requires that labels use the newer text. However, in many instances certain states (CA/NY) may take significantly longer to approve the newer text. (LC)

40 CFR discusses distribution under approved labeling. The Existing Stocks Policy further elaborates on the requirements of 40 CFR If labeling is amended on the initiative of the registrant, the registrant may distribute or sell under the previously approved labeling for a period of 18 months after the approval of the revision. The Agency may alter the time period for distribution or sale under the approved labeling in which case the registrant must comply with the EPA mandated time frames.


Can registrants continue printing older version label language (at the next production but within the month window) until the newer label text is approved by CA and/or NY?

A registrant may distribute or sell a pesticide under previously approved labeling until the month time period has expired. After 18 months the pesticide must bear the newly registered labeling. The month time frame is independent of state registration status of a product.

Can registrants continue printing older version label language after the month window if the newer label text has not yet been approved by CA and/or NY.

Registrants may not continue to label products with old labels after the month period regardless of the registration status of the product in a particular state.

Does the term "new production" refer to the production of the label or the production of the pesticide product.

The term “new production” generally refers to production of the pesticide product. If the new label cannot be printed in time to coincide with new production of the pesticide product and the production is within the month time period, old labels may be used, however supplemental or sticker labeling bearing the newly approved labeling must be used after the month date to bring the product into compliance.

40 CFR and the Existing Stocks Policy (56 FR ) create a general month period to distribute or sell products with existing labeling following approval of a voluntarily amended label. New production after the month window requires that labels use the newer text. Must the new label text be employed at retail bulk sites after 18 months, even if the manufacturer has not implemented the new label for non-refillable packages because no new manufacturing of the formulation has occurred since approval? (LC)

Regardless of whether the registrant has engaged in new production during the 18 months, any new production after 18 months must bear the new amended labeling. Repackaging is considered production therefore pesticide product repackaged into refillable containers must bear the new amended labeling.

When a registration is transferred, what is the existing policy for product labeling/produced in the "old" EPA registration number to be used up? (LC)

Generally, the new registrant may distribute or sell under the previously approved labeling for a period of 18 months after the effective date of the transfer. The Agency specifies the time period in its letters of transfer. See 40 CFR (c) and (e) or Chapter of the Label Review Manual.

When a product's registration is transferred from one company to another, e.g. Company A to Company B, what are the requirements for changing the product's labeling? (LC)

When a product registration is transferred from Company A to Company B, EPA allows Company B to sell and distribute existing stocks of the product for 18 months. Existing stocks are stocks that were produced and released for shipment by the date of the transfer and therefore would bear labeling based on Company A's registration. Each container or package bearing Company A's labeling must be clearly and accurately marked with the batch number, lot number or other descriptive designation used to identify the product in Company B's records. After 18 months, if any existing stocks remain, they would need to be relabeled with Company B's labeling in order to be sold or distributed.

Any product produced after the date of the transfer must bear Company B's labeling, including the new company name and new EPA Registration Number.

General Labeling

If we are not going to sell the product to a specific industry, do we still have to leave the claims for that specific industry on the label? For example, if there are specific claims for dentist, but we are not selling to the dentist - do we still have to include the dentist claim on the label? LC; 7/7/11

All claims to be made for registered pesticide products must be submitted for review in accordance with FIFRA 3(c)(1)(C). Once claims are approved, registrants may choose from the approved claims, which will appear on the marketed product label. Claims may be omitted so long as the omission does not make the marketed label false or misleading. For supplemental distributors, there are limitations to what changes can be made to the approved label; however, regarding claims 40 CFR (d)(5) allows specific claims to be deleted from the product labeling provided that no other changes are necessary.

Regarding anticoagulant rodenticides, such as (by a.i.) Bromadiolone and Difethialone. If labels do not specifically state that they can be used in food storage facilities or food processing plants, can these rodenticides be used under 21 CFR (c), which states in part " The use of insecticides or rodenticides is permitted only under precautions and restrictions that will protect against the contamination of food, food-contact surfaces, and food-packaging materials." LC; 5/19/11

You cannot use the pesticide at a food site unless it fits into one of the approved sites listed on the label and there is no restriction against it. It should be noted that on products labeled for indoor, commensal rodent control that include the food processing facility site, the following language should appear - "Do not contaminate water, food, feedstuffs, food or feed handling equipment, or milk or meat handling equipment or surfaces that come into direct contact with food or feed. When used in USDA inspected facilities, this product must be applied in tamper resistant bait stations."

What is the correct verbiage and placement on the label for expiration dates? LC; 6/3/10

Pesticides which change in chemical composition (e.g., the amount of active ingredient degrades so that it falls bellow the EPA-approved certified lower limit) must bear the following statement in a prominent position on the label: "Not for sale or use after [date]." 40 CFR (g)(6)(i). The agency requires this statement for products that cannot demonstrate one year storage stability in product chemistry guideline number for conventional pesticides and guideline for antimicrobial pesticides. The product must meet all label claims up to the expiration date indicated on the label. For placement of the statement, we recommend it be placed on the front panel, either immediately below the product name or ingredient statement.

See also Label Review Manual Chapter 5, Section VIII(a). Expiration dates may appear on labeling for other reasons. If they do, the correct wording and placement is determined on a case-by-case basis.

A label gives directions for use on Ornamental Turf Areas and lists specifically golf courses, cemeteries, parks, turfgrass, and other grass areas, but there is no indication or directions for use specifically on sod farms. There is also no strict prohibition against using the product on a sod farm. Can this product be used on a sod farm? LC; 6/3/10

The Agency treats sod farms as a separate use site from those on the directions for use list. Ornamental turf is not considered to include agricultural crop and sod farms are considered to be an agricultural crop. Since sod farms are not listed as a specific site for application on this label, and sod farms are not covered by the Agency's definition of ornamental turf, this pesticide can not be applied to sod being grown on sod farms.

Is it true that the manufacturer's label on a CONSUMER (as opposed to agricultural, etc.) pesticide imposes a legal obligation on the purchaser to use the product only as directed on the label? LC; 4/6/10

FIFRA sec. 12(a)(2)(G) makes it a violation of federal law for any person "to use any registered pesticide in a manner inconsistent with its labeling." All registered pesticides, including registered consumer pesticides, must bear the statement:

"It is a violation of Federal law to use this product in a manner inconsistent with its labeling." 40 CFR (i)(2)(ii).

Section 2(ee) of FIFRA provides limited exceptions to what is considered "in a manner inconsistent with" labeling. For instance it is not a violation to use a pesticide at a rate lower than that specified on the label unless the label specifically prohibits deviation from the specified rate.

We recently are putting together a label for supplemental distribution. The primary registrant is telling us to avoid using any parentheses on our label (even though theirs has some). Our particular statement where we use parentheses is dosages. We typically state use x to y ppm (a to b gals per gallons). Where a and b are simply converted values of x and y. Is this wrong? LC; 4/6/10

In general, EPA allows the use of parentheses on a label unless: 1) the parentheses are used in such a way that the labeling becomes false and/or misleading or 2) the use of the parentheses causes confusion making the directions for use inadequate to protect human health or the environment. The example you cite where you provide correct ppm information to the user based on the rate on the label would generally be an acceptable use of parentheses on a label.

Please note, however, that the label of a distributor product must be identical to the master label of the parent product, except as provided in 40 CFR (d). A supplemental distributor may not present statements in parentheses on a label unless the master label of the parent product also contains the same statements in parentheses. Further, the supplemental distributor may not delete statements in parentheses that appear on the parent product's label unless they involve one of the changes allowed in 40 CFR (d).

What constitutes a label's "front panel"? LC; 4/6/10

The front panel is generally regarded as the part of the label that is (normally) visible to the user, consumer, etc. when the product is in a retail environment. At a minimum, the front panel must contain the following information:

  • Restricted Use Product statement (if applicable)(40 CFR (j)).
  • Product Name, Brand or Trademark (40 CFR (b)).
  • Ingredient Statement (unless permission is granted to place it elsewhere due to impracticability) (40 CFR (g)(2)).
  • Keep Out of Reach of Children Statement (40 CFR ).
  • Signal Word (40 CFR ).
  • First Aid (or referral statement if First Aid is allowed on other parts of the label) (40 CFR (d)).
  • Skull & Crossbones Symbol and the word Poison (if applicable) (40 CFR (a)(1)).

In addition, generally the net weight or contents also appears on the front panel. See Label Review Manual Chapter 3, VII.

Device labeling: 40 CFR part makes the labeling requirements of Part applicable to Devices (Ultraviolet light systems or ultrasonic devices). However, nearly all Part requirements are phrased as applying to 'pesticide products' (not Devices), and otherwise are logically applicable only to substances, not devices (e.g., requirements tied to chemical concentrations and toxicity values). Has the Agency issued guidance concerning which of the detailed Part requirements are intended to apply to Devices, or the Agency’s expectations concerning how those requirements would be applied to Devices? LC; 3/11/10

The Agency has not issued guidance on what specific 40 CFR Part labeling requirements must be on device labels. However, some of the labeling requirements include but are not limited to that the device:

  • cannot bear false or misleading information;
  • must bear the number of the registered EPA Establishment where the device was produced; and
  • must bear adequate directions for use and warning or caution statements to prevent unreasonable adverse effects on the environments.

My question is in regards to shipping containers and the labeling of them. For example: A company produces a pesticide product that is put into a container for sale. This container is labeled per FIFRA requirements using the most recent EPA stamped accepted label. These containers are then placed in a cardboard box, whose sole purpose is to provide for ease of transporting the product. Once the box is received at the final destination, it is either put into stock until a pesticide container is needed or the pesticide containers are removed from the box and placed into use. Given this scenario:

  1. Does the box need to have the same exact labeling attached to it as the containers inside? Again, the box serves no other purpose except for transporting the pesticide containers.

  2. Are there any restrictions/requirements for the labeling on the outside of the box (e.g. Product name, company name and contact information, number and quantity of containers)? LC; 3/11/10

40 CFR (a)(4)(i) states that: “The label shall appear on or be securely attached to the immediate container of the pesticide product.” The regulations go on further to state: “If the immediate container is enclosed within a wrapper or outside container through which the label cannot be clearly read, the label must also be securely attached to such outside wrapper or container, if it is part of the package as customarily distributed or sold.”

If the pesticide product is customarily removed from the shipping container prior to being distributed or sold to the retail purchaser, the shipping container does not have to bear the full product label. If the shipping container is the unit which is customarily distributed or sold to the retail purchaser the shipping container must bear the full product label. Even where the shipping container is not required to bear the full product label, any information on the shipping container is labeling, and labeling that is false or misleading would be in violation of FIFRA. While the regulations do not specify particular labeling for shipping containers, the Agency recommends that the shipping container be labeled with enough information for emergency personnel to be able to identify the material in the shipping container in the event of an accident or spill. Be advised that DOT requirements may require labeling of the shipping container depending on the characteristics of the material being shipped.

Is there a regulation that specifies that only an EPA-registered establishment can affix "stickers" to its pesticide labels? LC; 12/10/09

Affixing a sticker to a container is considered labeling and therefore production as defined in 40 CFR 40 CFR (a)(1) requires any establishment where production occurs to be registered. Affixing a sticker must take place in a registered establishment.

When active ingredients, manufacturing-use products or end-use products are being imported into the United States and the proper U.S. labeling is present, are these products allowed to have other country or international labeling on the product container as well? (LC)

Generally, to be sold or distributed in the United States, a pesticide must be registered and must be labeled in accordance with the requirements of 40 CFR part The label (all written, printed or graphic matter on, or attached to, the pesticide) and any other labeling (written, printed or graphic material which accompanies the product or is referenced to on the label) may not be misbranded (e.g. false or misleading) as set forth in FIFRA section 2(q)(1)(A) and 40 CFR part Labeling language that is in addition to that required by FIFRA and its implementing regulations may be allowed if it is not false or misleading. Therefore, so long as the international labeling is not false or misleading, or otherwise causes the pesticide to be misbranded, it may be allowed on a product container (or accompanying the product) in addition to the U.S.-required labeling. Determining whether specific international labeling would be allowed requires a case-by-case comparison of the U.S. label and the international label.

Some pesticide products have a container label and a booklet containing the directions for use attached to the container. The EPA Label Review Manual spells out the requirements for the container label but it does not specify requirements for the booklet. What are the minimum requirements for booklet labels? Do they need to have the EPA registration number? What other information must be included in these booklets? LC

The booklet is considered “labeling,” defined in part as: “all labels and all other written, printed, or graphic matter (A) accompanying the pesticide or device at any time; or (B) to which reference is made on the label or in literature accompanying the pesticide or device.” FIFRA § 2(p)(2). Labeling must meet the requirements of 40 CFR Part  and must not be false or misleading. Most of Part speaks directly to what must be on the affixed label; however, EPA allows in 40 CFR (i)(1)(ii) for directions for use to be printed on labeling other than the affixed label such as in booklets, at the Agency’s discretion. EPA has not set forth minimum label requirements for accompanying literature (booklets). However, when directions for use will appear in accompanying literature such as a booklet, EPA will work with the registrant to determine what other labeling elements must also appear in the booklet so that the labeling as a whole is not false or misleading and ensures proper usage of the product.

Does the Label Review Manual (LRM) Chapter 3 section entitled "Container Label Contents When Booklets are Used" also apply when a product is attached to a "blister card" for sale? That is, does minimum labeling on the bottle need to include the 11 listed items and the rest of the information can be on the card that holds it? Where should the First Aid Statement appear? (LCO)

FIFRA and the Agency's implementing regulations establish the applicable requirements for which statements must be on the product label itself. In particular, 40 CFR (a) requires certain items to be included on the affixed label while 40 CFR (i)(1)(ii)(B) allows limited flexibility by allowing the directions for use to appear elsewhere if properly referenced on the affixed label. The affixed label must be "securely attached," meaning it can reasonably be expected to remain affixed during "the foreseeable conditions and period of use of the product." Generally, it is not acceptable to print the required label items only on the "blister card" because the blister card is a part of the packaging that is usually discarded as the product is opened and therefore could well be discarded even before the user first begins to actually use the pesticide product (and is almost certain to be discarded before additional applications if the product is used more than once).

An antimicrobial product formulated as a strip is sold in a package containing 12 and 24 strips. At the present, the label is placed only on the outer package and not on the individual units. Do the individual units also require a label? (LC)

Because the strips themselves are the pesticide product, they do not need to be individually labeled because 40 CFR (a)(4) requires labels to be securely attached to the immediate container of the product and not the product itself. If the strips were sold or distributed individually, then the individual package for each strip would need to be labeled. To ensure that the strips are not sold or distributed individually, one might consider adding to the label(s) a statement such as “Individual strips are not for resale.” With today's technologies, it may be difficult to determine what is the immediate container and whether your product is correctly labeled. We encourage applicants and registrants to discuss your packaging options when discussing labeling in order to avoid possible misbranding violations once the product is sold or distributed.

What is OPP’s policy with respect to embossed labeling?(LC; 09/11/

Embossed labeling must meet the requirements of 40 CFR Part (a)(2)(i) and (ii). These sections require that:

“(i) All words, statements, graphic representations, designs or other information required on the labeling by the Act or the regulations in this part must be clearly legible to a person with normal vision, and must be placed with such conspicuousness (as compared with other words, statements, designs, or graphic matter on the labeling) and expressed in such terms as to render it likely to be read and understood by the ordinary individual under customary conditions of purchase and use.

(ii) All required text must:

  • be set in 6–point or larger type;
  • appear on a clear contrasting background; and
  • "not be obscured or crowded."

In general, our preference is that the lettering be adequately raised to be seen clearly and be colored in a pastel color. In the past OPP has found that pastel colors work best for making the label clearly legible and other colors may not be legible and therefore not allowed. OPP also prefers that registrants remove use site language that is not needed on the distributed label if the product is actually being sold or distributed for just a subset of all of its registered uses, so that all label language can be set at a type size greater than 6 point if possible. (For example, if a product is being marketed just for swimming pool use, the cooling tower use language could be left off that label.) 40 CFR (b) allows distribution under a subset of approved labeling provided no changes would be necessary in precautionary statements, use classification or packaging.

For rodenticides in particular, when the label reads "product may be used to control rats in and around home, buildings, etc.", what is the maximum distance from a home, building etc. that the product may be used? (LC 11/1/07)

The term in or around home, buildings, etc., has not been defined from the standpoint of a maximum distance. However, the Agency’s current view is that rodenticide baits intended for use by the general public should only be used indoors and against the outside walls of buildings. EPA intends to require rodenticide registrants to amend those labels that currently allow placement of rat and mouse baits “in and around buildings” to delete that phrase and add language limiting use to “indoors and against the outside walls of buildings.” See Rodenticide Cluster RED, pp. vii, and

In the label review manual, Section 3, regarding Final Printed label/labeling. Please clarify. Would submission of a pdf that is sent to the printer constitute a Final Printed Label or would this still be considered draft? Does a registrant have to take a 2- step approach with the Agency to accommodate state submissions such that a pdf is submitted as an FPL with 2 copies of the actual printed version sent at a later time when available? If a pdf is considered draft labeling, how is the registrant notified that it has been provisionally accepted and within what timeframe? How long does the registrant have to submit the actual printed material? Thank you. LC; 12/13/07

Since the promulgation of EPA's regulatory labeling requirements for pesticides in , technology to produce true and accurate representations of final printed labeling has significantly advanced. To that end, true and accurate representations of final printed labeling for each pesticide product as marketed will be acceptable to meet the requirements of 40 CFR (a)(6). Generally a provisional draft master label will be reviewed and stamped accepted prior to the submission of final printed labeling. OPP strongly encourages applicants and registrants to submit draft labeling electronically. See Electronic Submissions of Labels for more information. Final printed labeling is not stamped approved by the Agency but is filed in the jacket of each pesticide as a record of the label with which the product is being marketed.

RE: Chapter 3 General Label Requirements II.B. Container Label Contents When Booklets are Used: Many products are in small package sizes, i.e., gal, pt, qt, ml and all of the text cannot fit on the base label (even with a front and back bottle label) Could you define EXACTLY what information is required to be on the base label. (LC; 11/29/07)

As described in Chapter 3.II of the Label Review Manual, the following must be on the label which is on or “securely attached” to the container:

  • Name and address of the producer, registrant, or person for whom produced.
  • Restricted Use Statement (if required).
  • Product Name, Brand or Trademark.
  • Ingredient Statement.
  • Signal Word, including Skull & Crossbones, if either are required.
  • Keep Out Of Reach Of Children" (KOOROC).
  • Precautionary Statements, including Hazards to Humans & Domestic Animals and Environmental Hazards.
  • EPA Registration Number and EPA Establishment Number.
  • Either Directions for Use or a Referral Statement to Directions for Use in booklet, if any.
  • Net weight or measure of contents.

Other parts of the label may be placed in a booklet or other “pull off” type labeling. This would include CDirections for Use, which includes C3- Storage and Disposal, and C5-Worker Protection Labeling [see 40 CFR (b)(3) for information on placement and required referral statements], and C4- Warranty Statement.

In addition to the boilerplate surface water label advisories found in the label review manual, numerous other surface water label advisories can be found on labels. Is the language found in the label review manual just guidance to be modified on a case-by-case basis, and if so, is there any other criteria used to determine which language will be used? (LC)

The boilerplate surface water advisory language found in the Label Review Manual is an example of a warning statement that has historically been required on pesticide labels based on: their tendency to run-off and drift; and their potential surface water impacts associated with the use pattern, environmental fate properties of the pesticide, and eco- or human health risks. These environmental fate and risk issues are typically identified during the pesticide risk assessment process. Beyond the boilerplate statement in the label review manual, label advisories may be modified on a case-by-case basis to reduce risk to humans and the environment based on the specifics of the pesticide being reviewed.

I would like to know how closely a pesticide product technical bulletin needs to follow the associated EPA approved label. For example, our pesticide product has all the language in the EPA label. For the technical bulletin used to market the product can we leave, for instance, the first aid instructions off of the technical bulletin? I understand that false or misleading statements cannot be made on the technical bulletin. (LC; 11/13/08)

"Technical bulletin" is not a defined regulatory term under FIFRA and therefore it is important to understand the nature of the bulletin described in order to answer. Upon clarification, it was found that the technical bulletin described in the question is a marketing brochure to sell the product and to provide information to customers and is not labeling as defined by FIFRA § 2(p). It would not accompany the product and there is not a reference to the bulletin on the product label. EPA does not have requirements for statements included on such a technical bulletin that is not a part of the labeling. However, it must not have claims that differ from the product label. See FIFRA § 12(a)(1)(B). If a registrant wishes to include additional claims in non-labeling marketing materials, such claims must be submitted as part of the statement of claims to be made that is required for registration under FIFRA § 3(c)(1)(C).

In PR , EPA states that label advisory statements can only be added or changed by amendment. It is silent on how to delete advisory statements. A previous PR Notice, Search EPA Archive, states that advisory statements can be deleted by notification. Is this still the case? (LC; 5/15/08)

PR Notice states that label advisory statements can only be added or changed by amendment, but does not specifically mention deletion of advisory statements. An earlier PR Notice, , states that adding, revising or deleting advisory statements may be accomplished by notification. However, a later PR Notice, , modified PRN by stating that any advisory statements required by EPA may not be deleted by notification. With regard to deleting advisory statements the questioner is correct that the latest PR Notice, , is silent on the issue and therefore we conclude that the earlier PR Notices and are both still applicable. Registrants may continue deleting non-required advisory statements by notification. However, PR Notice is also still applicable in that advisory statements required by EPA (for example, a ground water advisory) may not be deleted by notification and therefore may only be deleted by amendment.

We have a situation where we need to affix bar code stickers to already produced product (cartons & containers). The sticker would be completely separate from the product label containing the FIFRA required contents. Will adding the stickers be considered "production", thus requiring it to be done at an EPA establishment? I saw on this site that affixing stickers is considered labeling and therefore production as defined in 40 CFR. However, is that for FIFRA required contents ONLY or all stickers (including non-notification types)? LC; 10/23/12

PR Notice discusses the revision, addition or deletion of non-FIFRA related label elements through non-notification. The PR Notice goes on to list lot or batch codes, bar codes or other production identifiers as examples of changes that may be made to product without notifying EPA. Provided the bar code sticker is not being added to label to meet a labeling requirement and the bar code does not cover or obscure any required label element, EPA does not consider the placement of the bar code sticker on cartons and containers to be production that must occur in a registered establishment.

A. General Labeling: Use Classification

Must the statement “Restricted Use Pesticide" appear at the very top of a section 3 supplemental or SLN label? Can other wording or symbols appear above the RUP statement? (LC; 11/20/08)

Under the regulations (40 CFR (j)(2)(i)), restricted use products must bear statements of restricted use classification at the top of the front panel. The Label Review Manual (Chapter 6. III.B.1) and PR Notice both reflect this regulatory requirement that the statement must be at the very top of the label's front panel and also state that no other wording or symbols should appear above the RUP statement. This applies to all labels including section 3 supplemental and 24c Special Local Needs (SLN) labeling.

B. General Labeling: Product Name

Regarding pesticide product names, does the EPA consider use of the term "Expert" such as in "Expert's Choice" in a brand name to be false and misleading? If so, why? LC; 9/30/09

The Agency considers the use of "expert" such as in the name "Expert's Choice" to be potentially false or misleading because the term has no objective established meaning. "Expert" appears to refer to some individual or some sort of group of people, neither of which are further defined or identified. 40 CFR (b)(2) states that “No name, brand or trademark may appear on the label which: (I) Is false or misleading, …..” If pesticide labeling is false or misleading in any particular, the product is misbranded and it is a violation of FIFRA to sell or distribute a misbranded pesticide. See FIFRA 2(q)(1)(A); 12(a)(1)(E). Unless an applicant can prove otherwise to the Agency, for instance through consumer surveys, or can provide some objective meaning that is supported by evidence to "expert" on the label, the Agency considers the term “expert” (in any context) to be false and misleading.

A question about the appropriate name and address used on a pesticide label: An international company holds the registration for a product and are the manufacturer. Their USA subsidiary acts as their agent in registration activity. Is it acceptable to indicate the name and address of the USA company with the qualifier of "Manufactured by [name of registrant]" for: [USA subsidiary]". The USA subsidiary would also like to show their logo on the label. (LC)

40 CFR (c) requires that the name of the producer, registrants, or person for whom the product was produced be indicated on the label. Names of non-producers may be included if they are qualified by phrases such as "Packed for," "Distributed by," or "Sold by." More information is available in the Label Review Manual, Chapter In the case presented in the question, the name and address of the registrant would be the foreign company. The US agent may be indicated if properly qualified. In addition, there would be no problem with the use of the US subsidiary's logo as long as it was not misleading or otherwise inconsistent with FIFRA or its implementing regulations.

Regarding product names, page of the Label Review Manual says "Exact same name cannot be used for different products registered by any one registrant." In the case of registration transfer (purchase/merger) where supplemental distributor registrations must be reestablished under a new EPA registration number, must the same product (with the new registration number) have a new name when the supplemental distributor form is submitted? In effect, does a new EPA registration number as a result of a transfer constitute a "different product"? (LC)

40 CFR (b) requires the name, brand, or trademark under which a pesticide product is sold to appear on the front panel of the pesticide's label. It is acceptable for a product distributed under supplemental distribution (40 CFR ), as distributor product, to use the same name as the "parent" product. That product name would be reflected on the supplemental distribution form. In the case of a purchase/merger of two companies, the original supplemental distribution registrations go away and new supplemental distribution registrations are created with the filing of new distributor forms.

If a company acquires a FIFRA section 3 registered product with the same name as one of their existing products, one of the two product names must be altered to some degree so that no two products of the registrant have the exact same name.

The California Department of Pesticide Regulation would like confirmation on the following issue: U.S. EPA does not allow for the words "total" or "complete" as part of a product's name, unless it is part of the brand name - such as "Safer Brand" or "Total Killer Brand" (LC)

It has been the agency's policy not to allow the use of terms such as "total" or "complete" as part of product names because such use may be false or misleading. Use of terms such as "total" or "complete" may be allowed as part of a brand name so long as the brand name is presented in a non-misleading way. The Agency will work with registrants to fit potentially misleading brand names into the context of a label so that they are not misleading.

The LRM states a registrant cannot have two products registered under the same brand name. What if the registrant is issued more than one firm number under the same company? Does "registrant" encompass all firm numbers issued to the company under one name or would a "registrant" with multiple firm numbers be allowed to sell two products with the same name, if the only distinguishing factor is the EPA Reg. Numbers? (LC; 8/28/08)

40 CFR (b) states that the name of a product must appear on the front panel of the label and it cannot be false or misleading. The name may be considered to be false or misleading unless it is sufficiently different to enable a user to distinguish one product from another and the exact same name cannot be used by any one registrant for different registered products. See Label Review Manual Chapter The Agency would consider the same name for two different products under the same company name to be misleading regardless of whether the registration numbers are different due to multiple company numbers. A similar question was previously answered, LC

Can EPA register a product for one company with the same name of a product already registered by another company? (LC; 2/28/08)

Section 2(q)(1)(C) of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) states that a product is misbranded if “ it is an imitation of, or is offered for sale under the name of another pesticide.” Further, 40 CFR (b) states the names may not be false or misleading. We believe the best reading of the statute and regulations is that each product must have a unique name taking into account the name, brand or trademark in context. Thus, a company could not have two products with the same name but two different companies could potentially have a product with the same name because they would be distinguishable based on their company name. This interpretation stems from what is allowed under FIFRA and 40 CFR (b); it does not take into account any limitations on having the same name based on copyright or trademark laws.

The label for a registered product using an alternate brand name (ABN) includes only one set of usage directions from the approved master label. If additional use sites/directions (already approved on the master label) are added to the label of the ABN product, does a notification to EPA need to be filed? (LC; 9/22/08)

Already-approved use sites and use directions can be incorporated onto an alternate brand name label without notification to the agency. Before any new use sites or new use directions can be incorporated on the alternate brand name label, they must first be approved and stamped accepted on the product’s master label.

An alternative brand name product label is an example of a “split label” (a label that bears claims and directions for only a portion of the approved uses under a given master label, but is a complete label in itself, containing all the required labeling elements). Agency regulations allow a registrant to distribute or sell a product under a “split label” provided that in limiting the uses identified on the label, no changes would be necessary to the precautionary statements, use classification, or packaging of the product as stated in 40 CFR § (b). Furthermore, since split labels only contain labeling text contained in the already approved master label, the split labels are not stamped “accepted” separately and don’t require notification.

C. General Labeling: Name and Address of Producer/Registrant

The following company is listed on the EPA official company name list as follows: ABC CHEM CO dba (doing business as) XYZ COMPANY. On the label, how must the company name be declared? In other words, is it acceptable to list either of the company names, or must both company names be declared as listed in the EPA database. (LC)

40 CFR (c)(6 pp, K, About PDF) requires that the name and address of producer, registrant, or person for whom produced be included on a pesticide's label. The requirement allows that the name appearing on the label can be qualified in several ways. For the example above, using XYZ Company would be acceptable. EPA does, however, need to be able to link the company names appearing on labels with company names appearing on registration documents. Therefore, EPA asks that companies change their registration documents to reflect the company names used on labels. See Chapter 15 of the Label Review Manual for more information.

Is it acceptable to have the statement "Produced For" (or similar appropriate wording) on the label to qualify the registrant's name when the registrant is the manufacturer? For example, some of Registrant X's product is produced by the registrant and some is produced by another producer. The registrant would like the label to read "Produced For X" in both instances. (LC, 1/24/08)

40 CFR Part (c) addresses how the name and address of a producer must be represented on the label. The regulations are clear that an unqualified name and address is considered the name and address of the producer. If the producer is not the registrant and the name of the registrant appears on the label, the registrant's name and address must be qualified by terms such as “Packed for,” “Distributed by,” or “Sold by."The regulations are silent on whether the registrant could have the term “Produced For” or similar qualifier preceding their name and address on the label even when they are the producer of the product. Therefore, in a situation where the registrant is the producer of the product, the registrant’s name and address may appear either unqualified or qualified by an appropriate term such as “Distributed by” or "Produced for" so long as they qualification is not false or misleading. See FIFRA sec. 2(q)(1)(A)

The Agency states that a street address or P.O. Box, in addition to the city and state, are necessary for the proper delivery of mail. Does the Agency agree that in certain cases, where a facility-specific zip code exists, a zip code plus extension which is unique to a registrant may meet the standard of including an address necessary for proper delivery of the mail without including a full street address on the product label? (LC and LC 11/1/07)

The agency agrees that a zip code that is unique to a given registrant and adequate for the delivery of mail would meet the requirement of "address" as discussed in 40 CFR (a)(ii) and 40 CFR (b)(2).

Must the label of a registered pesticide set forth the actual "street" address of the company or may the address be set forth as follows: ABC Company, Albany, New York ? (LC)

In accordance with the regulations at 40 CFR (a)(ii) the label must show clearly and prominently the name and address of the producer, registrant or person for whom produced. 40 CFR (b)(2) also discusses an "address" requirement. That regulation states that a registrant must provide EPA with a current address that will be used by the Agency for corresponding with the registrant. It is also sufficient to provide company name, city, state, and a unique zip code where the zip code includes a PO box as part of the suffix.

D. General Labeling: Product Registration

We manufacture a pesticide product and sell it to a company in a state where our product is currently registered. Can the company resell our product in the same package and label to states where our product is not registered. Who is responsible for getting the products registered in the other states? LC; 10/21/13

Under Federal Law, only a federal registration is required to sell and distribute a pesticide. All states, under individual state laws, require that pesticides be registered in their state before they can be sold and distributed. The laws of the state where a sale or distribution occurs will determine who is responsible for any required state registration.

I would like to know or have someone define the term EPA File Symbol number on a section 18 product. Why does the product not have an EPA Registration number? (LC)

An EPA file symbol (a registrant’s company number followed by a sequence of letters) is a symbol that the Agency uses to identify a pending new product registration action. Once the agency completes action on an application for registration of a new pesticide product and registers the product, the file symbol is changed to a registration number (a registrant’s company number followed by a set of numbers).

Under section 18 of the Federal Insecticide, Fungicide and Rodenticide Act the Administrator may authorize the use of an unregistered pesticide or unregistered use of a registered pesticide (including an unregistered pesticide product) if an emergency condition exists as described under 40 CFR Part Some products authorized for use under section 18 have been submitted for registration and have therefore received an EPA file symbol. The agency has not taken final action with respect to registering the product but has authorized its use under section

These products could have an EPA file symbol assigned to them and that symbol may be included on a label, however, the product may only be used in accordance with a section 18 exemption granted by the Agency.

E. General Labeling: Establishment

Does the EPA Est. No. need to appear on the device itself or is it adequate for it to appear only on the container package? LC; 08/16/13

According to 40 CFR (b)(1), devices are subject to the standards for misbranding under FIFRA § 2(q)(1) and the labeling requirements set forth in 40 CFR Part Section 2(q)(1)(D) provides that a product is misbranded if “its label does not bear the registration number assigned under [section 7] to each establishment in which it was produced.” 40 CFR (f) states that the EPA establishment number may appear in “any suitable location on the label or the immediate container.” If the establishment number on the immediate container cannot be clearly read through an outer wrapper or container, then the establishment number must appear on the outer wrapper or container as well.

In the marketplace I've seen examples of products that have a complete EPA Establishment # coded on the container of a product in a format such as "EPA EST XXXX-XX-XX" when the product in the container is not a registered pesticide. In the examples that I've seen, there are no pesticidal claims on the product, only the inclusion of the establishment #. Would this be considered misbranding, or some other violation of FIFRA? LC; 05/02/11

An EPA Establishment Number coded on a container, in the absence of any pesticidal claims by the product labeling or advertising, would not make the product subject to FIFRA in most circumstances. If the presence of an establishment number is intended to imply the product has pesticidal effect or if consumers are misled by the establishment number to believe the product has a pesticidal effect, the product may be subject to FIFRA. Note that pesticide device packaging must bear the EPA establishment number for the place where the device was produced, so some unregistered products that bear establishment numbers may be devices. Further, labeling for all products are subject to the requirements of the Federal Trade Commission, which can take action against false or misleading claims.

An aerosol can is filled at one establishment (Est. No. 1) then shipped to a second establishment (Est. No. 2) for packaging into a box with a non-pesticidal product. The can has Est. No. 1 on the label. The can label itself is not being modified, just placed into the box. Since the can is being repackaged into the box, the box has Est. No. 2 on the label. Does the Est. No. on the can need to be changed to Est. No 2? Or should Est. No. 1 remain on the can with only the box reflecting Est. No 2? LC; 7/7/11

In the instance of an aerosol can filled at one establishment and packaged at a second establishment, the immediate container (the aerosol can) must bear the establishment number of the establishment where filled (Est. No. 1). The box that the aerosol can is placed in must bear the establishment number of the facility where the repackaging occurred (Est. No. 2). Both establishment numbers may appear because they can be easily associated with different steps in the packaging of the product. Please also note that if the full label of the aerosol can cannot be read through the outer package, the full label of the product must appear on the outer package.

We have a pesticide in a small size container that may be sold as is, in a blister card, or in a box. The pesticide is manufactured and labeled at one establishment with that company's establishment number on the immediate product label. We would like to have the opportunity to have a second or third company place the product in a blister card or box.

  1. Can the blister card/box have a different establishment number than the immediate container?
  2. Can the blister card list two or more establishment numbers, with the phrase "See lot number for Establishment identification"? i.e. a "T" in the lot number would identify the establishment within Tennessee." LC; 5/19/11

40 CFR part requires that all pesticides must be produced in an establishment registered with EPA. The definition of produce includes not only the manufacturing of pesticides but also packaging and repackaging of pesticides. If a pesticide container is placed in a blister card or box the packaging must take place in a registered establishment and the establishment number of the establishment appear on the package. If the packaging in the blister card or box takes place in a different establishment than where the original container was filled, the establishment numbers on the immediate container and the blister pack or box will be those of different establishments.

The blister card or box may list more than one establishment number as long as the correct establishment number where the last production step occurred is clearly visible on or through the outer container or wrapper and there is some designation to distinguish which establishment number applies. See 40 CFR (f). If the lot number is used to designate the appropriate establishment number, the label must explain how to interpret the lot number; i.e., “Letter at the end of the lot number designates the establishment number of the producing establishment. “T” = Tennessee, “O” = Ohio.” This statement should appear below the multiple establishment numbers. See also the Label Review Manual, Chapter 14(IV)(C).

Is there a penalty for false use of an EPA Establishment number (use by someone other than the entity which has been assigned that number)? LC; 3/11/10

Using a false EPA Establishment Number is considered misbranding as defined by section 2(q)(1)(A) of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), which states that a pesticide is misbranded if “its labeling bears any statementwhich is false or misleading in any particular.” Under Section 12(a)(1)(E) of FIFRA, the sale or distribution of any pesticide which is misbranded is unlawful. Violators may be assessed a civil penalty of up to $5, for each offense or a criminal penalty of up to $50, or 1 year imprisonment, or both, plus inflation adjustments provided by law.

Does the establishment number have to be on the master label before EPA will stamp the label? (LC; 09/11/)

No. 40 CFR (f) states: The producing establishment registration number preceded by the phrase “EPA Est.”, of the final establishment at which the product was produced may appear in any suitable location on the label or immediate container. Since the establishment number does not have to be on the printed label, but may be placed on, printed on, or embossed onto the container itself, it is not necessary for the establishment number to be on the master label.

Does changing of an EPA Establishment Number appearing on an approved label require notification or may the EPA Establishment Number be changed without notification? (LC)

The EPA Establishment number can be placed on either the label or the product container. PR Notice allows under Non-Notification, factual statements about where the product is made, which could include the Establishment Number. Therefore, the number can be changed without notification. The product must indicate the Establishment Number of the final establishment at which the product was produced.

Pesticides are often stored at a terminal facility in large stationary bulk tanks prior to shipment to a customer. Is an EPA establishment number required if the terminal transfers pesticide product from one tank to another? What establishment number would go on the tank, the formulator’s or the terminal’s? (LC06–)

If the terminal is transferring pesticides as part of the distribution of the product, it is not required to register as an establishment. The transfer is considered part of the process of shipping the pesticide to the retailer and ultimately the end-user. If, however, the terminal is transferring the pesticide to another container acting as a refilling establishment, the terminal must register as an establishment and put it’s establishment number on the refilled container.

We ink jet lot numbers on the primary container and master case. Also, registration and establishment numbers are printed on the primary label as well as the master case label. Do the registration and establishment numbers need to appear on the master case? (LC)

The registration and establishment number are not required to appear on the master case if the pesticide product is removed from the master case before being sold to the end-user. If the master case is the outer container as customarily distributed or sold to the user, 40 CFR (a)(4)(i) requires that the full label must appear on the master case, including the registration and establishment numbers. As a matter of general practice, EPA recommends that the master (outer) case bear identification of the product within to allow quick identification of the product in the case of an accident or spill. In addition, the person shipping the pesticide must ensure that the shipment meets all applicable Department of Transportation (DOT) regulations.

F. General Labeling: Misuse Statement

Should a person importing unregistered pesticides per the exceptions at 40 C.F.R. § (a), (b), (c)(2) or (d) include on the labels of those products the statement set forth at 40 C.F.R. § (i)(2)(ii) (“It is a violation of Federal law to use this product in a manner inconsistent with its labeling”) (“misuse statement”)?  (LC; )

In most cases, the misuse statement should not be included on the labeling of unregistered products being sold, imported or otherwise distributed in the U.S. because the statement would be false. The violation referred to in the misuse statement is a violation of section 12(a)(2)(G), which only prohibits misuse of registered products. Generally, it is not a violation of FIFRA section 12 to use an unregistered pesticide in a manner inconsistent with its labeling. Exceptions may exist based on an EPA order that imposes restrictions on the use of a particular unregistered product (e.g., a cancellation order that allows further use of the now unregistered pesticide), or as the result of an EPA regulation pursuant to FIFRA section 3(a).

If the misuse statement would be false as to a particular unregistered product, then including the statement on that product’s labeling would render it misbranded. Sales or distributions of misbranded pesticides that are not permitted by EPA order are violations of FIFRA section 12(a)(1)(E). Further, misbranded products generally cannot qualify for legal sale or distribution through the above-listed exceptions at section (a), (b), (c)(2) or (d), and therefore imports of such pesticides may be a violation of FIFRA section 12(a)(1)(A).

G. General Labeling: Ingredient Statement

Many registrants list ATCC numbers in parentheses after a specific bacteria. If the ATCC number is present on the EPA stamped "accepted" label, must it also be present on the final marketplace label or may the registrant omit the ATCC numbers from their final product labeling? (LC; )

In the past, EPA requested that American Type Culture Collection (ATCC) numbers appear on the final printed labels of products. However, after further consideration, EPA determined that while the ATCC numbers are necessary for the Agency microbiology reviewers as identifiers for the microorganisms tested and listed on product labels, they may not have the same level of significance to the end-users of the products. Therefore, the Agency now allows a company to list ATCC numbers in one of the following locations:

  • On the data matrix provided to the Agency.
  • On the master label (as optional text) with the listing of the organisms claimed, or As the final page of the master label (as optional text).

Thus, ATCC numbers do not have to appear on the final product labeling since the ATCC numbers may be placed on the label as optional text.

In the case of a "Bag-On-Valve" (BOV) pesticide product, as pressurized gas is released within the canister, a bag containing liquid pesticide - which bag is within the canister - is squeezed in order to expel the pesticide. Should the net contents be expressed in terms of liquid measure under 40 CFR (d)(2), or as pounds and ounces under 40 CFR (d)(3)? LC; 08/16/12

As described in the question, the pesticide within the bag is a liquid, suggesting that the net contents must be expressed in terms of liquid measure under 40 CFR (d)(2). Additionally, the bag is contained within a pressurized canister, suggesting that the net contents must be expressed in terms of weight under 40 CFR (d)(3). Because the pesticide is both liquid and pressurized, the net contents of BOV pesticide products must be expressed in terms of both liquid measure and weight.

H. General Labeling: Precautionary

If the active ingredient of a pesticide product is a microbial is the following statement required on the label:

"Mixers / loaders and applicators must wear a dust / mist filtering respirator meeting NIOSH standards of at least N, R or P Repeated exposures to high concentrations of microbial proteins can cause allergic sensitization."

If the above statement is a requirement, where is that requirement stated? LC; 3/3/11

Microorganisms are often strong sensitizers, and this precautionary label statement is required on microbial pesticides on a case-by-case basis to mitigate the potential risk of allergenicity from repeated inhalation exposure to airborne microbial particles.

This statement was first used during the Bt reregistration process. An earlier version of the statement was included in the Bt Reregistration Eligibility Decision document (RED). When the 40 CFR Part data requirements for microbial pesticides were amended in , the preamble to the rule included a rationale for requiring the dust/mist filtering respirator (refer to The Federal Register, Vol. 72, No. , Friday, October 26, , page “Notice, Pesticides: Data Requirements for Biochemical and Microbial Pesticides”). The Notice states, “The Agency expects that many microbial pesticides may be respiratory sensitizers, although there are no consistently reliable laboratory tests for this endpoint. Therefore, in general, the Agency requires protective equipment to lessen exposure to microbial agents for applicators with a high likelihood of repeated exposures.” Since then, when the Agency has had concern that a microbial pesticide may be a respiratory sensitizer and no information is available showing otherwise, the Agency has required the inclusion of a directions for use of a respirator to protect against sensitization when there is potential for inhalation exposure. Information showing a specific microbial pesticide is not a respiratory sensitizer would be considered and may lead EPA to determine this precautionary statement is not necessary for that specific pesticide.

In what size font must precautionary statements such as "Don't use with oil" be? LC;

All words, statements, graphic representations, designs or other information required on pesticide labeling must be set in no smaller than 6 point font. 40 CFR (a)(2). In addition, required content must appear on a clear contrasting background, not be obscured or crowded and be rendered so that it is likely to be read and understood by the ordinary individual under customary conditions of purchase or use. Precautionary statements must abide by the same 6-point font minimum, except when larger fonts are required for front panel precautionary statements such as signal words and child hazard warnings. 40 CFR (b) provides a table indicating the minimum required font size for front panel precautionary statements, which increases with the size of the label.

This question is in regard to placement of the First Aid statements on a Category I (Danger) product. Our understanding is that if the signal word is "Danger" the First Aid statement must be on the front panel unless EPA grants an exception. If EPA stamps accepted on a label that includes the sentence "See side [back] panels for first aid and additional precautionary statements" under the signal word, is that considered permission by the agency to move the First Aid section off the front panel? (LC; )

Yes. According to 40 CFR (d), first aid statements must appear on the front panel for all Toxicity Category I products, but the regulation allows for variation upon review if the proper reference statement is on the front panel. To request variation from the standard requirement, a registrant must explain to EPA why they believe it would be more practical for the information to appear elsewhere. EPA’s approval of the label with the variation is evidence of its acceptance.

What is the difference between the label signal words "dermal sensitizer" and "dermal irritant"? I understand the fact that there are four categories for dermal irritation, whereas there is only one for dermal sensitization, either the product is or is not a dermal sensitizer. Dermal irritants can cause erythema and edema, whereas dermal sensitizers have the potential for allergic contact dermatitis. However, contact dermatitis can be characterized by erythema (redness of the skin) and edema (essentially swelling). I could use some clarification. Thank you much. (LC; 9/24/07)

First, "dermal sensitizer" and "dermal irritant" are not signal words. Signal words are described in 40 CFR and are limited to "Danger," "Warning," and "Caution." Signal words are associated with four numbered EPA toxicity categories. These numbered toxicity categories correspond to the following tests: oral and dermal LD50, inhalation LC50, eye and dermal irritation. These tests are based on a single exposure to a substance. In contrast, dermal sensitization is an immunologically mediated cutaneous reaction to repeat exposures to a substance. Dermal sensitization is not part of the numbered toxicity categorization scheme. Pesticides either are or are not dermal sensitizers. Whether a pesticide is a dermal sensitizer is based on tests as described in OPPTS You are correct that the two endpoints (dermal irritant and dermal sensitization) correlate; and that is why the OPPTS skin sensitization procedures state the highest nonirritating dose be used for the Beuhler and GPMT tests. While no signal word is associated with dermal sensitization, products that test positive for dermal sensitization may be required to bear precautionary label language for this endpoint such as: "Prolonged or frequently repeated skin contact may cause allergic reactions in some individuals." See 40 CFR

Will the Agency allow the use of the GHS explosiveness symbol and the GHS flammability symbol on pesticide labeling? Is use of these symbols limited to NAFTA labels? (LC; 5/15/08)

The Agency will allow the use of the GHS (Globally Harmonized System for Hazard Communication) explosiveness symbol and the GHS flammability symbol on pesticide labeling and it is not limited to NAFTA labels. 40 CFR requires warning statements on the flammability or explosive characteristics of pesticide products meeting listed criteria. These statements, as applicable, must remain on labels that choose to in addition use the GHS symbols. Further, 40 CFR (d)(3) requires a flammability symbol specifically for total release fogger products and offers an example symbol. The GHS flammability symbol is equivalent and may replace the example provided. GHS symbols may be added by a label amendment and may not be added through notification. The GHS symbols allowed are:

I. General Labeling: Environmental Hazards Statement

Chapter 8. II. D. 4 of the Label Review Manual indicates when Ground Water Advisories are "generally" required. However many labels for outdoor use meeting the specified thresholds do not have such advisories. Imidacloprid meets the specified thresholds for the advisories and has been detected in ground water in Long Island, NY. The labeling for the agricultural product has the ground water advisory, but the label for the termiticide product does not. Why the inconsistency? LC; 1/10/08

As pointed out in the Chapter 8.II.D.4, Ground Water Advisories are “generally” required. The ground water advisory is a case-by-case basis determination depending on the use site and available data. Termiticides uses are generally considered indoor uses because applications involve injection through drilled holes in slabs of constructed houses, or for pre-construction, the soil is sprayed just before the foundation is poured. Under such circumstances, OPP has not generally required ground water advisories.

I. General Labeling: Directions for Use

If an EPA master label contains a range (i.e. ppm or 1 – 3 oz/gallon of water) on the use instructions, can the distributor end-use label bear a specific rate within that range (i.e. ppm or 2 oz/gallon of water) instead of the range if the label doesn’t specify when the higher or lower rate would be needed? LC; 06/04/13

40 CFR (d) requires that labeling for the distributor product be the same as the registered primary product except for: product name, distributor name and address, registration number, establishment number, and deletion of specific claims (provided no other changes are necessary). It is not permissible to list a specific application rate on the distributor product labeling when the application rates on the registered primary product appear in a range. In order for a specific rate to be listed on the distributor product labeling, that one specific rate must appear on the registered primary product master labeling.

Are spreader settings required on the label of granular pesticide products for turf? While especially for consumer products, they may be helpful - spreader models offered often change and it is difficult to include all models. For professional products if the label use rates are clearly given in pounds per acre or sq ft. can spreader settings be provided upon request instead for a specific spreader as long as the information given gives a use rate consistent with the use rates on the label? LC; 7/7/11

Spreader settings are not required to appear on the label of granular pesticide products. The label must include the application rate but calibrations/settings for specific brands of application equipment are not required, regardless of whether the product is for the general consumer or used by commercial applicators. Registrants may provide accurate information if they choose.

When a label specifically states, “Not for sale or use after the expiration date,” is it a violation of FIFRA for an individual consumer to use the product after that date? LC; 9/24/09

Section 12(a)(2)(G) of FIFRA states that “it shall be unlawful for any person to use any registered pesticide in a manner inconsistent with its labeling.” Use after the expiration date is inconsistent with the label directions and would be a violation regardless of the reason the date appears on the label.

Is the February 6, policy decision from the Office of Compliance Monitoring's Policy and Grants Division regarding greenhouse application still current? This policy indicates "that a label must specify greenhouse in order for the product to be applied in a greenhouse". I thought EPA revised this policy, but I was told by another state that this is still EPA's current view. (LC; 5/15/08)

The Agency’s current position on greenhouse application is that in accordance with FIFRA section 2(ee) a label does not have to specify greenhouse as a site, provided the crop is on the label, in order to use the product in a greenhouse.

Labels with non-agricultural use requirements often have statements such as “Do not allow people or pets on treatment area during application. Do not enter treatment areas until sprays have dried…”

Regarding the second sentence of that statement, is it directed at all people or just workers that the applicator has control over? Is it the responsibility of the applicator to make sure that no one enters the treated area until sprays have dried, and if so, how can the applicator accomplish that when applying to roadside right-of –ways and other areas that they cannot realistically control? LC; 11/15/07

The label language cited (or similar labeling) appears on many labels with non-agricultural uses and must be read carefully in the context of the entire labeling of the product. There are many variations of the statements cited above and based on the wording of the statements they may have different meanings. On some labels the prohibitions against entry are specific to certain uses. On other labels the prohibitions are expressed in such a way that the prohibition applies to a broad array of uses.

The prohibition in the language cited above applies specifically to the applicator of the pesticide. The first sentence requires the applicator to keep people or pets from entering the treatment area during application. While the applicator may not be able to control the movement of people or pets into the area, the applicator can and must stop applying the pesticide if people or pets enter the area being treated. The second sentence prohibits the applicator from entering the treated area until sprays have dried. Neither sentence would require the applicator to have a continuing obligation to keep people or pets out of the treated area after application of the pesticide.

Would EPA regulate fertilizer and soil amendment products marketed by company “F” as pesticide products under the following conditions: contains a known synthetic plant growth regulator (e.g NAA and IBA), intends to market these products on food crops or, does not declare the synthetic plant growth regulator ingredients on the label. (LCO)

The Federal Insecticide Fungicide and Rodenticide Act, as amended, defines a pesticide in part as “1) any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pests, 2) any substance or mixture of substances intended or used as a plant regulator, defoliant, desiccant, and 3) any nitrogen stabilizer …” FIFRA § 2(u)(emphasis added).

Regulations established under FIFRA state, in part: “A substance is considered to be intended for a pesticidal purpose, and thus to be a pesticide requiring registration, if:
* * *
“b) The substance contains one or more active ingredients and has no significant commercial value as distributed or sold other than
(1) use for a pesticidal purpose (by itself or in combination with any other substance), (2) use for manufacture of a pesticide;” 40 CFR part (emphasis added)

Under 40 CFR (b), products containing NAA and IBA may be pesticides even if no claims were made on the label.

Intent for a pesticidal purpose is considered on a case-by-case basis and the Agency may determine a product is a pesticide, and therefore requires a registration, regardless of the product’s label claims. If you are unsure whether your product is a pesticide, it would be prudent to contact the Office of Pesticide Programs.

What is the Agency's policy in the event a registrant or manufacturer wants to remove pesticidal claims from a product label in order to avoid the obligation to register the product?

The lack of pesticidal claims on a product does not necessarily mean the product does not need to be registered. The Federal Insecticide Fungicide and Rodenticide Act defines a pesticide in part as "1) any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pests, 2) any substance or mixture of substances intended or used as a plant regulator, defoliant, desiccant, and 3) any nitrogen stabilizer ." FIFRA § 2(u)(emphasis added).

Regulations established under FIFRA state, in part: "A substance is considered to be intended for a pesticidal purpose, and thus to be a pesticide requiring registration, if:
* * * "b) The substance contains one or more active ingredients and has no significant commercial value as distributed or sold other than
(1) use for a pesticidal purpose (by itself or in combination with any other substance),
(2) use for manufacture of a pesticide;" 40 CFR part (emphasis added)

Intent for a pesticidal purpose is considered on a case-by-case basis and the Agency may determine a product is a pesticide, and therefore requires a registration, regardless of the product's label claims. If you are unsure whether your product is a pesticide, it would be prudent to contact the Office of Pesticide Programs.

What is the official EPA definition of an "orchard" in respect to the boundaries? Is it the outside drip line of the trees, or number of feet beyond the drip line, or another criterion? Some do not have fence lines and are part of a larger field. (LC)

EPA has not established an "official" definition of "orchards" as used on product labels. An orchard is considered a distinct use site. Generally, one would take a common sense approach to determining where a product labeled for use in an orchard might end. Normally, one would determine that the orchard would end at the outer edge of the drip line of the last row of trees.

What is the statutory or regulatory authority that the word "should" used on pesticide labels is non-mandatory language. (LC)

Neither the Federal Insecticide, Fungicide and Rodenticide Act ("FIFRA") nor its implementing regulations contain a definition of the term "should." The Office of Pesticide Programs (OPP) recognized the need for clarification of whether the term "should" on pesticide labels is considered mandatory or advisory and issued a Pesticide Registration Notice (PR notice) in (See PR notice ). The statutory basis for this PR notice is section 2(ee) of FIFRA, which defines the term "to use any registered pesticide in a manner inconsistent with its labeling" (i.e., misuse) as use of "any registered pesticide in a manner not permitted by the labeling" The following excerpt from PR notice explains OPP's interpretation of terms such as "should", "may," and "must" as used on pesticide labels.

PR notice states, in pertinent part:

Mandatory statements, which commonly use imperative verbs such as "must" or "shall," either require action or prohibit the user from taking certain action. Advisory statements generally provide information, either in support of the mandatory statements or about the product in general. To ensure that the intent of each labeling statement is clear, mandatory statements need to be clearly distinguishable from advisory statements. Currently, labeling provisions are enforced by taking into consideration all of the information presented on the label and by reading advisory statements in the context of the entire label. Problems can arise when advisory statements are either vague or ambiguous in meaning, or are inconsistent with mandatory labeling statements. In the past, advisory statements have commonly used suggestive verbs such as "should," "may" or "recommend" to encourage the user to achieve the directed behavior, but often these statements can be unclear as to whether they are mandatory or advisory. Advisory language using terms such as "should," "may" and "recommend" can create ambiguities as to the intent of the direction or precaution. Too often, common everyday speech using the word "should" creeps into mandatory label statements where the imperative tense is needed to communicate that certain action is required. Another problem is contradictory headings and statements. A set of mandatory directions preceded by an advisory heading such as "Use Recommendations" potentially conflicts with the nature of the intended action. Lastly, the use of words such as "should" in advisory language can mistakenly imply that an unaccepted use is permissible. For example, the direction "you should remove all food articles prior to use" on a product that is not registered for any food uses could be mistakenly read to suggest that it is not mandatory to remove all food from the area to be treated. Consequently, such a statement would not be acceptable. The Agency seeks to improve mandatory and advisory labeling statements by providing guidance (see Appendix) on how they can best be written. Mandatory statements are generally written in imperative or directive terms (such as "shall," "must," "do this," "do not") so that a typical user will understand that these statements direct the user to take or avoid certain actions, and that failure to follow these instructions is a misuse of the product. Advisory statements are generally best written in descriptive or nondirective terms to support the mandatory statements or provide information. Suggestive terms such as "should," "may" or "recommend" may be confusing or ambiguous, or potentially conflict with mandatory labeling statements; thus, they are to be avoided. EPA realizes that the use of descriptive terms for advisory statements is not appropriate for every situation and that there are times where it may be necessary to use "should," "may," "recommend" or similar words.

What does a 7-day restriction mean? Is it 7 days from time treatment ended (7/24) or does the treatment day count as Day 1 and from then out to Day 7? (LC)

Traditionally the Agency considers the day of treatment to be Day 0. The 7-day restriction (pre-harvest interval) would start with Day 1 which is the day after the initial treatment with subsequent days to follow in order. The Agency has not required the exact time of treatment to be recorded but if someone were to appropriately document treatment ending at, for example a.m. on Day 0, then Day 1 would end at a.m. the next day and so forth.

What is the minimum labeling required on the outside shipping container that is used to transport several individually labeled containers to be sold/distributed separately? (LC)

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Intermodal container

Standardized reusable steel box used for transporting goods

A foot long (&#;m) shipping container. Each of its eight corners has an essential corner castingfor hoisting, stacking, and securing
In there were over 20&#;million intermodal containers in the world.
Making containers stackablemade loading and transport on large ships feasible and efficient

An intermodal container, often called a shipping container, is a large standardized shipping container, designed and built for intermodal freight transport, meaning these containers can be used across different modes of transport – from ship to rail to truck – without unloading and reloading their cargo.[1] Intermodal containers are primarily used to store and transport materials and products efficiently and securely in the global containerized intermodal freight transport system, but smaller numbers are in regional use as well. These containers are known under a number of names, such as simply container, cargo or freight container, ISO container, shipping, sea or ocean container, sea van or (Conex) box, container van, sea can or c can.[nb 1]

Intermodal containers exist in many types and a number of standardized sizes, but ninety percent of the global container fleet are so-called "dry freight" or "general purpose" containers[2][3] – durable closed rectangular boxes, made of rust-retardant Corten steel; almost all 8 feet (&#;m) wide, and of either 20 or 40 feet ( or &#;m) standard length, as defined by International Organization for Standardization (ISO) standard [2][4] The worldwide standard heights are 8&#;feet 6&#;inches (&#;m) and 9&#;feet 6&#;inches (&#;m) – the latter are known as High Cube or Hi-Cube (HC / HQ) containers.[5]

First invented in the early 20th century, modern foot intermodal containers proliferated during the s and s under the containerization innovations of the American shipping company SeaLand. Just like cardboard boxes and pallets, these containers are a means to bundle cargo and goods into larger, unitized loads, that can be easily handled, moved, and stacked, and that will pack tightly in a ship or yard. Intermodal containers share a number of key construction features to withstand the stresses of intermodal shipping, to facilitate their handling and to allow stacking, as well as being identifiable through their individual, unique ISO reporting mark.

In , there were about &#;million intermodal containers in the world of varying types to suit different cargoes.[4][nb 2] Containers have largely supplanted the traditional break bulk cargo – in containers accounted for 60% of the world's seaborne trade.[7][8] The predominant alternative methods of transport carry bulk cargo – whether gaseous, liquid or solid – e.g. by bulk carrier or tank ship, tank car or truck. For air freight, the lighter weight IATA-defined unit load devices are used.


Freight car in railway museum Bochum-Dahlhausen, showing four different UIC pa-containers
Side of Vietnam era U.S. Army steel 'CONEX' box container (3D)
In , many containers still featured riveted aluminum sheet and post wall construction, instead of welded, corrugated steel.[9]

Main articles: Containerization and Conex box

By the s, railways across several continents were carrying containers that could be transferred to other modes of transport. The Liverpool and Manchester Railway in the United Kingdom was one of these. "Simple rectangular timber boxes, four to a truck, they were used to convey coal from the Lancashire collieries to Liverpool, where they were transferred to horse-drawn carts by crane."[10] Early versions of standardized containers were used in Europe before World War II. Construction of these containers had a steel frame with wooden walls, floor, roof and doors.

The first international standard for containers was established by the Bureau International des Containers et du Transport Intermodal (B.I.C.) in , and a second one in , primarily for transport between European countries. American containers at this time were not standardized, and these early containers were not yet stackable – neither in the U.S. nor Europe. In November , the first container terminal in the world was opened by the Pennsylvania Rail Road Company in Enola, PA. The development of containerization was created in Europe and the US as a way to revitalize rail companies after the Wall Street Crash of , in New York, which resulted in economic collapse and a drop in all modes of transport.[11]

In April at Zürich Tiefenbrunnen railway station, the Swiss Museum of Transport and the Bureau International des Containers (BIC) held demonstrations of container systems for representatives from a number of European countries, and from the United States. A system was selected for Western Europe, based on the Netherlands' system for consumer goods and waste transportation called Laadkisten (lit. "Loading chests"), in use since This system used roller containers for transport by rail, truck and ship, in various configurations up to 5,&#;kg (12,&#;lb) capacity, and up to by by 2 metres (10&#;ft 2&#;in ×&#;7&#;ft 6+1&#;2&#;in ×&#;6&#;ft 6+3&#;4&#;in) in size.[12][13] This became the first post World War&#;II European railway standard of the International Union of Railways – UIC, known as "pa-Behälter." It was implemented in the Netherlands, Belgium, Luxembourg, West Germany, Switzerland, Sweden and Denmark.[14]

The use of standardized steel shipping containers began during the late s and early s, when commercial shipping operators and the US military started developing such units.[15] In the U.S. ArmyTransportation Corps developed the "Transporter", a rigid, corrugated steel container, able to carry 9, pounds (4,&#;kg). It was 8&#;ft 6&#;in (&#;m) long, 6&#;ft 3&#;in (&#;m) wide, and 6&#;ft 10&#;in (&#;m) high, with double doors on one end, was mounted on skids, and had lifting rings on the top four corners.[16] After proving successful in Korea, the Transporter was developed into the Container Express (CONEX) box system in late Based on the Transporter, the size and capacity of the Conex were about the same,[nb 3] but the system was made modular, by the addition of a smaller, half-size unit of 6&#;ft 3&#;in (&#;m) long, 4&#;ft 3&#;in (&#;m) wide and 6&#;ft 10+1&#;2&#;in (&#;m) high.[nb 4] CONEXes could be stacked three high, and protected their contents from the elements.[17] By the US military used some , Conex boxes, and more than , in , making this the first worldwide application of intermodal containers.[17] Their invention made a major contribution to the globalization of commerce in the second half of the 20th century, dramatically reducing the cost of transporting goods and hence of long-distance trade.[24][25]

From onwards, engineer Keith Tantlinger repeatedly contributed to the development of containers, as well as their handling and transportation equipment. In , while at Brown Trailers Inc. of Spokane, he modified the design of their stressed skin aluminum foot trailer, to fulfil an order of two-hundred 30 by 8 by feet (&#;m ×&#;&#;m ×&#;&#;m) containers that could be stacked two high, for Alaska-based Ocean Van Lines. Steel castings on the top corners provided lifting and securing points.

In trucking magnate Malcom McLean bought Pan-Atlantic Steamship Company, to form a container shipping enterprise, later known as Sea-Land. The first containers were supplied by Brown, where McLean met Keith Tantlinger, and hired him as vice-president of engineering and research. Under the supervision of Tantlinger, a new 35&#;ft (&#;m) x 8&#;ft (&#;m) x 8&#;ft 6&#;in (&#;m) Sea-Land container was developed, the length determined by the maximum length of trailers then allowed on Pennsylvanian highways. Each container had a frame with eight corner castings that could withstand stacking loads. Tantlinger also designed automatic spreaders for handling the containers, as well as the twistlock mechanism that connects with the corner castings.

Every international shipping container must have a "CSC-Plate"

Two years after McLean's first container ship, the Ideal X started container shipping on the U.S. East Coast,[29]Matson Navigation followed suit between California and Hawaii. Just like Pan-Atlantic's containers, Matson's were 8&#;ft (&#;m) wide and 8&#;ft 6&#;in (&#;m) high, but due to California's different traffic code, Matson chose to make theirs 24&#;ft (&#;m) long. In , McLean began container service to South Vietnam for the US military with great success.

ISO standards for containers were published between and by the International Maritime Organization. These standards allow for more consistent loading, transporting, and unloading of goods in ports throughout the world, thus saving time and resources.[31]

The International Convention for Safe Containers is a regulation by the Inter-governmental Maritime Consultative Organization on the safe handling and transport of containers. It decrees that every container travelling internationally be fitted with a CSC Safety-approval Plate.[32][33] This holds essential information about the container, including age, registration number, dimensions and weights, as well as its strength and maximum stacking capability.

Longshoremen and related unions around the world struggled with this revolution in shipping goods.[34] For example, by a clause in the International Longshoremen's Association (ILA) contract stipulated that the work of "stuffing" (filling) or "stripping" (emptying) a container within 50 miles (80&#;km) of a port must be done by ILA workers, or if not done by ILA, that the shipper needed to pay royalties and penalties to the ILA. Unions for truckers and consolidators argued that the ILA rules were not valid work preservation clauses, because the work of stuffing and stripping containers away from the pier had not traditionally been done by ILA members.[34] In the Supreme Court of the United States heard this case and ruled against the ILA.[34]

In January , a shortage of shipping containers at ports caused shipping to be backlogged.[35][36][37]


Forty foot ( m) containers make up 70% of the world's container volume, which is measured in TEUs[4]
The standard casting that is located on each of the eight corners of a container. The twistlocksfit through the larger oval hole on the bottom castings. Top casting ovals hold twistlock fittings used to secure another container on top.

Ninety percent of the global container fleet consists of "dry freight" or "general purpose" containers – both of standard and special sizes.[2][3] And although lengths of containers vary from 8 to 56 feet ( to &#;m), according to two container census reports[nb 5] about 80% of the world's containers are either twenty or forty foot standard length boxes of the dry freight design.[4] These typical containers are rectangular, closed box models, with doors fitted at one end, and made of corrugatedweathering steel (commonly known as CorTen)[nb 6] with a plywood floor.[39] Although corrugating the sheet metal used for the sides and roof contributes significantly to the container's rigidity and stacking strength, just like in corrugated iron or in cardboard boxes, the corrugated sides cause aerodynamic drag, and up to 10% fuel economy loss in road or rail transport, compared to smooth-sided vans.[40]

Standard containers are 8 feet (&#;m) wide by 8&#;ft 6&#;in (&#;m) high,[nb 7] although the taller "High Cube" or "hi-cube" units measuring 9&#;feet 6&#;inches (&#;m) have become very common in recent years. By the end of , high-cube 40&#;ft containers represented almost 50% of the world's maritime container fleet, according to Drewry's Container Census report.[42]

About 90% of the world's containers are either nominal foot (&#;m) or foot (&#;m) long,[4][43] although the United States and Canada also use longer units of 45&#;ft (&#;m), 48&#;ft (&#;m) and 53&#;ft (&#;m). ISO containers have castings with openings for twistlock fasteners at each of the eight corners, to allow gripping the box from above, below, or the side, and they can be stacked up to ten units high.[44]

Although ISO standard of only required nine-high stacking, and only of containers rated at 24,&#;kg (53,&#;lb),[45] current Ultra Large Container Vessels of the Post New Panamax and Maersk Triple E class are stacking them ten or eleven high.[46][47] Moreover, vessels like the Marie Maersk no longer use separate stacks in their holds, and other stacks above deck — instead they maximize their capacity by stacking continuously from the bottom of the hull, to as much as twenty-one high.[48] This requires automated planning, whereby heavy containers are systematically kept at the bottom of the stack, and light ones on top — not only to stabilize the ship, but also to prevent overloading and collapsing the bottom containers.

Regional intermodal containers, such as European, Japanese and U.S. domestic units however, are mainly transported by road and rail, and can frequently only be stacked up to two or three laden units high.[44] Although the two ends are quite rigid, containers flex somewhat during transport.[49]

Container capacity is often expressed in twenty-foot equivalent units (TEU, or sometimes teu). A twenty-foot equivalent unit is a measure of containerized cargo capacity equal to one standard foot (&#;m) long container. This is an approximate measure, wherein the height of the box is not considered. For example, the 9&#;ft 6&#;in (&#;m) tall high-cube, as well as 4-footinch half-height (&#;m) foot (&#;m) containers are equally counted as one TEU. Similarly, extra long 45&#;ft (&#;m) containers are commonly counted as just two TEU, no different than standard 40 feet (&#;m) long units. Two TEU are equivalent to one forty-foot equivalent unit (FEU).[50][51]

In the global container fleet grew to a volume of &#;million TEU, based on Drewry Shipping Consultants' Container Census.[52][nb 8] Moreover, in for the first time in history foot High cube containers accounted for the majority of boxes in service, measured in TEU.[52] In it was noted by global logistics data analysis startupUpply,[53] that China's role as 'Factory of the world' is further incentivizing the use of foot containers, and that the computational standard 1&#;TEU boxes only make up 20% of units on major East-West liner routes, and demand for shipping them keeps dropping.[54] In the 21st century, the market has shifted to using foot high-cube dry and refrigerated containers more and more predominantly. Forty-foot units have become the standard to such an extent, that the sea freight industry now charges less than 30% more for moving a ft unit than for a 1&#;TEU box. Although ft units mostly have heavy cargo, and are useful for stabilizing both ships and revenue,[nb 9] carriers financially penalize 1&#;TEU boxes by comparison.[54]

For container manufacturers, foot High-Cubes now dominate market demand – both for dry and refrigerated units.[54] Manufacturing prices for regular, dry freight containers are typically in the range of $—$ U.S. per CEU (container equivalent unit),[52] and about 90% of the world's containers are made in China.[43] The average age of the global container fleet was a little over 5 years from end to end , meaning containers remain in shipping use for well over 10 years.[6]

The typical gooseneck tunnel is clearly visible in the underside of a toppled-over, long container (first picture), as well as in a container's interior, where it takes the space otherwise covered by wood flooring. Gooseneck container trailer showing twistlock couplings for forty-foot boxes at its four corners. Twenty foot containers on the other hand, frequently have forklift pockets, accessible from the sides (last picture).[nb 10]

Gooseneck tunnel[edit]

A gooseneck tunnel, an indentation in the floor structure, that meshes with the gooseneck on dedicated container semi-trailers, are mandatory features in the bottom structure of 1AAA and 1EEE ( and ft high-cube) containers, and optional but typical on standard height, forty-foot and longer containers.


Forty foot High-cube actively refrigerated container – refrigerating equipment visible on the front end.
A flat-rack container loaded with a small vessel loaded by a reach stacker.

Other than the standard, general purpose container, many variations exist for use with different cargoes. The most prominent of these are refrigerated containers (a.k.a. reefers) for perishable goods, that make up six percent of the world's shipping boxes.[3][43] And tanks in a frame, for bulk liquids, account for another % of the global container fleet.[3]

Although these variations are not of the standard type, they mostly are ISO standard containers – in fact the ISO standard classifies a broad spectrum of container types in great detail. Aside from different size options, the most important container types are:[58][nb 11]

  • General-purpose dry vans, for boxes, cartons, cases, sacks, bales, pallets, drums, etc., Special interior layouts are known, such as:
    • rolling-floor containers, for difficult-to-handle cargo
    • garmentainers, for shipping garments on hangers (GOH)[60][61]
  • Ventilated containers. Essentially dry vans, but either passively or actively ventilated. For instance for organic products requiring ventilation
  • Temperature controlled – either insulated, refrigerated, and/or heated containers, for perishable goods
  • Tank containers, for liquids, gases, or powders. Frequently these are dangerous goods, and in the case of gases one shipping unit may contain multiple gas bottles
  • Bulk containers (sometimes bulktainers), either closed models with roof-lids, or hard or soft open-top units for top loading, for instance for bulk minerals. Containerized coal carriers and "bin-liners" (containers designed for the efficient road and rail transportation of rubbish from cities to recycling and dump sites) are used in Europe.
  • Open-top and open-side containers, for instance for easy loading of heavy machinery or oversize pallets. Crane systems can be used to load and unload crates without having to disassemble the container itself.[62] Open sides are also used for ventilating hardy perishables like apples or potatoes.
  • Log cradles for cradling logs[63]
  • Platform based containers such as:
    • flat-rack and bolster containers, for barrels, drums, crates, and any heavy or bulky out-of-gauge cargo, like machinery, semi-finished goods or processed timber. Empty flat-racks can either be stacked or shipped sideways in another ISO container
    • collapsible containers, ranging from flushfolding flat-racks to fully closed ISO and CSC certified units with roof and walls when erected.[64]

Containers for Offshore use have a few different features, like pad eyes, and must meet additional strength and design requirements, standards and certification, such as the DNV by Det Norske Veritas, LRCCS by Lloyd's Register, Guide for Certification of Offshore Containers by American Bureau of Shipping and the International standardISO Offshore containers and associated lifting sets , in support of IMO MSC/Circ. [65]

A multitude of equipment, such as generators, has been installed in containers of different types to simplify logistics – see containerized equipment for more details.

Swap body units usually have the same bottom corner fixtures as intermodal containers, and often have folding legs under their frame so that they can be moved between trucks without using a crane. However they frequently don't have the upper corner fittings of ISO containers, and are not stackable, nor can they be lifted and handled by the usual equipment like reach-stackers or straddle-carriers. They are generally more expensive to procure.[66]


40 foot high-cube container. The one foot extra height is indicated by the black and yellow markers near the top corners.

Basic terminology of globally standardized intermodal shipping containers is set out in standard:

  • ISO () Freight containers — Vocabulary, 2nd edition; last reviewed and confirmed in

From inception, ISO standards on international shipping containers, consistently speak of them sofar as 'Series 1' containers – deliberately so conceived, to leave room for another such series of interrelated container standards in the future&#;! [nb 12]

Basic dimensions and permissible gross weights of intermodal containers are largely determined by two ISO standards:

  • ISO / Series 1 freight containers—Classification, dimensions and ratings
  • ISO Series 1 freight containers—Specification and testing—Part 1: General cargo containers for general purposes

Weights and dimensions of the most common (standardized) types of containers are given below.[nb 13] Forty-eight foot and fifty-three foot containers have not yet been incorporated in the latest, edition of the ISO [68] ISO standard maximum gross mass for all standard sizes except ft boxes was raised to 36,&#;kg or 79,&#;lb per Amendment&#;1 on ISO&#;, in [69] Draft Amendment&#;1 of ISO&#;&#; – for the eighth edition – maintains this.[70] Given the average container lifespan, the majority of the global container fleet have not caught up with this change yet. Moreover, U.S. highways cannot handle such heavy fully laden containers yet, including the mass of truck (and trailer).

Values vary slightly from manufacturer to manufacturer, but must stay within the tolerances dictated by the standards. Empty weight (tare weight) is not determined by the standards, but by the container's construction, and is therefore indicative, but necessary to calculate a net load figure, by subtracting it from the maximum permitted gross weight.

The bottom row in the table gives the legal maximum cargo weights for U.S. highway transport, and those based on use of an industry commmon tri-axle chassis. Cargo must also be loaded evenly inside the container, to avoid axle weight violations.[71] The maximum gross weights that U.S. railroads accept or deliver are 52,&#;lb (24,&#;kg) for foot containers, and 67,&#;lb (30,&#;kg) for foot containers,[72]in contrast to the global ISO-standard gross weight for footers having been raised to the same as footers – in the year .[73] In the U.S., containers loaded up to the rail cargo weight limit cannot move over the road, as they will exceed the U.S. 80,&#;lb (36,&#;kg) highway limit.[72]

Container by
common name
ISO (global) standard containers [74][75]Common North American containers [76]
Standard height
Standard height
40&#;foot high-cube 45&#;foot high-cube 48&#;foot high-cube 53&#;foot high-cube [77]
Length 19&#;ft 10+1&#;2&#;in
Width 8&#;ft
8&#;ft 6&#;in
Height 8&#;ft 6&#;in
9&#;ft 6&#;in
9&#;ft 6&#;in
Length &#;m
19&#;ft 3&#;in
39&#;ft 4+3&#;8&#;in
44&#;ft 5+1&#;8&#;in
47&#;ft 5&#;in
52&#;ft 5&#;in
Width &#;m
7&#;ft 7+3&#;4&#;in
8&#;ft 2&#;in
Height &#;m
7&#;ft 8+1&#;2&#;in
8&#;ft 8+1&#;2&#;in
8&#;ft 11&#;in
Width &#;m
7&#;ft 6&#;in
8&#;ft 2&#;in
Height &#;m
7&#;ft 5&#;in
8&#;ft 5&#;in
8&#;ft 10&#;in
Internal volume 1,&#;cu&#;ft
Common maximum
gross weight
Empty (tare) weight
8,&#;lb [78]
8,&#;lb [76][78]
10,&#;lb [76]
Common net load
ISO Max Gross Mass 36,&#;kg
per ISO&#;,&#;Amd1&#;() [69][70]
Not standardized
U.S. maximum
legal truck weights
80,&#;lb (36,&#;kg) overall maximum on Interstate highways / 84,&#;lb (38,&#;kg). (6&#;or more axles) on non-Interstate highways [79]
triaxle chassis:
44,&#;lb (20,&#;kg)[71][72]
triaxle chassis: 44,&#;lb (20,&#;kg) [71][72]


Here are examples of tests from ISO (Stacking, Lifting, Restraint, wall, roof and floor Strength, Rigidity).[80]

1 Stacking C
2 Lifting from appropriate set of four top corner fittings C
3 Lifting from the four bottom corner fittings C
4 Restaint longitudinal C
5 Strength of ends walls C
6 Strength of side walls Only if designed
7 Strength of the roof (where provided) C
8 Floor strength C
9 Rigidity (transverse) C
10 Rigidity (longitudinal) C
11 Lifting from fork-lift pokets (where fitted) C
12 Shoring slots Only if designed
13 Weatherproofness

Non-standard and uncommon sizes[edit]

'Pallet wide' containers[edit]

Two foot 'High-cube' containers on a Roll-on/roll-off(RoRo) tractor. The text in the yellow arrow on the top unit, indicates its extra metre width.
Forty-five-foot containers can be seen sticking out feet (&#;m), as part of the forty foot container stacks at the back of this ship.


European 'Pallet Wide' (or PW) containers are minimally wider, and have shallow side corrugation, to offer just enough internal width, to allow common European Euro-pallets of &#;m (47+1&#;4&#;in) long by &#;m (31+1&#;2&#;in) wide,[81] to be loaded with significantly greater efficiency and capacity. Having a typical internal width of &#;m (96+1&#;8&#;in),[82] (a gain of ~10 centimetres (3+15&#;16&#;in) over the ISO-usual &#;m (92+1&#;8&#;in),[83] gives 'Pallet-wide' containers a usable internal floor width of &#;m (94+1&#;2&#;in), compared to &#;m (78+3&#;4&#;in) in standard containers, because the extra width enables their users to either load two Euro-pallets end on end across their width, or three of them side by side,[nb 14] whereas in standard ISO-containers, a strip of internal floor-width of ~33 centimetres (13&#;in) cannot be used by Euro-pallets.

As a result, while being virtually interchangeable:[82]
A foot PW can load 15 Euro Pallets – four more, or 36% better than the normal 11 pallets in an ISO-standard foot unit
A foot PW can load 30 Euro Pallets – five more, or 20% better than the 25 pallets in a standard foot unit, and
A foot PW can load 34 Euro pallets – seven more, or 26% better than 27 in a standard foot container.

Some 'Pallet-Wides' are simply manufactured with the same, ISO-standard floor structure, but with the side-panels welded in, such that the ribs/corrugations are embossed outwards, instead of indenting to the inside.[84] This makes it possible for some Pallet-Wides to be just &#;m (96+7&#;8&#;in) wide,[82] but others can be &#;m (98+3&#;8&#;in) wide.[85]

Many sea shipping providers in Europe allow these on board, as their external width overhangs over standard containers are sufficiently minor that they fit in the usual interlock spaces in ship's holds,[84] as long as their corner-castings patterns (both in the floor and the top) still match with regular foot units, for stacking and securing.

The 45&#;ft (&#;m) pallet-wide high-cube container has gained particularly wide acceptance, as these containers can replace the &#;m (44&#;ft 7+3&#;8&#;in) swap bodies that are common for truck transport in Europe. The EU has started a standardization for pallet wide containerization in the European Intermodal Loading Unit (EILU) initiative.[86]


Australian RACE containers are also slightly wider to optimise them for the use of Australia Standard Pallets, or are 41&#;ft (&#;m) long, and &#;m (8&#;ft 2&#;in) wide, to be able to fit up to 40 pallets.[87][88]

U.S. / North American oversize containers[edit]

Container "Toplifter" forklift moving two empty foot boxes by their foot posts

Although the below described sizes are not exclusively used in the U.S. (they are also used in cargo traffic across the borders, into Canada and Mexico), they are predominantly United States initiatives.


The foot (&#;m) shipping container is a High Cube container in that it is 9&#;ft 6&#;in (&#;m) tall on the exterior. It is 8&#;ft 6&#;in (&#;m) wide which makes it 6 inches (15&#;cm) wider than ISO-standard containers.[89] This size was introduced by container shipping company APL (formerly American President Lines) in , and is used domestically in North America on road and rail,[90] but can only be transported on deck by ships. This size being 8 feet (&#;m) longer and 6 inches (15&#;cm) wider has 29% more volume capacity than the standard ft High Cube,[91] yet costs of moving it by truck or rail are almost the same.


Swift 53 ft Intermodal container

General purpose foot (&#;m) containers were introduced in the United States in , and are used both in the US and Canada, mainly for domestic road and rail transport.[90] They are considered High-cubes, based on their 9&#;ft 6&#;in (&#;m) ISO-standard height. Their width of 8&#;ft 6&#;in (&#;m) however makes them 6 inches (15&#;cm) wider than ISO-standard containers.[89] These large boxes have 60% more capacity than standard-height foot (&#;m) containers, enabling shippers to consolidate more cargo into fewer containers.[91][92][93]

Generally, North American foot containers were not constructed strong enough to endure the rigors of ocean transport, but in container carrier APL introduced the first foot ocean-capable containers. All new, reinforced foot boxes were built specifically for international trade and designed to withstand ocean voyages on its South China-to-Los Angeles service.[90] In however, APL stopped offering vessel space for foot containers on its trans-Pacific ships.[94] Nevertheless, In both Crowley and TOTE Maritime each announced the construction of their respective second combined container and roll-on/roll-off ships for Puerto Rico trade, with the specific design to maximize cubic cargo capacity by carrying foot, inch wide (2,&#;mm) containers.[95][96] Within Canada, Oceanex offers foot-container ocean service to and from the island of Newfoundland.[97] Fifty-three-foot containers are also being used on some Asia Pacific international shipping routes.[67]


In May , Canadian Tire and Canadian Pacific Railway announced deployment of the first foot (&#;m) intermodal containers in North America. The containers allow Canadian Tire to increase the volume of goods shipped per container by 13%.[98]

Small containers[edit]

The ISO standard has sofar never standardized foot (3 m) containers to be the same height as so-called "Standard-height", 8&#;ft 6&#;in (&#;m), and foot containers. By the ISO standard, foot (and previously included 5-ft and 61&#;2-ft boxes) are only of unnamed, 8-foot ( m) height. But industry makes foot units more frequently of 8&#;ft 6&#;in (&#;m) height,[83] to mix, match (and stack) better in a fleet of longer, 8'6" tall containers. Smaller units, on the other hand, are no longer standardized, leading to deviating lengths, like 8&#;ft (&#;m) or 6+1&#;2&#;ft (&#;m), with non-standard widths of m / in and m / 76¾ in respectively, and non-standard heights of m / 7'5" and m / 6'" respectively,[83] for storage or off-shore use.

U.S. Military[edit]

The United States military continues to use small containers, strongly reminiscent of their Transporter and Conex boxes of the s and s. These mostly comply with (previous) ISO standard dimensions, or are a direct derivative thereof. Current terminology of the United States armed forces calls these small containers Bicon, Tricon and Quadcon, with sizes that correspond with (previous) ISO standard sizes 1D, 1E and 1F respectively. These containers are of standard[nb 15] 8&#;ft (&#;m) height, and with a footprint size either one half (Bicon), one third (Tricon) or one quarter (Quadcon) the size of a standard foot, one TEU container.[99][][]
At a nominal length of 10 feet (&#;m), two Bicons coupled together lengthwise match one foot ISO container, but their height is 6 inches (&#;mm) shy of the more commonly available foot ISO containers of so-called standard height, which are 8&#;ft 6&#;in (&#;m) tall. Tricons and Quadcons however have to be coupled transversely&#;— either three or four in a row&#;— to be stackable with twenty foot containers.[] Their length of 8&#;ft (&#;m) corresponds to the width of a standard foot container, which is why there are forklift pockets at their ends, as well as in the sides of these boxes, and the doors only have one locking bar each. The smallest of these, the Quadcon, exists in two heights: 96&#;in (&#;m) or 82&#;in (&#;m).[] Only the first conforms to ISO standard dimensions (size&#;1F).


In Japan's domestic freight rail transport, most of the containers are 12&#;ft (&#;m) long in order to fit Japan's unique standard pallet sizes.[]

  • Gallery: Small container size examples
  • foot (&#;m) the 19D-type container used by JR Freight in Japan

  • U.S. Navy tractor moves Quadcon containers at Kin Red Port in Okinawa ()

  • U.S. Navy load Tricon containers into a Lockheed C-5 Galaxy transport aircraft ()

  • U.S. Navy moving a Bicon box. Note the forklift pockets only in the sides, not at the ends.

Reporting mark[edit]

Various markings on the rear end of a MOLcontainer

Each container is allocated a standardized ISO reporting mark (ownership code), four letters long ending in either U, J or Z, followed by six digits and a check digit.[] The ownership code for intermodal containers is issued by the Bureau International des Containers (International container bureau, abbr. B.I.C.) in France, hence the name BIC-Code for the intermodal container reporting mark. So far there exist only four-letter BIC-Codes ending in&#;"U".

The placement and registration of BIC Codes is standardized by the commissions TC and TC in the JTC1 of the ISO which are dominated by shipping companies. Shipping containers are labelled with a series of identification codes that includes the manufacturer code, the ownership code, usage classification code, UN placard for hazardous goods and reference codes for additional transport control and security.

Following the extended usage of pallet-wide containers in Europe the EU started the Intermodal Loading Unit (ILU) initiative. This showed advantages for intermodal transport of containers and swap bodies. This led to the introduction of ILU-Codes defined by the standard EN which has the same format as the earlier BIC-Codes. The International Container Office BIC agreed to only issue ownership codes ending with U, J or Z. The new allocation office of the UIRR (International Union of Combined Road-Rail Transport Companies) agreed to only issue ownership reporting marks for swap bodies ending with A, B, C, D or K – companies having a BIC-Code ending with U can allocate an ILU-Code ending with K having the same preceding letters. Since July the new ILU codes can be registered, beginning with July all intermodal ISO containers and intermodal swap bodies must have an ownership code and by July all of them must bear a standard-conforming placard.[]


A cargo container being transferred from a rail car to a flat-bed truck, lifted by a reach stacker

Containers are transferred between rail, truck, and ship by container cranes at container terminals. Forklifts, reach stackers, straddle carriers, and cranes may be used to load and unload trucks or trains outside of container terminals. Swap bodies, sidelifters, tilt deck trucks, and hook trucks allow transfer to and from trucks with no extra equipment.

ISO-standard containers can be handled and lifted in a variety of ways by their corner fixtures, but the structure and strength of foot (type E) containers limits their tolerance of side-lifting, nor can they be forklifted, based on ISO ().[]


Main article: Intermodal freight transport

Containers can be transported by container ship, truck and freight trains as part of a single journey without unpacking. Units can be secured in transit using "twistlock" points located at each corner of the container. Every container has a unique BIC code painted on the outside for identification and tracking, and is capable of carrying up to 20–25 tonnes. Costs for transport are calculated in twenty-foot equivalent units (TEU).


When carried by rail, containers may be carried on flatcars or well cars. The latter are specially designed for container transport, and can accommodate double-stacked containers. However, the loading gauge of a rail system may restrict the modes and types of container shipment. The smaller loading gauges often found in European railroads will only accommodate single-stacked containers. In some countries, such as the United Kingdom, there are sections of the rail network through which high-cube containers cannot pass, or can pass through only on well cars. On the other hand, Indian Railways runs double-stacked containers on flatcars under 25 kVoverhead electrical wires. The wires must be at least metres (24&#;ft 5&#;in) above the track. China Railway also runs double-stacked containers under overhead wires, but must use well cars to do so, since the wires are only metres (21&#;ft 8&#;in) above the track.[]


About 90% of non-bulk cargo worldwide is transported by container, and the largest container ships can carry over 19, TEU (Twenty-Foot Equivalent, or how many 20 foot containers can fit on a ship). Between and , an average of 2, containers were reported lost at sea.[] Other estimates go up to 10,; of these 10% are expected to contain chemicals toxic to marine life.[] Various systems are used for securing containers on ships.[][] Losses of containers at sea are low.[]


Containers can also be transported in planes, as seen within intermodal freight transport. However, transporting containers in this way is typically avoided due to the cost of doing such and the lack of availability of planes which can accommodate such awkwardly sized cargo.

There are special aviation containers, smaller than intermodal containers, called Unit load devices.

Securing and security[edit]

Securing containers and contents[edit]

Main article: Load securing

There are many established methods and materials for stabilizing and securing intermodal containers loaded on ships, as well as the internal cargo inside the boxes. Conventional restraint methods and materials such as steel strapping and wood blocking and bracing have been around for decades and are still widely used. Polyester strapping and lashing, and synthetic webbings are also common today. Dunnage bags (also known as "air bags") are used to keep unit loads in place.

Flexi-bags can also be directly loaded, stacked in food-grade containers. Indeed, their standard shape fills the entire ground surface of a 20&#;ft ISO container.

  • Methods of securing containers or internal loads
  • Containers can be horizontally connected with lashing bridge fittings

  • Dockworkers securing containers on a ship with steel lashing bars and turnbuckles

  • Polyester Lashing Application

  • Polyester Strapping and Dunnage Bag application


Intermodal containers which contain valuables can be the target of break-ins and burglary when left unattended. In these cases, the container may be fitted with a security system consisting of a motion detector and panel inside the container. The panel can trigger a siren, strobe, or light to deter intruders, or use a radio signal to alert security guards.

Items that were packed incorrectly may come loose and cause a false response from an inside motion detector. If criminals break in by cutting through a wall of the container, the obstructed motion detector becomes useless. Tomographic motion detectors work well in intermodal containers because they do not require a line of sight to detect motion. The entire container is covered by a volumetric sensing mesh that is not blocked by equipment or inventory. Tomographic motion detection is not prone to misdetection due to dirt buildup as is the case for beams and infrared sensors.

Non-shipping uses[edit]

Containerized equipment[edit]

Hammelmann Diesel unit – built into container

Container-sized units are also often used for moving large pieces of equipment to temporary sites. Specialised containers are particularly attractive to militaries already using containerisation to move much of their freight around. Shipment of specialized equipment in this way simplifies logistics and may prevent identification of high value equipment by enemies. Such systems may include command and control facilities, mobile operating theatres[] or even missile launchers[] (such as the Russian 3M Klubsurface-to-surface missile).

Complete water treatment systems can be installed in containers and shipped around the world.[]

Electric generators can be permanently installed in containers to be used for portable power.[]


Container City in Cholula, Mexico uses fifty old sea containers for 4,&#;m2(48,&#;sq&#;ft) of workshops, restaurants, galleries, etc., as well as some homes.

Half the containers that enter the United States leave empty.[] Their value in the US is lower than in China, so they are sometimes used for other purposes. This is typically but not always at the end of their voyaging lives. The US military often used its Conex containers as on-site storage, or easily transportable housing for command staff and medical clinics.[] Nearly all of over , Conex containers shipped to Vietnam remained in the country, primarily as storage or other mobile facilities. Permanent or semi-permanent placement of containers for storage is common. A regular forty-foot container has about 4,&#;kg (8,&#;lb) of steel, which takes 8,&#;kWh (28,&#;MJ) of energy to melt down. Repurposing used shipping containers is increasingly a practical solution to both social and ecological problems.

Shipping container architecture employs used shipping containers as the main framing of modular home designs, where the steel may be an integrated part of the design, or be camouflaged into a traditional looking home. They have also been used to make temporary shops, cafes, and computer datacenters, e.g., the Sun Modular Datacenter.

Intermodal containers are not strong enough for conversion to underground bunkers without additional bracing, as the walls cannot sustain much lateral pressure and will collapse. Also, the wooden floor of many used containers could contain some fumigation residues, rendering them unsuitable as confined spaces, such as for prison cells or bunkers. Cleaning or replacing the wood floor can make these used containers habitable, with proper attention to such essential issues as ventilation and insulation.

See also[edit]

International standards[edit]

ISO container seal on doorlock
  • ASTM D Standard Practices for Securement of Cargo in Intermodal and Unimodal Surface Transport
  • ISO Series 1 freight containers – Classification, dimensions and ratings
  • ISO Freight containers – Vocabulary
  • ISO Series 1 freight containers – Corner fittings – Specification
  • ISO – Series 1 freight containers – Specification and testing
    • ISO – Part 1: General cargo containers for general purposes
    • ISO – Part 2: Thermal containers
    • ISO – Part 3: Tank containers for liquids, gases, and pressurized dry bulk
    • ISO – Part 4: Non-pressurized container for dry bulk
    • ISO – Part 5: Platform and platform based containers
  • ISO Hooks for lifting freight containers of up to 30 tonnes capacity – Basic requirements
  • ISO Series 1 freight containers – Handling and securing
  • ISO Freight containers – Coding, identification and marking
  • ISO Freight containers – Container equipment data exchange (CEDEX) – General communication codes
  • ISO/TS Freight containers – Radio frequency identification (RFID) – Licence plate tag
  • ISO Freight containers – Straddle carriers for freight container handling – Calculation of stability
  • ISO Supply chain applications of RFID – Freight containers
  • ISO/PAS Freight containers – Mechanical seals
  • ISO Freight containers – Electronic seals


  1. ^Based on size alone, at least 5% of intermodal containers do not comply with ISO standards,[2] and should technically not be called ISO containers.
  2. ^Up from an estimated &#;million in [6]
  3. ^8&#;ft 6&#;in length, 6&#;ft 3&#;in width and 6&#;ft 10+1&#;2&#;in height, and &#;lb capacity[17][18]
  4. ^ Some sources also mention a foot version.[21][22]
  5. ^The Containerisation International Market Analysis Report: World Container Census , and the Drewry Maritime Research report: Container Census [38]
  6. ^Originally "COR-TEN", a trademark of U.S. Steel Corporation
  7. ^Using "standard" to mean 'standard height', as intended within the ISO standard,[41] as opposed to meaning dry van or general purpose container.[4]
  8. ^Up from an estimated &#;million TEU in [3]
  9. ^Heavy 1&#;TEU containers are habitually stacked low in a vessel, both for the stability of a ship (keep the center of gravity low), as well as being often used under long term contracts, providing financial stability.[54]
  10. ^ Infrequently there are two sets,[55] an outer set which may be used for loaded handling, and an inner set only for unloaded handling, by smaller forklifts.[56]
  11. ^Frequently used abbreviations for the most common ISO types are: GP (General Purpose), HC / HQ (High Cube), OT (Open Top), RF (Refrigerated), RK (Rack) and TK (Tank).[59]
  12. ^ The term "Series 1" in the standards' names expresses the interrelated nature of the standards, leaving room for another such series in the future. In , Michel Hennemand, president of the International Container Bureau (BIC), and chair of ISO Technical committee , subcommittee SC 1: General purpose containers, asked whether the time has come to develop a new series of standards on containers (Series 2), to accommodate new sizes like American foot and European Pallet-wide containers. A new series which, given the significant investments required by the industry, would replace the current series of standards (series 1) in the next 20 or 25 years.[67]
  13. ^Forty-five-foot containers were not standardized by the ISO until the Amendment No. 2 to the ISO standard.[41]
  14. ^providing the pallets were neatly stacked, without overspill
  15. ^the word standard – not the name 'Standard'&#;!


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  2. ^ abcdDr. Jean-Paul Rodrigue. "World Container Production, ". The Geography of Transport Systems. Hofstra University. Archived from the original on 4 July Retrieved 19 July
  3. ^ abcde"Global Container Fleet". World Shipping Council. Archived from the original on 11 May Retrieved 19 July
  4. ^ abcdef"World Container Fleet Overview". CSI Container Services International. January Archived from the original on 18 July Retrieved 18 July
  5. ^"Container sizes". Retrieved 1 February
  6. ^ abContainer Supply Review(PDF) (Report). World Shipping Council. May p.&#;1. Retrieved 18 July
  7. ^"Container Shipping – Statistics & Facts". Statista Inc. Archived from the original on 5 December Retrieved 27 July
  8. ^Global Trade – World Shipping Council
  9. ^"Frequently Asked Questions - Modeling Eras". 14 August Archived from the original on 14 August
  10. ^Essery, R. J, Rowland. D. P. & Steel W. O. British Goods Wagons from to the Present Day. Augustus M. Kelly Publishers. New York USA. Page 92
  11. ^Lewandowski, Krzysztof (). "Czechoslovak activity to prepare European norms for containers before the Second World War"(PDF). Acta Logistica. 1 (4): 1–7. doi/al.v1i ISSN&#;
  12. ^M.K. "Vorläufer der heutigen Container: pa, BT und B" [Predecessors of today's containers: pa, BT and B]. MIBA (in German) (Special 54): 12– Retrieved 23 July
  13. ^Nico Spilt. "Laadkistvervoer – Langs de rails" [Loading bin transport] (in Dutch). Archived from the original on 20 July Retrieved 20 July
  14. ^Lewandowski, Krzysztof (). "Wymagania Organizacyjne Stosowania Systemu ACTS" [Organizational Requirements Use the ACTS System] (PDF). Pojazdy Szynowe (in Polish). 2: 1– ISSN&#;
  15. ^Intermodal Marine Container Transportation: Impediments and Opportunities, Issue // National Research Council: The container revolution (page 18): "This [Army] box in turn served as a model for the small containers that most major ship operators began using during the late s and early s. These however, were mainly loaded and unloaded at the docks, and not used intermodally.."
  16. ^"History & Development of the Container – The "Transporter", predecessor to the CONEX". U.S. Army Transportation Museum. 15 May Archived from the original on 20 July Retrieved 20 July
  17. ^ abcHeins, Matthew (). "2"(PDF). The Shipping Container and the Globalization of American Infrastructure (dissertation). University of Michigan. p.&#; Retrieved 21 July
  18. ^Levinson, Marc (). "7"(PDF). The Box: How the Shipping Container Made the World Smaller and the World Economy Bigger. Princeton, N.J.: Princeton University Press. p.&#; ISBN&#;. Retrieved 21 July
  19. ^Flanagan, Robert (). "Fleeing G.o.D.". Falloff. p.&#;7. ISBN&#;.
  20. ^Michael J. Everhart (7 July ). "My Vietnam Tour – ". Retrieved 21 July
  21. ^Levinson, Marc. "Sample Chapter for Levinson, M.: The Box: How the Shipping Container Made the World Smaller and the World Economy Bigger". The Box: How the Shipping Container Made the World Smaller and the World Economy Bigger. Princeton University Press. Archived from the original on 22 January Retrieved 17 February
  22. ^Gittins, Ross (12 June ). "How the invention of a box changed our world – Business –". The Sydney Morning Herald. Retrieved 17 February
  23. ^Cudahy, Brian J. (September–December ). "The Containership Revolution: Malcom McLean's Innovation Goes Global"(PDF). TR News. No.&#; Archived(PDF) from the original on 4 March Retrieved 1 March
  24. ^Bartsch, Butsri. "Sea freight – somehow antique yet modern!". Archived from the original on 8 June Retrieved 20 May
  25. ^"International Convention for Safe Containers (CSC) – Adoption: 2 December ; Entry into force: 6 September ". Retrieved 1 February
  26. ^International Convention for Safe ContainersArchived 5 March at the Wayback Machine (Geneva, 2 December )
  27. ^ abc"NLRB v. Longshoremen, U.S. " &#; via Admiralty and Maritime Law Guide.
    "NLRB v. Longshoremen, U.S. " &#; via Justia: U.S. Supreme Court.
  28. ^Partners, McAlinden Research (16 November ). "Shipping Container Shortage Could Last Until Next Year, Boosting Container Leasing Stocks". McAlinden Research Partners. Retrieved 3 February
  29. ^cameronc86 (31 December ). "Container Shortage – The Reasons Behind It". ClearFreight. Retrieved 3 February
  30. ^"Shipping companies box clever to overcome container shortages". The National. 9 November Retrieved 3 February
  31. ^World Container Fleet - CSI Container Services International
  32. ^"Shipping Container Homes Globally". Retrieved 24 May
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  35. ^"40ft High Cubes set to Dominate the Container Equipment Market". Drewry Shipping Consultants. 18 June Archived from the original on 29 August Retrieved 18 July
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  40. ^"The Triple-E A larger-than-life puzzle". 5 September Archived from the original on 5 September
  41. ^Hammond, Richard. Episode 4: Mega Ship. Big. Event occurs at Retrieved 10 May
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Build-A-Bear Workshop - Why They're Successful

Author: Claire Rampen, Co-founder at Reath

UK-based startup Reath has been working with organisations to move away from single-use packaging and reduce waste. Here the team details their work to build an open data standard for reusable packaging, funded by UK Research and Innovation. 

No-one needs to remind you that packaging waste is a problem; although other types of pollution may be ‘invisible’, we are faced with daily evidence of this broken system in the form of discarded – often single-use – packaging. The problem extends beyond the litter you see in the streets: you may do your best to deposit recycling into the correct bin, but due to contamination, and a lack of regulation around packaging materials, the chances of it having a second life are, unfortunately, small. 

Despite all of our innovations in the packaging materials space (for example compostable packaging), and despite the increase in recycling rates over the last 20 years, packaging waste is still a huge problem.

There are compelling arguments for the introduction of more ‘circular’ systems (that is, reusing, or &#;closing the loop&#; on recycling – ensuring waste is collected, recycled and used to make new products) rather than transitioning all single-use packaging to compostable. 

If you think this sounds like an idealistic solution, bear in mind that countries such as Norway and the Netherlands have demonstrated that this behaviour can work: they achieve return rates of packaging as high as 96% through their incentivised recycling schemes. 

However there are three challenges for companies looking to adopt reusable packaging:

  1. Packaging regulation is not built for circular systems
  2. Lack of data to inform the design of reusable packaging systems
  3. Challenge of integrating into existing business processes 

Through our work setting up Reath, we had the opportunity to speak to companies who were trying to overcome these challenges. We realised that a fundamental piece of the puzzle was missing: a robust data infrastructure around reuse. So we set out to define and standardise the data points for reusable packaging. 

Our approach

Reath conducted a research project, funded by UK Research and Innovation, to begin building the open data standard. Open standards for data are reusable agreements that make it easier for people and organisations to publish, access, share and use better quality data. The process we followed was based on the guidance offered by the Open Data Institute (ODI), and involved the following steps:

1: Mapping the data ecosystem

The term ‘data ecosystem’ describes the organisations who publish or receive data, within a certain domain, and the data infrastructure that allows the data to flow between them. In our case, this meant anyone who was involved in the production, use, sale and disposal of packaging. We used the ODI’s Data Ecosystem Mapping tool, and participated in the data ecosystem mapping webinar. This was a critical step in the process, as the exercise improved our understanding of the ecosystem, helped us to identify new stakeholders and surfaced datasets that already existed in this space.

2: Identifying stakeholders within the key domains

This led us to identify key categories of stakeholders who would be critical in defining the necessary data points needed for the core open data standard. 

These broad stakeholder categories were as follows:

  1. Manufacturing brands: the brands that produce the consumer goods to be packaged. 
  2. Retailers and supermarkets: the companies who have relationships with the individual consumer, and with the manufacturing brands.
  3. Environmental compliance bodies: the relevant national organisations in charge of implementing and upholding environmental safeguarding policies and ensuring that businesses comply with regulation. 
  4. Health and safety bodies: the relevant national and local organisations in charge of implementing and upholding health and safety standards to protect the end consumer, and ensuring that businesses comply with regulations. 

3: Conducting interviews with participants from representative organisations

We then created a key stakeholder map, identifying businesses within our target segments. 

We conducted 25 interviews with representatives who held a variety of roles within the organisations to better understand the needs that each contributor had.  

4: Synthesising the qualitative data

We then started working with the qualitative data we had collected, to extract learnings and insights. The purpose of this was to identify:

    1. the key challenges for individuals within organisations seeking to adopt reuse systems
    2. how these end-user needs can be met by an open data standard, and the tools that are built on top of an open data standard for example, a digital passport
    3. the key datasets to be included in the open data standard to meet those needs.

We used techniques such as creating user stories and identifying themes across all the respondents&#; answers. Our final piece of synthesis was to form statements of our key findings, and then provide evidence through quotes from our qualitative interviews.

5: Producing an alpha data standard for feedback and further iteration

We are in the final stages of the project and will be releasing an alpha data standard, along with a working paper, to capture the decisions made. 

The process of building an open data standard from scratch was initially very daunting. However, we leant heavily on resources provided by the ODI, finding the interactive exercises and webinars particularly valuable. It has been an incredibly rewarding process; through our interviews, we have deepened our understanding of the domain we are working within, and have made some fantastic connections.

The project has left us feeling inspired by the dedication and focus of the individuals we interviewed, all determined to make reuse systems work.


Build packaging standard a bear

The Ultimate Guide to Corrugated Boxes

Glossary of Terms

Adhesive: The substance used to hold plies of solid fiberboard together, to hold linerboard to the tips of flutes of corrugated medium, or to hold overlapping flaps together to form the joint or to close a box.

Bale: A shaped unit of materials, enclosed in a fiberboard container or other wrapping, bound by strapping, rope or wire.

Basis Weight: An attribute of containerboard, but the values may be determined from the combined corrugated board. When determining the basis weight from combined board, the take-up factor of the corrugated medium, which varies with flute size, and the weight of the adhesive must be considered.

Bending: The ability of containerboard or combined board to be folded along scorelines without rupture of the surface fibers to the point of seriously weakening the structure.

Blank or Box Blank: A flat sheet of corrugated board that has been cut, scored, and slotted, but not yet glued together.

Box Manufacturer: An establishment that has equipment to score, slot, print and join corrugated or solid fiberboard sheets into boxes, and that regularly uses that equipment in the production of fiberboard boxes in commercial quantities.

Box Manufacturer's Certificate (BMC): A statement printed in a round or rectangular design on a corrugated box flap that certifies the box conforms to all applicable standards, and identifies its manufacturer. Sometimes referred to as a class stamp or cert stamp.

Box Style: Distinctive configuration of a box design, without regard to size. A name or number identifies styles in common use.

Boxboard: The types of paperboard used to manufacture folding cartons and set up (rigid) boxes.

Built-up: Multiple layers of corrugated board glued together to form a pad of desired thickness, normally used for interior packing.

Bulk: Unpackaged goods within a shipping container. Also, a large box used to contain a volume of product (e.g., “bulk box”).

Bundle: A shipping unit of two or more articles or boxes wrapped or fastened together by suitable means.

Caliper: Usually expressed in thousandths of an inch (mils) or sometimes referred to as "points." Caliper measurements are also used as an indirect measure of manufacturing quality.

Cardboard: A thin, stiff pasteboard used in the creation of playing cards, signs, etc. Term is often misused to refer to Boxboard (folding cartons) and Containerboard (corrugated boxes).

Carton: A folding box made from boxboard, used for consumer quantities of product. A carton is not recognized as a shipping container.

Case: As used by the packaging industry, a corrugated or solid fiberboard box.

Chipboard: A paperboard generally made from recycled paper stock. Uses include backing sheets for padded writing paper, partitions within boxes and the center ply or plies of solid fiberboard.

Combined Board: A fabricated sheet assembled from several components, such as corrugated or solid fiberboard.

Compression Strength: A corrugated box's resistance to uniformly applied external forces. Top-to-bottom compression strength is related to the load a container may encounter when stacked. End-to-end or side-to-side compression may also be of interest for particular applications.

Containerboard: The paperboard components (linerboard, corrugating material and chipboard) used to manufacture corrugated and solid fiberboard. The raw materials used to make containerboard may be virgin cellulose fiber, recycled fiber or a combination of both.

Corrugated Board, Corrugated Fiberboard: The structure formed by gluing one or more sheets of fluted corrugating medium to one or more flat facings of linerboard. There are four common types:

  • Single Face: Combination of one fluted corrugating medium glued to one flat facing of linerboard.
  • Single Wall: Two flat facings of linerboard, one glued to each side of a corrugated medium. Also known as Double Face.
  • Double Wall: Three flat facings of linerboard, one glued to each side of two corrugated mediums.
  • Triple Wall: Four flat facings of linerboard, one glued to each side of three corrugated mediums.

Corrugator: The machine that unwinds two or more continuous sheets of containerboard from rolls, presses flutes into the sheet(s) of corrugating medium, applies adhesive to the tips of the flutes and affixes the sheet(s) of linerboard to form corrugated board. The continuous sheet of board may be slit to desired widths, cut off to desired lengths and scored in one direction.

Design Style: A style of fiberboard trays or caps having flaps scored, folded and secured at flange side walls forming the depth, as opposed to a slotted style having a set of major and minor closing flaps.

Die Cut: The act of cutting raw material (such as combined board) to a desired shape (such as a box blank) by using a die.

Dimensions: The three measurements of a box: length, width and depth. Inside dimensions are used to assure proper fit around a product. Outside dimensions are used in the carrier classifications and in determining pallet patterns.

Double Wall: A corrugated board construction where two layers of medium are glued between three layers of flat linerboard facing.

Edge Crush Resistance/Short Column Compression (ECT): The amount of force needed to crush on-edge combined board is a primary factor in predicting the compression strength of the completed box. When using certain specifications in the carrier classifications, minimum edge crush values must be certified.

Facings: Sheets of linerboard used as the flat outer members of combined corrugated board. Sometimes called inside and outside liners.

Fiberboard: A general term describing combined paperboard (corrugated or solid) used to manufacture containers.

Flaps: Extension of the side wall panels that, when sealed, close the remaining openings of a box. Usually defined by one scoreline and three edges.

Flexo Folder Gluer: A machine, usually capable or running at high speed that prints, folds, cuts, and glues sheets of corrugated board, converting them into shipping boxes.

Flute: The wavy layer of corrugated medium that is glued between the flat inner and outer sheets of linerboard to create corrugated board. Fluting generally runs parallel to the height of a shipping box.

Joint: The opposite edges of the blank glued, stapled, wire stitched, or taped together to form a box.

Kraft: German word meaning “strength”; designating pulp, paper or paperboard produced from wood fibers.

Liner: A creased fiberboard sheet inserted as a sleeve in a container and covering all side walls. Used to provide extra stacking strength or cushioning.

Linerboard: The flat sheets of paper that comprise the outer surfaces of a sheet of corrugated board.

Medium: The paperboard used to make the fluted layer of corrugated board.

Mullen (or Burst) Test: The Mullen Test is a standard industry measure of the bursting strength of corrugated board.

Overlap: A design feature wherein the top and/or bottom flaps of a box do not butt, but extend one over the other. The amount of overlap is measured from flap edge to flap edge.

Pad: A corrugated or solid fiberboard sheet, or sheet of other authorized material, used for extra protection or for separating tiers or layers of articles when packed for shipment.

Palletizing: Securing and loading containers on pallets for shipment as a single unit load, typically for handling by mechanical equipment.

Panel: A "face" or "side" of a box.

Paperboard: One of the two major product categories of the paper industry. Includes the broad classification of materials made of cellulose fibers, primarily wood pulp and recycled paper stock, on board machines. The major types are containerboard and boxboard. (The other major product group of the paper industry is paper, including printing and writing papers, packaging papers, newsprint and tissue.)

Partition: A set of corrugated, solid fiberboard or chipboard pieces that interlock when assembled to form a number of cells into which articles may be placed for shipment.

Ply: Any of the several layers of linerboard or solid fiberboard.

Point: Term used to describe the thickness or caliper of paperboard, where one point equals one thousandth of an inch.

Puncture Resistance: The puncture resistance of combined board indicates the ability of the finished container to withstand external and internal point pressure forces and to protect the product during rough handling. This method is used on heavy double wall and triple wall as an alternative to burst.

Regular Slotted Container (RSC): A box style created from a single sheet of corrugated board. The sheet is scored and slotted to permit folding. Flaps extending from the side and end panels form the top and bottom of the box. The two outer flaps are one-half the container’s width in order to meet at the center of the box when folded. Flute direction may be perpendicular to the length of the sheet (usually for top-opening RSCs) or parallel to the length of the sheet (usually for end-opening RSCs).

Score or Scoreline: An impression or crease in corrugated or solid fiberboard, made to position and facilitate folds.

Scored and Slotted Sheet: A sheet of corrugated fiberboard with one or more scorelines, slots or slits. May be further defined as a box blank, a box part, a tray or wrap, a partition piece, or an inner packing piece.

Seam: The junction created by any free edge of a container flap or panel where it abuts or rests on another portion of the container and to which it may be fastened by tape, stitches or adhesive in the process of closing the container.

Set-up Boxes: Boxes that have been squared, with one set of end flaps sealed, ready to be filled with product. An article that is packed for shipment in a fully assembled or erected form.

Sheet: A rectangle of combined board, untrimmed or trimmed, and sometimes scored across the corrugations when that operation is done on the corrugator. Also, a rectangle of any of the component layers of containerboard, or of paper or a web of paperboard as it is being unwound from the roll.

Slit: A cut made in a fiberboard sheet without removal of material.

Slit Score: Shallow knife cuts made in a box blank to allow its flaps and sides to be folded into a shipping box.

Slip Sheet: A flat sheet of material used as a base upon which goods and materials may be assembled, stored and transported.

Slot: A wide cut, or pair of closely spaced parallel cuts including removal of a narrow strip of material made in a fiberboard sheet, usually to form flaps and permit folding without bulges caused by the thickness of the material. Common widths are 1/4 in. (6 mm) and 3/8 in. (9 mm).

Stacking Strength: The maximum compressive load a container can bear over a given length of time, under given environmental/distribution conditions, without failing.

Tensile Strength: Indicates the containerboard's resistance to breaking when it is pulled into or through equipment during the converting and printing processes.

Tube: A sheet of combined boards, scored and folded to a multi-sided form with open ends. It may be an element of a box style or a unit of interior packing that provides protection and compression strength.

Unit: A large group of bundled or unbundled boxes, banded and/or stretch filmed together for shipment.

Unitized Load: A load of a number of articles or containers, bound together by means of tension strapping, plastic shrink or stretch films.

Web: A continuous sheet of paperboard or paper.

Wrap-around Blank: A scored and slotted sheet of corrugated fiberboard that is formed into a box by folding it around its contents. The user makes both the flap and joint closures.


Kangaroo and Joey Unboxing - Build A Bear


Two orders going on 2 weeks

Two orders going on 2 weeks. Have not shipped and will not provide information when they will. Shipping delays are understandable, however they refuse to communicate and provide a timeline when they plan to.

Ordered bucks worth 2 weeks ago

Ordered bucks worth 2 weeks ago. Still not shipped no tracking number says order will be arriving within the next 3 days. Yet it has not shipped. Tried using the computer help section all it did was ask for order number and then tell me it can't find my order even though it shows under my acct. Calling is a nightmare had to call about my last order too and waited 45 minutes. The site messes up Constantly really frustrating when your kids love them and this is what we have to deal with.
Tried placing another order and after spending an hour doing birth certificates dressing them etc the site won't let me continue to pay.. Beyond angry



I was hesitant to order online because of the negative reviews. I decided to take a risk because the bear that I wanted is only available online. I placed my order end of the day on Sept. 3rd, received my bear exactly a week later, Sept. 10th. Pretty quick considering I live in Canada. Initially I thought I wasn't getting un update about my order, but, except for the order confirmation email, the shipping information email went to my spam folder. Had a pleasant in-store experience too with my kids.


Buying a build a bear is mainly about the experience , staff at the blanchardstown store need some training on how to engage with children instead of ignoring them and pushing sales.
In there today with my excited 8 year old, there was another child getting a bear as well and the assistant that was with him was brilliant. Our assistant was terrible Didn&#;t do any of the heart knee rubbing etc no engagement at all with my son but was sure to try to flog me a half price voucher. I said it to the manager but I don't know why I wasted my breath spent 70 euro and definitely wouldn't bother again.

Poor online shopping experience

Shipping says days. I ordered online on 22nd Aug as a surprise gift for my daughter who is off to university. It&#;s really important to me that she gets it before she goes. It&#;s 3rd Sept and still nothing. I&#;ve emailed to find out where it is and they haven&#;t got back to me. She leaves tomorrow and I&#;m absolute gutted. A very poor online shopping experience.

Google Reviews

Needs Improvement

On August 3, , I decided that I wanted to order a bear online from BAB, as an emotional support comfort item. I had never been to BAB and had no prior experience with their online service. I also have a disability, I was too anxious and uncomfortable to go to the store in person, especially since I&#;m a young adult. That being said, the best option for me was to order my bear and accessories online, which I did that same day.

I ordered 5 items; online exclusive shirt, scent disc, voice recorder, cub condo, and the happy hugs bear. The price was a little more expensive than I expected, (the code &#;FREESHIP,&#; was supposed to give free shipping, but I tried it multiple times and it never worked for me-none of the promotions worked at the time), but I put my order in anyway. After that, I got an email with an &#;order confirmation,&#; telling me my order number.

The next day on August 4, , I recorded my voice message for the voice recorder. On August 5, , I received another email, telling me that my order was being processed.

On August 10, , it had been five days since I received anything from BAB. In the previous email they sent me, it said to expect shipping information. However, I was constantly checking my email and I didn&#;t see anything. I decided to send them an email via the contact from on their site. Later on that day, I received an email that said &#;shipping confirmation,&#; it had my tracking number from FedEx. I thought this was weird because they never contacted me back about my concerns nor did they answer any of my questions, but since it looked like they we&#;re going to be shipping my item, I was willing to let it go.

After August 10, , I didn&#;t receive anything else about my order. Whenever I would check FedEx online to see my tracking information, it would say that a shipping label was created, but FedEx still hadn&#;t received the package. It had been 3 days and my package still hadn&#;t been delivered to FedEx. At this point I began to worry if it would ever show up. In total, I had waited 11 days. That is terribly slow for a company as big as BAB to ship out and manage orders. It doesn&#;t make sense how they expect customers to wait this long for a bear that is almost double the price of your average teddy bear with horrible customer service and management.

I then started to become more and more concerned, so I looked up reviews and that was enough to make me even more worried than I was before. I read over hundreds of reviews about the same thing happening to other people and their orders, I even read some where they didn&#;t receive their order at all. Scared that this might happen to me, on August 13, , I reached out to BAB again, asking why FedEx hadn&#;t received the package and when it might be shipped out.

BAB did not reach out to me (again), so I was pretty sure that I wasn&#;t going to receive my order. Today, it&#;s August 14, , and to my surprise, my bear was delivered to my house. Now, I checked the tracking number and on the FedEx website, it still says that there was a shipping label created, but no package was received. That being said, I didn&#;t expect it to come today. Because of that, the box it was sent in was soaked (because it&#;s raining), but luckily, the bear nor the birth certificate were not harmed (I know that this is mostly FedEx&#;s fault but I digress).

Everything is in tact, the bear is in great condition, looks and feels really nice. It also feels like the nice stuffing, not that cheap crunchy stuff. The voice recorder works when I press it and it sounds pretty clear-although there is an annoyingly long silence at the end of the recording but that&#;s excusable. The shirt I ordered came and I was able to put it on the bear with ease, it looks like it&#;s good quality and the lettering looks nice and bright. I ordered a lavender scent, I didn&#;t know what it would smell like beforehand so I blindly purchased it but it doesn&#;t smell like it&#;s lavender. It kinda smells like a sweet candy but nevertheless, it smells pleasant and it was put in a good spot-in the back of the head.

Overall, this was a frustrating experience and it gave me a lot of anxiety. I didn&#;t know what was happening with my order and I felt like that could have been easily solved with better communication. I don&#;t think I would order online again, just because personally, it gave me too much stress. However, I&#;m happy that my order has been delivered and I don&#;t have to panic anymore.


Great service

Recently visited the Chester Grosvoner branch, I was really impressed with the service from the 3 ladies that day. They helped me and my partner build a bear with our 3 year old girl, she decided to call her bear Max and the girls made a big fuss of her. Thank you team!

Very Poor Customer Service when you&#;

Very Poor Customer Service when you call the () They cancelled my order because I didn&#;t reply fast enough with the corrected information, which I replied an hour after receiving their email. When I called the representative told me I should of called to begin with because probably my email was not received and now my order is cancelled. If I want my items to place a new order. She was rude and uninterested in keeping my business.

Yellow Bee Jewellery

Matching Hogwarts Robes for our bears

I went to the Manchester store in the Arndale Centre yesterday with 3 friends, we went for one of my friends birthday to get build-a-bears with matching Hogwarts robes. We were served by a woman, I think called Molly. She was very lovely. The build-a-bears had offers so we got a bit of a discount on the bears, I bought a Hufflepuff robe and scarf and a Captain America outfit. The prices wasn't too bad for the bears, a little expensive for the costumes - but nothing to complain about. The build-a-bears were cute!

Very poor customer support

Very poor customer support, they clearly mislabbeled a shipment as home delivery instead of 2day delivery, while I did pay for 2day delivery.

Their reasoning for not refunding money - "It was delivered in the 2 day time frame, home delivery would have taken longer."



I entered the Lakeside store recently to purchase 2 bears for my children and I was told I needed to santise my hands with the store hand sanitiser. I explained that I had my own sanitiser and that I had just cleaned my hands, Demi demanded that she needed to see me clean my hands with it in front of her as it is apparently store policy. I asked where this policy was stated and of course there is no such thing. If this is a rule, why was every other customer allowed into the store without using it? I sanitised my hands in front of her with my own sanitiser and her words were "you know what, why don't you just leave" I was told to get out of the shop in front of my children. What is going on? Is this normal customer service? How did she even get a job to begin with? I am appalled by this and the fact that at least 2 other staff members watched on like it was totally normal to treat people in this way, for asking a question!!! I called the store to relay this to the store manager, Charlotte. Charlotte explained that nothing could be done about what I had experienced because according to Demi I was being "aggressive", how ironic. If being aggressive is the label you get for asking a question then this team is being led by the wrong people. Staff here clearly need thorough training in customer care, service and basic manners. So unprofessional and rude and lack tact. A change of attitude is needed, better yet - a change of staff. If you would like to be spoken to in a degrading manner, then please go ahead and visit this store - I wish you luck.

Samantha Reilly

I got the online-exclusive peacock from&#;

I got the online-exclusive peacock from Build-a-Bear just yesterday, as well as some supplies (still awaiting the medical port kit and the bedset). I was very pleased with how he survived the delivery (thanks USPS for handling him with such care). The gift box he came in was in excellent condition, and he was nice and soft. I named him &#;kennedy&#; (after my favorite president), and I&#;ve been taking very good care of him so far. He&#;s very beautiful, with his bright colors, and his tail actually goes up and down like a real peacock. His face is very expressive: his eyes are a bright green, and he looks like he&#;s always smiling. The tiny supplies he came with are adorable.

UPDATE: The port kit and the bed set arrived in perfect condition. They&#;re so tiny and cute. I love them!

deidra j quintana

I Placed a Online Order with the voice&#;

I Placed a Online Order with the voice recording which I did per email Instructions, I waited 2 weeks & went online to check status there was no order to be found, so I emailed them and there response was I'm sorry your order was cancelled the voice wasnt as clear, so I emailed back ON WHY I WASNT NOTIFIED THIS WAS A SENTIMENTAL GIFT, I GOT NO RESPONSE. HORRIBLE CUSTOMER SERVICE

When I am writing my own review I AM&#;

When I am writing my own review I AM NOT taking the negative comments online about build a bear at all [email protected]

My experience has been EXCELLENT and the SUPPORT at the MANCHESTER store for me pushing 2 bears for Manchester bombing has been EXTREMELY EXCELLENT and staff at store too EVEN Head office !!!!!

One of people who stands out was Aisha extremly helpful and so supportive and made the experience very welcoming also the person who made my bears for me also extremely helpful too .

It's my view and the first time I been in Manchester build bear store and the reason for going on the store because of the bombing for this year in . AMAZING service and even Head office AMAZING to what they did for me !!!!!

Also the ASSISTING manger Kim has been amazing over the phone too !!!!!!!!!!

I totally don't understand why people would be so negative about build a bear when I feel the opposite way round !!!!!!!

I just want to say thank for what build a bear done

Many thanks



Sioux Gijzen

Total satisfaction

Total satisfaction!
I ordered a Stuffed Red Raptor with personalised voice recording on 30 April I had constant communication from BaBW tracking my dino, aswell as dispatch date. Item was in good received in good condition, on 5 May, with the birth certificate as ordered. My great nephew was bowled over with his talking dino, and listens to it constantly! Best gift ever! Thanks Build-a-Bear, UK!

Fine items but poor packaging.

The items are fine. But the packaging for the delivery is worrisome.

I am a customer in WA Australia, and the order dispatch was done pretty fast although they only noticed you few days later (Australia Post did a better job here at noticing their customers). After a week+, finally received my items. But unlike what you saw from Youtube, the items are all packed in a soft parcel/satchel bag with zero bubble wrap/protection around the item.

I was fortunate enough I guess to have the Tom Nook and Isabelle in perfect condition, but their birth certs are worn and terribly folded (imagine you toss your single sheet paper bare into a bag which is fully filled, and brought the bag onto a trip for one week, how would you expect the paper to look like at the end of the trip?)

Considering you have spent that much money on the items and delivery, and they can&#;t even get the basics done correctly is pretty disappointing.

And also the birth certs you received are blank generic certs

Summary: They could do better to make the service and items worth AUD

Update: email for birth cert replacement and they sent me the cert template. Not the best solution, but at least they replied prompt and efficiently.


Shocked to hear about other peoples negative experiences with B-A-B. I ordered a gift online for my friend's child and I had an issue with my order. I got in touch with customer services and they replied very promptly and politely, resolving my issue at first contact. Maybe I got lucky here, but personally I was impressed with their customer service.


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