Web-Distributed Labeling Workgroup Discussion Paper 

Potential Benefits & Challenges of Web-Distributed Labeling 

Introduction 

During a recent meeting of the PPDC Web Distributed Labeling (WDL) Workgroup, several 

group members questioned further investments of time and energy towards implementing WDL 

until potential benefits of the initiative are identified. The document identifies potential benefits 

of WDL to different stakeholder groups, along with challenges and unresolved issues. This 

paper explores many of the perceived benefits of WDL that are known today, although additional 

benefits may be realized as WDL develops. 

It is also noted that WDL is initially proposed as a voluntary option for registrants, and WDL 

would not be appropriate for all pesticide products. Instead, it is likely that WDL would be used 

primarily for those products with labeling that is long or changes frequently and that are used by 

people primarily in the course of their business activities. The potential benefits described in this 

paper would be realized only for those registrants, users, and dealers of products that are labeled 

with WDL. 

Some benefits will be realized by all involved stakeholders, although others are more 

stakeholder-specific. The following are just some of the key benefits of WDL that are discussed 

in this paper: 

● Access to state-specific and site-specific streamlined, easy-to-read labeling 

● Labeling available in larger fonts 

● Improved labeling compliance 

● Web linkages to product stewardship information 

● Reduced labeling costs and redistribution expenses to registrants 

● Faster access to newly-registered uses 

● Faster implementation of risk mitigation measures 

● Reduction in multiple versions of labeling in the marketplace 

Benefits and Challenges for Specific Stakeholder Groups

The following sections outline potential benefits and challenges for: 

• Pesticide Users 

• Registrants 

• Pesticide Dealers/Retailers 

• Farm Workers and Worker Advocacy Groups 

• State and Tribal Pesticide Regulators 

• United States Environmental Protection Agency 

August 5, 2009 1 of 12 PPDC Discussion Paper 
Pesticide Users

a. Benefits 

 1. Access to streamlined, easy-to-read labeling

WDL would be used to deliver streamlined labeling for users, thereby replacing 

50-page multi-crop labeling with site-specific labeling that is only a few pages. 

This could make it dramatically easier and faster to ascertain how to safely, 

effectively, and legally use products. It should also improve compliance with 

labeling restrictions. 

 2. Access to larger fonts

A common complaint among users is the small font size found on many container 

labels and attached labeling. WDL should make it possible for users to customize 

font size for printed labeling. Users with electronic versions of WDL can simply 

use software to enlarge the labeling image on a computer screen. 

 3. Faster access to newly-registered uses

Re-labeling of containers with hard-copy labeling is a time-consuming and 

expensive process. Because of this, there is often a significant lag time in relabeling containers as newly-labeled containers gradually replace existing 

containers in the channels of trade. Users may therefore be unable to immediately 

access container labeling that contains newly-registered uses. They may also be 

unable to quickly access supplemental labeling with the newly-registered uses. 

With WDL, updated labeling could immediately be posted on the Internet upon 

EPA and state approval, making newly-registered uses immediately available. 

This should provide greater flexibility in dealing with existing stocks of materials 

since existing containers would not need to be re-labeled with the updated 

container labeling. 

 4. Verified access to state-approved labeling

Some users make applications in more than one state, and there is increasing use 

of Internet vendors to market pesticide products. As stated above, many states 

require users to comply not only with a product’s container labeling, but more 

specifically with the labeling approved by that state. Under the current system of 

hard-copy labeling, there is no good means for users who buy products in a 

different state or from the Internet to verify whether the labeling in their 

possession matches the labeling version approved in the state where the product is 

being applied. WDL could make it much easier for users to verify that the 

labeling in their possession is approved for use in the state in which they intend to 

use the product. 

 5. Improved standardization of labeling

Although federal regulations require all pesticide labeling to have certain sections, 

there are generally no requirements for the order in which those sections are 

August 5, 2009 2 of 12 PPDC Discussion Paper 
found on labeling. Furthermore, related restrictions and precautions can be found 

throughout the labeling in different sections. This lack of standardization can 

make it difficult for users to find those portions of the labeling pertaining to their 

intended use site. A parallel project to WDL is the electronic submission of 

pesticide labeling for pesticide registrations. The electronic submission process 

and building websites for WDL may be facilitated through the use of structured 

product labeling and increased standardization of how labeling is formatted and 

arranged. Greater standardization could make it easier for users to read (and 

therefore, comply with) labeling restrictions, precautions, and directions. 

 6. Better access to product stewardship information 

The container label on a WDL product would direct users to a website to access 

and download the labeling specific to the product. The website could also provide 

or link to useful information in addition to the labeling, such as product 

stewardship information on reducing drift, choosing nozzles, calculating use rates, 

state pesticide disposal programs, container recycling, and more. 

 7. Multiple delivery methods

With WDL, pesticide users would be able to choose the delivery method and 

format of WDL that best meets their needs, including direct download in portable 

document format (PDF), HTML or PDF via email, mobile labeling delivery via 

text message, barcode scan delivery to a mobile device, FAX on demand, or an 

email/phone request for a hard copy to be mailed through the US postal system. 

This flexibility does not exist under the current system of hard-copy labeling. 

b. Challenges & unresolved issues 

 1. Lack of high-speed Internet access in all areas

Many parts of the rural U.S. still lack high-speed Internet access, and many 

farmers continue to rely on dial-up modems for Internet access. In addition, not 

all pesticide users have Internet access of any kind. However, people are 

resourceful and rely a variety of means to get the information that they need. 

Also, delivery mechanisms other than direct Internet access will be offered for 

WDL. 

 2. Need for culture change

The transition from hard-copy container labeling to WDL will require a 

significant amount of education of the regulated community. Not all pesticide 

users may be comfortable with this change, especially if they are unaware of the 

concept until it is implemented. WDL would not be used for all products so 

outreach can be targeted to industry sectors. Implementation of a web-distributed 

labeling system would include sufficient time to transition from the traditional 

paper-based system, allowing regulators, extension personnel, and others to 

educate the public. 

August 5, 2009 3 of 12 PPDC Discussion Paper 
 3. Expiration dates and older products

Under the current system of hard-copy labeling, users can continue to use a 

product according to the labeling found on the container for as long as they 

possess the product. The exceptions to this are the rare instances when EPA has 

issued a use cancellation date or when a product is no longer registered in a state 

and that state’s laws prohibit the use of unregistered pesticides. This practice 

allows users to use a product many years after the product is purchased. With 

WDL, the labeling accessed at an Internet site would change over time as uses are 

added or removed. This could mean that labeling might not be valid indefinitely. 

One strategy is to establish an expiration date for WDL based on download date 

or production lots. However, the challenge is to establish expiration dates long 

enough to allow the large majority of users to continue using product until the 

product is completely used, but not so long that a user can continue using the 

downloaded labeling forever. If the expiration date is too short, some purchasers 

of pesticides may not be able to legally use the complete contents of a container 

for the site for which the product was intended at the time of purchase. This 

could create product disposal issues. 

Registrants

 

a. Benefits 

1. Reduced labeling costs

Labeling containers with hard-copy is extremely expensive. It is also expensive 

and resource-intensive for registrants to re-label containers in the channels of 

trade when new uses are registered or existing uses are cancelled. With WDL, 

registrants could “re-label” large numbers of products instantly by simply 

changing the document accessed at a defined Internet site. 

 2. More market sector-specific labeling

The current paper-based labeling system makes it difficult for registrants 

distribute different versions of labeling for the same product in a similar region 

without causing confusion. WDL would include streamlined directions on the 

container label, but most of the site and state-specific instructions would be 

included on the downloaded labeling. Registrants could use WDL to target 

marketing and distribution to specific markets, use patterns, or user groups. 

Registrants could then be confident that users had ready access to the use 

instructions in a more readable format. For example, a product with broad use 

patterns (turf, industrial, agricultural, forestry) could be marketed differently 

based on the different uses through WDL. 

 3. Faster market access 

Because of the time involved with re-labeling containers with hard-copy labels, 

there is a usually a lag time between when uses are registered and when those relabeled containers reach retailers and end users. This can delay user access to 

August 5, 2009 4 of 12 PPDC Discussion Paper 
newly-registered uses, even when registrants use supplemental labeling. WDL 

could result in almost instantaneous access of users to new labeling, as well as 

access of registrants to certain markets. 

 4. Promotes level playing field

Under the current system of hard-copy labeling, EPA may require labeling 

revisions for a category of products, for example products containing a specific 

active ingredient. Even though EPA may establish a single date for making such 

changes, the products from different registrants or for different formulations from 

the same registrant can reach the market at different times depending on market 

forces and differences in supply chains. With WDL, labeling revisions can be 

implemented simultaneously, promoting a level playing field for different 

companies marketing the same active ingredient. 

 5. Faster removal of uses from marketplace

Registrants frequently remove uses from pesticide labeling, either voluntarily 

through marketing decisions or through a regulatory mandate. Just as it allows for 

faster market access for new uses, WDL could facilitate faster removal of uses 

from the marketplace. 

 6. Enhanced Inventory Management

All states have a state pesticide registration program, making it illegal to 

distribute or sell (and, in some states, to use) a product that is not registered in the 

state. In some states, pesticides can also be deemed misbranded if they are 

distributed with labeling other than the labeling that has been registered by the 

state. Since the version of labeling approved in one state may differ from that 

registered in other states, registrants must manage their inventory to ensure that 

pesticides shipped into a state are appropriately labeled. With hard-copy labeling, 

this may necessitate the re-labeling of containers prior to shipping products across 

state lines, or a registrant may simply choose to not market products in certain 

states if inventory management is not feasible. With WDL, registrants could 

customize the labeling for a given state and site, thereby addressing state-specific 

differences in labeling without re-labeling containers. 

b. Challenges & unresolved issues 

 1. Tort liability questions

There are many concerns about whether the institution of WDL will alter the tort 

liability of pesticide registrants. Would those who adopt the WDL approach be 

more vulnerable to tort litigation if users do not comply with requirements to 

obtain labeling? Conversely, would registrants who opt out of the WDL process 

be more vulnerable to tort litigation for failure to employ technology that could 

better inform customers how to use products safely and effectively? 

August 5, 2009 5 of 12 PPDC Discussion Paper 
2. Enforcement liability questions 

There are questions about how FIFRA enforcement might change under a WDL 

system, including who would be responsible if the WDL downloaded from a 

website is incorrect and whether a product is registered in a given state. This may 

concern some registrants because they are likely to be held responsible to ensure 

that all WDL labeling is correct. However, registrants also have this 

responsibility with hard-copy labeling, so the issue may be with information 

technology rather than regulation. 

 3. Gaining acceptance by dealers and users

Although the current system of hard-copy pesticide labeling is imperfect, most 

pesticide dealers and users understand it. With any significant change, there may 

be those that resist the change and voice their concerns. Discomfort with change 

and technology may push some customers and dealers toward products with hardcopy labeling, at least initially. Outreach and education targeted to both pesticide 

users and dealers may reduce the concerns expressed if WDL is implemented. 

 4. Increased standardization of labeling format 

Implementation of WDL may lead to pressure for increased standardization of 

how labeling is formatted. Some registrants may view any increased uniformity 

as a limitation on their creativity. 

5. Customer Acceptance

The transition from hard-copy container labeling to WDL will require a 

significant amount of education of the regulated community. Not all pesticide 

users may be comfortable with this change, especially if they are unaware of the 

concept until it is implemented. In order for registrants to realize the full benefits 

of WDL, they would need to ensure that their customers are aware of and willing 

to accept the transition. 

Pesticide Dealers/Retailers

a. Benefits 

 1. Greater customer understanding of product labeling

How many times does a dealer get a question from customers on how to safely, 

effectively, and legally use a product that they have purchased or intend to 

purchase? With streamlined WDL, the use directions would be site-specific and 

may include application-specific instructions. This should increase customer 

understanding and reduce the number of questions to dealers on labeling 

interpretation. 

 2. Capitalizing on customer service

People who apply pesticides as part of their business rarely go to a dealer and read 

the labeling in the dealer establishment. Therefore, they will continue to depend 

on dealers, agronomists, and other parties for expertise and assistance in making 

August 5, 2009 6 of 12 PPDC Discussion Paper 
product choices. WDL would allow for a direct connection between the dealer 

and the applicator that is purchasing the product. Some customers may also ask 

dealers to access and print WDL. This sales and communication opportunity 

could increase customer loyalty to dealers who offer these services. 

 

b. Challenges & unresolved issues 

 1. Increased demand for customer service

There will almost certainly be requests from customers for dealers to access and 

download WDL for their purchases. While some retailers may view increased 

customer service as an opportunity to gain sales and customers, others could view 

it as a burden. Some retailers may also need to train their employees to better 

serve customers and deal with technology. 

 2. IT investments & Lack of high-speed Internet access

Some dealers may not have computers or high-speed Internet access. Many parts 

of the U.S. still lack high-speed Internet access, and dealers and farmers in those 

areas continue to rely on dial-up modems for Internet access. If they choose to 

download and print WDL as a service to their customers, those dealers will need 

to make technology upgrades and budget their services accordingly. Dealers may 

also build relationships with libraries, coffee houses, and other locations that 

already offer Wi-Fi and other technologies to access the Internet. 

 3. Liability questions

Some have raised questions as to whether dealers would have any responsibility 

to ensure that the purchaser of a product accesses the WDL, and whether dealers 

incur any liability if they access incorrect WDL on behalf of a customer. EPA’s 

enforcement issue paper makes it clear that it is the ultimate responsibility of the 

pesticide user to obtain and comply with the correct version of the WDL. Such a 

regulatory position should adequately address the liability concerns voiced to date 

by dealers, although this issue continues to generate further discussion. 

Farm Workers and Worker Advocacy Groups

a. Benefits 

 1. Better risk mitigation

As already discussed, two benefits of WDL would be the availability of a 

streamlined container label, and the ability of the WDL system to provide shorter, 

site-specific labeling. The first would allow employers and employees to find 

those sections of the container label that address worker safety, such as first aid, 

emergency contact information, personal protective equipment, and re-entry 

intervals. The shorter, site-specific labeling would also increase the likelihood 

August 5, 2009 7 of 12 PPDC Discussion Paper 
that pesticide users will read and comply with the labeling requirements, thereby 

improving risk mitigation. 

 2. Better communication with non-English-speaking workers 

Use of technology would make it possible to better communicate to non-Englishspeaking workers or those persons with low levels of literacy. While the 

container labeling will direct users to Internet sites with enforceable labeling, the 

WDL system could also incorporate links to Internet sites with product 

stewardship information. These websites could use streaming video, pictures, and 

other methods to better convey how to safely use and handle pesticides. If 

resources have been translated, they could also be made available in languages 

other than English. 

b. Challenges & unresolved issues 

 1. Lack of high-speed Internet access 

High-speed Internet access, or any Internet access for that matter, is not accessible 

for some farm workers, especially migrant workers. Therefore, some workers 

may not be able to directly access WDL because full container labeling would not 

be available. However, safety-related information would be on the label affixed to 

the container. 

2. Limited scope of the WDL system 

Participation in the WDL system would be voluntary and advocacy groups may 

have interest in products that are not part of the WDL system. Although the WDL 

system might not meet all of the needs of advocacy groups, that instituting a 

WDL system would not decrease the amount of information available. 

State & Tribal Pesticide Regulators

a. Benefits 

1. Better user compliance & risk mitigation

A fundamental tenet of pesticide regulation is the belief that a pesticide will not 

cause unreasonable adverse effects to human health or the environment as long as 

it is used according to the labeling. However, pesticide labeling can be long and 

difficult to read, and anecdotal information suggests that some pesticide users do 

not fully read the labeling for that reason. WDL could be used to deliver 

streamlined labeling for users, thereby replacing 50-page multi-crop labeling with 

site-specific labeling that is only a few pages. This should increase the number of 

pesticide users reading, and therefore complying with, the pesticide labeling. 

2. Faster implementation of new labeling requirements

Many times, new labeling restrictions are implemented to better mitigate risk or to 

add newly-registered uses. However, it can sometimes take months or years for 

re-labeled pesticide products to reach the channels of trade and the hands of users. 

August 5, 2009 8 of 12 PPDC Discussion Paper 
WDL could be used to get revised labeling in the channels of trade sooner. This 

is especially beneficial for market entry of reduced-risk uses and products. 

3. Reduction in multiple versions of labeling in the marketplace

With the current system of hard-copy labeling, there is often a significant lag time 

in re-labeling containers as newly-labeled containers gradually replace existing 

containers in the channels of trade. During this interim period, there are multiple 

versions of product labeling in the channels of trade. The multiplicity of versions 

of product labeling also occurs as a consequence of the practice using 

supplemental labeling to allow for the legal use of newly registered uses. This 

proliferation of labeling can create confusion among pesticide users. It can also 

cause regulatory challenges because it is difficult to verify what version of a 

product’s labeling a user had in their possession during use. For participating 

products, the WDL system would largely eliminate multiple versions of labeling 

in the channels of trade and the use of supplemental labeling. 

 4. Easier verification of compliance with state-registered labeling

All states have a state pesticide registration program, making it illegal to 

distribute or sell (and, in some states, to use) a product that is not registered in the 

state. This involves a state reviewing labeling. However, this labeling can vary 

greatly among states, either because some state-specific language may appear 

only in the relevant state or because of other voluntary differences in labeling by 

registrants based on market forces. In many states, a product can be deemed to be 

misbranded under state law if it bears labeling other than what has been registered 

by the state. Under the current system of hard-copy labeling, it is difficult or 

impossible for state regulators to verify whether the applicator is using labeling 

that matches approved by the state. By using technology available to compare 

different versions of similar electronic files, WDL should make this verification 

much easier. 

 5. Increased standardization of labeling format 

Although federal regulations require all pesticide labeling to have certain sections, 

there are generally few requirements for the location or order in which those 

sections appear in labeling. Furthermore, related restrictions and precautions can 

be found throughout a product’s labeling in different sections. This lack of 

standardization can make review difficult. A parallel project to WDL is the 

electronic submission of pesticide labeling for pesticide registrations. The 

electronic submission process and web-produced WDL may be facilitated through 

the use of structured product labeling and increased standardization of labeling 

format. 

August 5, 2009 9 of 12 PPDC Discussion Paper 
b. Challenges & unresolved issues 

1. Lack of Internet access for State inspectors

Some agencies do not have Internet access for field inspectors. In order for WDL 

to be of most utility to regulators, State inspectors should be able to access the 

website in the field to compare the state-registered version of labeling with the 

version in the possession of the applicator. 

2. Defining appropriate labeling formats “in possession”

 With hard-copy labeling, regulators can usually verify labeling compliance during 

use inspections by simply referring to the labeling accompanying a product 

container (if the container is available). However, with WDL, the labeling would 

not be physically attached to the container. Because of this, most regulators agree 

that there should be a requirement for the user of a product with WDL to have a 

copy of the labeling in their possession during use. While some states may allow 

the labeling in the possession of the user to be in an electronic format, other states 

may want the labeling to be in hard-copy format. This may cause confusion 

among users, especially those that make applications in more than one state. 

 3. Conflicts with state-specific laws or regulations

Some states may have statutory or regulatory requirements that address the 

distribution of pesticide labeling, including the allowed formats for labeling being 

distributed. Distribution of web-based labeling may conflict with the laws and 

regulations in some states. If EPA establishes a WDL system, the effect of 

FIFRA sec. 24(b) – which prohibits states from “impos[ing] or continu[ing] in 

effect any requirements for labeling . . . different from those required under 

[FIFRA]” – on any such provisions would need to be evaluated. 

US Environmental Protection Agency

a. Benefits 

1. Improved protection of public health and the environment

 Product labeling is the primary mechanism used by EPA to communicate critical 

information to the pesticide user. The labeling contains use directions, health and 

safety information, and instructions for proper storage and disposal. Improved 

comprehension of and compliance with labeling and faster realization of risk 

mitigation measures in the field, expected benefits of web distributed labeling, 

would improve protection of human health and the environment. 

2. Improved labeling comprehension & compliance

A fundamental tenet of pesticide regulation is the belief that a pesticide will not 

cause unreasonable adverse effects to human health or the environment as long as 

it is used according to the labeling. However, pesticide products’ labeling can be 

long and difficult to read, and anecdotal information suggests that many pesticide 

users do not fully read the labeling for that reason. WDL can be used to deliver 

streamlined labeling for users, thereby replacing 50-page labeling with labeling 

August 5, 2009 10 of 12 PPDC Discussion Paper 
that is only a few pages. The shorter web-distributed labeling would be targeted 

to the state and target site of the application, providing only the relevant required 

elements of labeling. Streamlined, simplified labeling should result in a greater 

likelihood of pesticide users reading and understanding, and therefore complying 

with, the pesticide labeling. 

3. Faster implementation of new labeling requirements

The web-distributed labeling system has the potential to dramatically accelerate 

the speed with which new labeling requirements to protect public health and the 

environment could take effect. Rather than waiting for paper labeling to work its 

way through the printing and distribution processes, the new requirements could 

appear in labeling downloaded from the website within a week or even a day or 

two after EPA approval. Users who purchased products after the changes were 

posted on the website would find the new requirements in the labeling they 

downloaded. Thus, like the current system the new requirements would apply 

prospectively, to products purchased after the date of EPA’s decision. Unlike the 

current system, it would implement changes much sooner after EPA concluded 

they were needed. Faster implementation of risk mitigation measures and 

registration of reduced-risk products could improve the overall safety of public 

health and the environment. 

b. Challenges & unresolved issues 

1. Need for culture change

The transition from hard-copy container labeling to WDL would require a 

significant amount of education of stakeholders throughout the regulated 

community. Not all people will be comfortable with this change, especially if 

they are unaware of the concept until it is implemented. Stakeholder outreach is 

critical to the refinement of web-distributed labeling; feedback and support from 

registrants, users, dealers, educators, state regulators, and environmental groups, 

and others is necessary to ensure that the concept can be successful. Once 

stakeholders are comfortable with the concept, broad outreach to all potentially 

affected parties will occur. Implementation of a web-distributed labeling system 

will include sufficient time to transition from the traditional paper-based system, 

allowing regulators, extension personnel, and others to educate the public. 

2. Ensuring a level playing field

 Web-distributed labeling has the potential to benefit registrants who elect to 

participate in such a system. Although some registrants may elect not to 

participate in web-distributed labeling, others may not have the capability. EPA 

must be sensitive to the concerns of those who cannot participate during the 

development of the web-distributed labeling system and should ensure that the 

web-distributed labeling system is available to all potential stakeholders. 

 3. Conflicts with state-specific laws or regulations

August 5, 2009 11 of 12 PPDC Discussion Paper 
Some states may have statutory or regulatory requirements that address the 

distribution of pesticide labeling, including the allowed formats for labeling being 

distributed. Distribution of web-based labeling may conflict with the laws and 

regulations in some states. If EPA establishes a WDL system, the effect of 

FIFRA sec. 24(b) – which prohibits states from “impos[ing] or continu[ing] in 

effect any requirements for labeling . . . different from those required under 

[FIFRA]” – on any such provisions would need to be evaluated. 

4. Definition of ‘production” and registration of establishments 

EPA regulations for the registration of establishments require that an operator 

must register his establishment if he engages in “production” of a pesticide. 

“Production” is described to include re-labeling a pesticide. EPA needs to clarify 

that the action of downloading WDL does not constitute “production” of a 

pesticide. 

5. EPA Internet Access

Generally, the private sector adopts developing technology faster than EPA. 

Implementing WDL would require significant technological advances, including 

building a database for state-registered labeling, hosting a website/portal, and 

including security controls to maintain the integrity of labeling. If EPA is 

required to build and maintain the WDL system, adoption could take longer. 

Summary 

Although significant questions still remain, the potential benefits and challenges of WDL for 

regulators, pesticide users, registrants, and other stakeholders must be considered. Other 

benefits and challenges will likely be identified as the development of a WDL system moves 

forward. 

August 5, 2009 12 of 12 PPDC Discussion Paper