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Web-Distributed Labeling for Pesticide Products

Pesticide Registration Notice

Notice To: Manufacturers, Producers, Formulators, and Registrants of Pesticide Products

Attention: Persons Responsible for Initial and Continuing Federal Registration of Pesticide 

Products

Subject: Web-Distributed Labeling for Pesticide Products

This Notice presents the Agency’s guidance on optional participation in web-distributed labeling 

for pesticide products. The Agency believes that voluntary adoption of these recommendations 

by pesticide registrants will help pesticide users to better understand and comply with pesticide 

labeling. In addition, the Agency believes that web-distributed labeling could allow addition of 

new uses, modification of existing labeling, and implementation of labeling-based risk mitigation 

measures more quickly. EPA undertakes initiatives such as this facilitate access to specific 

pesticide product labeling. This Notice is intended to improve existing labeling by allowing users 

to download the portions of the pesticide labeling specific to their intended state and site of use. 

Registrants who wish to adopt web-distributed labeling should follow the instructions in this 

Notice. No registrant is required to take any action in response to this notice.

EPA plans to reevaluate this Pesticide Registration Notice within 5 years of the final publication 

date to ensure that the web-distributed labeling system is keeping up with current technology. 

I. Products Potentially Affected by This Notice

This Notice is targeted to pesticide products marketed primarily to applicators for use in the 

course of commercial activity, such as commercial applicators applying to agricultural, turf, and 

structural sites, and private applicators in the course of producing an agricultural commodity. If 

you have questions on applying this Notice to your product, please contact the EPA Product 

Manager or Regulatory Action Leader.

II. Scope of Policy 

This PR Notice provides guidance to pesticide registrants and to EPA. Although EPA encourages 

registrants to adopt the following options for making labeling content available via the internet, 

this Notice is not binding on either EPA or pesticide registrants, and EPA may depart from this 

guidance in individual circumstances. Likewise, pesticide registrants who voluntarily choose to 

participate in this initiative may assert that the guidance is not appropriate for a specific pesticide 

or situation.

III. Background

Since 2007, the U.S. Environmental Protection Agency (EPA or the Agency) has been exploring 

the feasibility and advisability of allowing registrants to make legally enforceable pesticide 

product labeling available to users via the internet, an initiative referred to as “web-distributed 

labeling” (WDL). At the end of 2010, EPA initiated a “user acceptance pilot” that ran until 

April 2011. (75 FR 51058, August 18, 2010; EPA-HQ-OPP-2010-0632) The user acceptance 

pilot involved a simulation of a WDL website that users could visit and on which they could 
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provide feedback. The user acceptance pilot did not involve any changes to existing pesticide 

labeling on containers or legally valid electronic versions of pesticide labeling. EPA also 

published a Federal Register notice that outlined EPA’s positions on issues related to WDL and 

also sought comment on a number of these issues. (75 FR 82011, December 29, 2010; EPA-HQOPP-2010-0648)

Based on its review of the comments and other feedback received from the Federal Register

notice, the user acceptance pilot, and the draft of this Pesticide Registration Notice (; EPA-HQ2012-0906), EPA is implementing a voluntary approach to WDL that would allow registrants to 

distribute pesticide products with labeling that refers the user to the website from which the user 

may download legally valid, enforceable labeling. The container would still be accompanied by 

a physical copy of the EPA-accepted labeling sufficient for the correct use of the product. 

However, a user could access the most current version of the state- and site-specific labeling 

from a website identified on the container label. Offering WDL while retaining the full labeling 

on or accompanying pesticide containers would allow users, registrants, and EPA to acquire a 

better understanding of the strengths and limitations of WDL and possibly serve as a transition to 

a system that relies more heavily on the internet and other technologies to provide users with 

legally enforceable labeling. For example, registrants could determine whether specific types of 

products would be better suited to WDL and users could evaluate the relative benefit of WDL 

versus the current pesticide product labeling.

As considered by EPA, WDL would make available via the internet site- and state-specific use 

directions for pesticide products as downloadable electronic files. To access this labeling, a user 

would visit the website identified on the pesticide label, enter information identifying the 

product, and select the intended state and use site. The website would return a streamlined 

version of the pesticide labeling containing the language applicable to all uses, such as hazard 

and first aid statements, and the relevant state/site specific directions for use (e.g., application to 

cranberries in Maine). 

This PR Notice provides guidance about how EPA intends to implement WDL under this 

system. 

IV. Discussion of Issues and Recommendations

A. Terminology in this Notice

The list of terms below provides a description of the meaning of each term for the purposes of 

this Notice only. These definitions do not supersede or otherwise alter any definitions contained 

in FIFRA or EPA’s pesticide regulations.

1. Master labeling – The complete set of EPA-accepted labeling information, including all 

approved uses and associated use information for a pesticide product registration, regardless of 

whether this complete set is actually distributed or sold with the product.

2. Quick Reference (QR) Code – A barcode that can be read by a smartphone or other hand-held 

technology device with a camera that directs the user to a specific website. 
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3. Released for shipment – A product becomes released for shipment when the producer has 

packaged and labeled it in the manner in which it will be distributed or sold, or has stored it in an 

area where finished products are ordinarily held for shipment. Products stored in an area where 

finished products are ordinarily held for shipment, but which are not intended to be released for 

shipment must be physically separated and marked as not yet released for shipment. Once a 

product becomes released for shipment, the product remains in the condition of being released 

for shipment unless subsequent activities, such as relabeling or repackaging, constitute 

production. (40 CFR 152.3) 

4. Released for shipment date – For the purposes of this Notice only, the date printed on the 

container label or body of the container that corresponds to the date on which the product 

container was released for shipment as defined in this Notice and at 40 CFR 152.3. The released 

for shipment date should be prominent and the location should be described on the container 

label. The released for shipment date should be located in a place that is visible without opening 

the label, package, or booklet attached to the container.

5. Rendered output – The final version of WDL returned to a user for a product where the user 

has performed a search for labeling using the product’s unique identifier, a state and specific site. 

6. Unique identifier – For the purposes of this Notice, a series of characters, e.g., an alphanumeric combination, used to distinguish the labeling for a specific version of the product from 

other products with the same registration number and different labeling as permitted under 40 

CFR 152.130(b). The registrant would need to establish a new unique identifier if a change in 

the labeling would render the previously approved version of the labeling invalid, for example, in 

the event of a change to the precautionary statements, use classification, or packaging of the 

product. For example, if product A’s labeling version 1 advised users that the product was 

flammable, and the registrant reformulated product A to eliminate flammability, product A’s 

labeling version 2 would need a different unique identifier than product A’s labeling version 1. 

The unique identifier must be distinguished from the EPA registration number, establishment 

number, and distributor number, but may start with the EPA registration number. Registrants 

would develop the unique identifiers for each product to which WDL would apply. The unique 

identifier should be identified clearly as the unique identifier. The unique identifier should be 

located in a place that is visible without opening the label, package, or booklet attached to the 

container.

7. Web-distributed labeling – Legally valid labeling for a pesticide product that is accessed 

through the Internet and can be tailored to the product user’s intended state and site of 

application.

B. Description of Process for Adding WDL to a Product’s Labeling 

Each registrant wishing to use WDL submits an application for amended registration containing 

new labeling statements as described in more detail below. See Section V. If EPA approves the 

application, the registrant would be responsible for creating, publishing, and maintaining the 

website containing the WDL. This responsibility would be in addition to all other regulatory 

requirements related to pesticide registration and labeling. WDL would not change EPA’s 
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policies about and requirements for submission and review of final printed labeling. Registrants 

could control the formatting of the rendered output of the labeling, so long as the rendered output 

conforms to the existing applicable requirements at 40 CFR Part 156 (e.g. 40 CFR 156.10(a)(2)). 

Users would follow the URL on the pesticide container label to the appropriate website using a 

computer, smartphone, or other internet-enabled device. They would enter the unique identifier 

for the product, the state where the product will be used, and then select the use site from an 

established list of some or all uses approved on the master labeling for inclusion as part of the 

WDL (known as a “pick list”; see http://www.epa.gov/pesticides/foodfeed/ for EPA’s 

recommended terminology for some commodities). The website would return a streamlined 

version of labeling that includes all general information from the labeling and only the use 

directions and restrictions related to the specific state and site of use. The user would verify that 

the date on the WDL rendered output was later than the container’s released for shipment date 

(i.e., WDL labeling would be legally valid only if it bears an approval date on or after the 

released for shipment date). The user could print the WDL, save it electronically, or view it. 

Printing the WDL would not constitute production by the user as defined at 40 CFR 167.3. See

75 FR 82011, 82022; December 29, 2010. The user would be responsible for complying with 

either the WDL or the container labeling. Also, the user would be responsible for complying 

with applicable requirements (e.g., state regulations) that require users to maintain a copy of the 

labeling used for application. The use of WDL would not impose any additional recordkeeping 

requirements on users.

Registrants may choose to further refine the web-distributed labeling returned to the user as long 

as the web-distributed labeling content includes all general information and the use directions 

and restrictions related to the specific state and site of use chosen by the user. For example, 

registrants may choose to offer the user the option to refine the web-distributed labeling by 

application method or to retrieve the labeling in both English and another language.

C. New Labeling Statements

The Agency recommends that a statement be added to the container label of each pesticide 

product using WDL and on the rendered output of the WDL. For WDL labeling to receive EPA 

approval, the statement should: (1) direct users to the relevant website, (2) note that the 

electronic version of the labeling is also legally valid, and (3) inform users in cases where the 

additional labeling conflicts with the container label, the user may choose which version of the 

labeling to follow. The statement should make clear that for areas of overlap or conflict, the user 

must use only one set of labeling instructions, either the attached container label or the 

downloaded labeling. The following statement should appear at the beginning of the directions 

for use immediately following any required text. Minor wording changes may be acceptable.

“You may obtain additional labeling from {insert website URL}. If using the 

additional labeling to apply the product, you must possess a copy of this 

additional labeling at the time of application. It is a violation of federal law to use 

this product in a manner inconsistent with its attached label or any additional 

labeling, including any web-distributed labeling. In instances where the 

additional web-distributed labeling conflicts with the container label, the user may 
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choose a single, valid version of the labeling to follow. However, for areas of 

overlap or conflict, the user must use only one set of labeling instructions, either 

the attached container label or the web-distributed labeling. Do not mix and match 

labeling directions.”

To facilitate linkage to labeling that changes over time, pesticide labeling for products using 

WDL should bear a released for shipment date and a unique identifier. These pieces of 

information would be used to match the product with the correct set of WDL. The released for 

shipment date and unique identifier, both clearly identified as such, should appear either on the 

pesticide container or on the labeling. The labeling should inform the user of the specific 

location on the container or labeling of the released for shipment date and unique identifier. This 

statement should follow the WDL statement listed above or an equivalent statement:

“The released for shipment date is in {specify format, e.g., Month DD YYYY, 

DDMMYYYY, or MMDDYYYY} format and can be found {location, e.g., on the neck of the 

container}. The unique identifier format is {format, e.g., 10 character alpha-numeric 

combination} and it can be found {location, e.g., on the neck of the container}.”

The first page of the rendered output of WDL should include a statement indicating the legal 

validity of the label and explaining how labeling must be followed when different versions are 

available to the user. For example, WDL could contain the following statement in a prominent 

location, for example, at the top of the page following any required text, such as the restricted 

use statement:

“This labeling is legally valid only for use in {state} and only with container of 

product {name of product & unique identifier} that bears a “released for 

shipment” date on or before {date of website access}. For pesticide applications 

following this labeling, you must possess a copy of this labeling at the time of 

application. If this labeling conflicts with labeling found on the pesticide product, 

use only one set of the labeling instructions in its entirety. Do not mix and match 

labeling directions.”

“Currently the user is responsible for complying with the requirements of product 

labeling obtained when the user took possession of the product’s container. The 

user must comply with all instructions and requirements in the labeling and must 

keep the labeling as long as the user has the container. Similarly, the user who 

relies upon WDL may meet this requirement by maintaining a printed or 

electronic copy of the labeling to meet federal and state recordkeeping 

requirements. In the situations described above where the WDL labeling conflicts 

with labeling on the pesticide container, the user must be able to identify which 

labeling was used and followed at the time of the pesticide’s application.”

Subsequent pages of the labeling should include an abbreviated legal statement that references 

the primary statement on legal validity of the labeling. For example the following statement 

could be located in the header of the document:
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“This labeling is legally valid only for use in {state} and only with the container 

of {name of product & unique identifier} that bears a “released for shipment date” 

on or before {date of website access}. See page 1 of this document for additional 

legal requirements on the use of this labeling.”

The registrant also should ensure that the web-distributed labeling includes on each page the 

following statements as part of the footer:

“This web-distributed labeling was rendered by accessing {website} on {date}.” 

“{Product name} Web-Distributed Labeling – Page {page number} of {total pages}.”

In addition to the information and statements listed above, the registrant may include a Quick 

Response code or a similar symbol capable of being scanned by handheld devices to connect to 

the internet and to return to the website listed on the container label or accompanying material. 

Per Section 2(p)(2) of FIFRA, the content the Quick Response code or other similar symbol 

references would be considered labeling and therefore subject to review by the Agency.

D. Website 

1. WDL Content

After the user searches by unique identifier, state, and site, the website should provide the user 

with the general labeling content that applies across all use sites as well as the content specific to 

the use site(s) requested by the user. The labeling content provided to users should be 

subdivided by use site and state. Additional subdivisions, such as application method, may be 

acceptable on a case-by-case basis. 

The WDL rendered output should also include the statements and content listed in Unit IV.C. or

equivalent. The rendered format of the labeling must conform to existing applicable standards at 

40 CFR Part 156.

Where practicable, all WDL website functionality and rendered output should be accessible by 

handicapped individuals.

2. Website References on Labeling

Registrants (or their content providers) may develop a website for WDL distinct from existing 

websites. The simplest WDL URL would direct the user to a website where he or she could 

input the unique identifier, state, and site of application. The website would return only the 

WDL requested by the user. Any links from this WDL website to other information could 

clearly indicate through a disclaimer statement that the user is exiting the portion of the website 

considered labeling and going to a website that is not part of the product’s labeling.

 

Should the registrant wish to add or retain a reference to the company’s website on the labeling, 

including by directing the user to the registrant’s primary website to download labeling, the 

registrant should be aware that the website becomes labeling under FIFRA and is subject to 

review by the Agency. For example, if the container label directed the user to www.website.com
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to download the WDL, all content on www.website.com would be considered labeling. If the 

website is false or misleading, the product would be misbranded and unlawful to sell or distribute 

under FIFRA section 12(a)(1)(E). 40 CFR 156.10(a)(5) lists examples of statements EPA may 

consider false or misleading. Again, any links from the WDL portion of the website to other 

information could clearly indicate through a disclaimer statement that the user is exiting the 

portion of the website considered labeling and going to a website that is not part of the product’s 

labeling. 

In addition, regardless of whether a website is referenced on the product's labeling, claims made 

on the website may not substantially differ from those claims approved through the registration 

process. FIFRA section 12(a)(1)(B). Therefore should the Agency find or if it is brought to 

EPA’s attention that a website contains claims substantially differing from the EPA-approved 

registration, the website could be referred to the EPA's Office of Enforcement and Compliance 

Assurance. 

3. Website Function

EPA will consider website functionality when deciding whether to approve an amendment to add 

WDL. In order to ensure that the WDL website, and thus pesticide labeling, is readily available 

to users, ideally, the website would have minimal down time and be accessible 24 hours a day, 

every day of the year, exclusive of website maintenance downtime. Registrants should schedule 

routine website maintenance at times when expected user traffic is minimal. The website would 

also have a reasonable minimum response time. The content provider should consider the 

potential number of people that may attempt to access the site at one time. 

Registrants (or their content providers) should not limit users from accessing labeling content 

through the website by requiring users to log in or pay a fee, even where other non-WDL 

services do require users to log in or pay a fee. The website should not require advanced (i.e., 

more than current common computer capabilities or standard software) computer systems or 

software. The labeling content should be provided, at a minimum, in PDF format, although 

registrants may choose to make WDL available through other technology, such as “apps” for 

tablets or smart phones. Users should not be required to download software specific to the WDL 

site when accessing the WDL site from a traditional computer (i.e., not a smartphone or other 

hand-held internet-enabled device). The website should direct users who do not have the Adobe 

Acrobat Reader program installed on their computers to the website where users can download 

and install the program.

The website URL should be easy to read and easily identifiable, generally with no more than 25 

characters. The URL should link directly to the WDL webpage where the user can search for the 

labeling content by unique identifier, state, and use site. When designing websites, registrants 

should be aware that many rural areas still lack broadband internet access. 

4. Website Security

Registrants should ensure secure access to upload or change labeling on the WDL website. 

Registrants would be responsible for ensuring that the content of the WDL site, including 

labeling, is accurate and up to date. Registrants should ensure the labeling provided from the 
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WDL website (rendered output) cannot be altered by users. EPA recommends that registrants 

maintain an audit history for users performing any activity other than accessing labeling.

5. Website Usage Data

In order for the EPA to analyze the success, needs, and future direction of the WDL program, 

EPA may periodically discuss with registrants website usage information on the WDL websites. 

Website usage information that may be of interest includes:

• Number of website hits

• Average time user spends on the website

• Number of downloads/printed labels

• Other web content that is provided 

• Other content that is accessed by the users

Where feasible, EPA may also seek information on the registrant’s WDL activities by state and 

use site. 

E. Discontinuing Web-Distributed Labeling

A registrant may choose to discontinue making labeling available through the internet at any 

time. To discontinue participation in web-distributed labeling, the registrant would cease to 

make available labeling at the website designated on the pesticide container labeling. The 

website listed on the product container labeling would inform the user that no web-distributed 

labeling is available for the product and instruct the user to follow the label that is attached to the 

container.

V. What Registrants and Applicants Can Do

A. Adoption of Web-Distributed Labeling 

To initiate the process of adding WDL to an existing product registration, the company would 

file an application for an amendment with EPA. Adding WDL to an existing product registration 

is not necessarily an action covered by the Pesticide Registration Improvement Act (PRIA). 

Submitting an amendment that only seeks to add WDL to labeling would be a non-PRIA Fast 

Track action. However, a registrant could include an application to amend labeling to include 

WDL as part of an action covered by PRIA, such as adding a new use site. 

A registrant may also choose to add WDL to a proposed new product’s labeling. 

In addition to any other required elements of the application, applications that incorporate WDL 

should include the master labeling and examples (preferably at least two) of the labeling in the 

rendered output (state- and site-specific labeling). Registrants could submit WDL to EPA as 

electronic files, such as a link to a non-public test website or a PDF file. EPA would also accept 

printed copies of the WDL for review.

As part of the approval process, EPA may review the website including rendered content through 

a link to a draft of the website not available to the public (if available), URL, and/or printed 

samples of the rendered labeling content. All content submitted to EPA for review should be 

clearly marked as draft and not valid for legal use. EPA may ensure the URL is easy to read and 
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that it directs the user directly to the WDL webpage. EPA may also review the website on a 

case-by-case basis to evaluate ease of use. EPA would also review the labeling in the rendered 

output to determine, on a case-by-case basis, if it correctly reflects the approved master labeling. 

Note: Only the master labeling would be stamped "accepted"; the sample rendered WDL 

labeling would not be stamped. As a condition of approval of the amendment, EPA may require 

the registrant to amend the website to provide updated labeling within a specific timeframe after 

the revised labeling receives all necessary approvals from EPA and a state. EPA anticipates that 

it would require registrants to provide updated labeling within a specific time frame if necessary 

to implement risk mitigation measures. For other changes, such as adding a new use, EPA 

would likely leave the labeling amendment schedule to the discretion of the registrant, provided 

the labeling and website are updated within 18 months of approval by EPA as is the standard 

timeframe for updating labeling when new labeling is approved. See 40 CFR 152.130(c).

B. Discontinuing Participation in Web-Distributed Labeling

To initiate the process of removing WDL from an existing product registration, the company 

would file an application for an amendment with EPA. Removing WDL from an existing 

product registration is not necessarily an action covered by PRIA. Submitting an amendment 

that only seeks to remove WDL from labeling would be a non-PRIA Fast Track action. 

However, a registrant could include an application to amend labeling to remove WDL as part of 

an action covered by PRIA. 

C. Supplemental Distributors

The label of a distributor product must be the same as the label of the parent product, except as 

provided in 40 CFR 152.132(d). If the primary registrant for the product uses WDL, the 

supplemental distributor of that product can choose whether to participate in WDL for the 

supplementally distributed product under the terms of the agreement between the primary 

registrant and supplemental distributor. However, if the primary registrant does not use WDL 

for a product, the supplemental distributor of that product may not use WDL for that product.

VI. Effective Dates

This Notice will be effective immediately. 

VII. Addresses to Use

Registrants should send amendments to one of the following addresses: 

U.S. Postal Service Deliveries

The following official mailing address should be used for all correspondence or data submissions 

sent to OPP by U.S. mail:

Document Processing Desk (AMEND) (Distribution Code as identified in PR Notice 2006-1)

Office of Pesticide Programs (7504P)

U.S. Environmental Protection Agency

Ariel Rios Building1200 Pennsylvania Ave., NW

Washington, D.C. 20460-0001

Personal/Courier Service Deliveries
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The following address should be used for all correspondence or data submissions that are handcarried or sent by courier service Monday through Friday, from 8:00 AM to 4:30 PM, excluding 

Federal holidays:

Document Processing Desk (Distribution Code as identified in PR Notice 2011-X) (AMEND) 

Office of Pesticide Programs (7504P) 

U.S. Environmental Protection Agency

Room S-4900, One Potomac Yard

2777 South Crystal Drive 

Arlington, Virginia 22202-4501 

VIII. For Further Information 

If you wish to obtain further information on this notice, please contact Michelle Arling, 

arling.michelle@epa.gov, 703-308-5891. For questions about a specific product or active 

ingredient, please contact the product manager.

___________________________ Dated:_________________

Steven Bradbury, Ph.D., Director

Office of Pesticide Programs

U.S. Environmental Protection Agency

Attachments
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Attachments to PR Notice 2014-1

These attachments present how master labeling for a hypothetical product could be revised to 

include web-distributed labeling, a properly rendered example of web-distributed labeling, and 

several examples of improperly rendered web-distributed labeling.

The attachments are as follows:

• Bugtox Master Labeling (proper web-distributed labeling statements)

• Bugtox Web-Distributed Labeling for Pome (proper web-distributed labeling)

• Bugtox Web-Distributed Labeling for Pome (incorrect web-distributed labeling – missing 

directions for use)

• Bugtox Web-Distributed Labeling for Pome (incorrect web-distributed labeling – missing 

precautionary statement)

• Bugtox Web-Distributed Labeling for Pome (incorrect web-distributed labeling – only 

contains directions for use)