If the product is a distributor product, it must meet federal registration/labeling requirements as laid out in the Supplemental distribution code (40 CFR 145.132)
Labeling must be provided for the following:
- Label of the box/ container
- Individual labels for each product (pesticide or non-pesticide) found inside the box. The active ingredient list found on the box/container referenced above does not count.
- Supplemental labels/pamphlets
According to the Sale and Distribution of Misbranded Pesticides and Devices statute, a person may not offer for sale or distribute a pesticide or device determined by the commissioner to be misbranded, including a pesticide or device that:
- is an imitation of or is offered for sale under the name of another pesticide or device; or
- does not comply with the labeling requirements under this chapter or FIFRA.
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA Section 2(p)) defines pesticide “label” and “labeling” as:
- Label: The written, printed, or graphic matter on, or attached to, the pesticide or device or any of its containers or wrappers.
- Labeling: All labels and all other written, printed, or graphic matter accompanying the pesticide or device at any time, or to which reference is made on the label or in literature accompanying the pesticide or device, except to current official publications of the Environmental Protection Agency, the United States Departments of Agriculture and Interior, and the Department of Health and Human Services, State experiment stations, State agricultural colleges, and other similar Federal or State institutions or agencies authorized by law to conduct research in the field of pesticides.
Products found within the kit must bear the same name on all kit labeling as the individual product registration held with the state (Pesticide Registration Statute).
Example: if a kit named “Daily Disinfectant Necessities Kit” lists “Baxter’s Best Surface Disinfectant” as a pesticide product to be found within the kit, then the individual pesticide product must also be registered separately with the state with the same name “Baxter’s Best Surface Disinfectant”.
A different name would require an additional separate registration.
Additional Kit Labeling Recommendations
Complete labeling of each pesticide product with the kit should be visible on the exterior package label. Non-pesticide products listed as included in the kit do not require the full labeling to be visible on the exterior package but should state full product labeling can be found on the inside of the kit itself.
Product Label Revisions
If significant changes are made to product label content the registrant must submit a completed Pesticide Label Revision Checklist (listed under "Forms + Resources") along with a digital copy of the updated label and safety data sheet. Instructions are included within the form.
Addition of Hemp: For a company’s product to be recognized by the State of Minnesota for use on hemp, the product must be recognized by the EPA for use on Hemp and a revised label referencing the products use on hemp must be submitted to the State.
When submitting this new label please:
- Fill out a Pesticide Label Revision Checklist (listed under "Forms + Resources") making sure to note that a new crop use has been added.
- Email the checklist along with the updated label to Pesticide.Registration.mda@state.mn.us with the subject line: HEMP Revised Label.
- If the label will be/has been submitted via ALSTAR there is no need to re-attach the label, but please indicate this in the email.
Plans are reviewed in the order they are received. When your plan is up for review, you will be contacted by phone or email. The review of most plans is underway within about 30 days. An email will be sent when the plan review is complete.
Plans are reviewed in the order they are received. When your plan is up for review, you will be contacted by phone or email. The review of most plans is underway within about 30 days. An email will be sent when the plan review is complete.
When submitting your plan review application, be sure to include all necessary documents initially. Incomplete or missing documentation will delay the review process. Have a single point of contact for your project. If the plan reviewer has to discuss the plan with multiple people, it can also delay the review process. Being prepared to answer any questions the MDA has in a timely manner will also help the complete the review more quickly.
When submitting your plan review application, be sure to include all necessary documents initially. Incomplete or missing documentation will delay the review process. Have a single point of contact for your project. If the plan reviewer has to discuss the plan with multiple people, it can also delay the review process. Being prepared to answer any questions the MDA has in a timely manner will also help the complete the review more quickly.
