Minnesota law states that “Each pesticide with a unique United States Environmental Protection Agency pesticide registration number or a unique brand name must be registered with the commissioner.” Accordingly, alternate brand name, distributor products are required to be registered.
Do alternate brand names or distributor labels require registration?
Minnesota law states that “Each pesticide with a unique United States Environmental Protection Agency pesticide registration number or a unique brand name must be registered with the commissioner.” Accordingly, alternate brand name, distributor products are required to be registered.
No, a basic producer’s product does not need to be registered before a supplemental distributor’s version of the same product can be registered.
Does a basic producer's product need to be registered before a supplemental distributor's version of the product can be registered?
No, a basic producer’s product does not need to be registered before a supplemental distributor’s version of the same product can be registered.
| Definition | Example | Is additional registration required? |
|
|---|---|---|---|
| Kits | A kit includes multiple products and can contain one or more FIFRA-regulated products, along with, in some cases, one or more non-FIFRA products. Each product in the kit is separately packaged and labeled – just as it would be if sold separately. The kit consists of an outer container, such as cardboard box, which houses the separately packaged FIFRA and non-FIFRA products placed inside the outer container |
Lice Kit
Pool Care Kit
|
Yes, if the product is sold/marketed under a new name (different from the name of each pesticide product inside), and/or each product label is not completely visible from the outside of the package. For specific registration guidance please see Section 3 Pesticide Registration |
| Co-packs | A co-pack is when two or more pesticide products
Each container must bear, or be accompanied by, full labeling, and the full labels of both containers must be visible. If the outermost packaging obscures any part of the labeling of the pesticides, the full labels must be duplicated and attached to the outermost container. |
Co-packs direct the user to mix the two products together before application. |
No, currently registered products that are simply packaged together without the addition of a new name, with each pesticide label completely visible from the outside of the package would not be required to hold a new/separate registration with the state. |
| Multipacks | A multipack is when two or more pesticide products with the same EPA Registration Number are packaged together. Each container must bear the full pesticide label. | This could include different scents and different names but the same EPA Registration Number. | No |
| Shrink Wrapped MPPT | When MPPT products are packaged together through shrink-wrapping so the full immediate container labeling for the pesticide is available to the consumer at the point of purchase | Multipacks can sometimes be sold as shrink-wrapped MPPT | No |
