AAPCO’s 25(b) Workgroup issues more prescriptive label guidance

March 19, 2021

The Association of American Pesticide Control Officials (AAPCO) 25(b) Workgroup released updated label guidance for FIFRA minimum risk pesticide products, otherwise known as 25(b)s. The new guidance includes label requirements not prescribed in the original guidance released over 5 years ago. While this document is guidance and utilizes descriptors like “should” instead of “must”, ultimately states have the authority to refuse to register if the guidance is not followed.

Industry is appreciative of the states willingness to work together to provide us with guidance that is acceptable to most states rather than each state having their own, individual requirements. However, as requirements for standardized label placement, format and text increase, the ability to set individual products apart at shelf decreases, hampering marketing efforts. By way of example, active ingredients must now be listed in descending order of predominance, even though the individual percentages for the active ingredients must also be listed.

Another new element is the requirement for a state registration number to be listed on the label with the caveat “if necessary”. However, the guidance does not address what a registrant is to do if more than one state decides this element is necessary. Will this lead to state specific labels that registrants must figure out how to manage and control?

The above represent only two of the changes to the guidance. As registrants work on brand refreshes and new product rollouts, it is of the utmost importance to gain a full understanding of all of the changes to the 25(b) label guidance document.

For the full guidance click here.

How TSG can help

TSG has significant experience with minimum risk pesticides and can guide you through the current regulatory processes at the state level.

We have helped many clients secure 25(b) registrations. We are in contact with state regulators on a daily basis and we understand the intricacies of not only pesticide regulation but also the state regulation of fertilizers, amending material, animal feed and pet food.

As a regulatory partner, we can offer you the peace of mind that comes with knowing that we are constantly monitoring for changes to the state regulatory landscape that could affect your business.

Need some assistance with your 25(b) product? Contact us at info@tsgconsulting.com


Contact us