Retailers may soon be receiving new labels from BASF, Monsanto and Dow-DuPont along with guidance on relabeling the 2017 inventory you may have of these products.  On October 13, 2017, USEPA reclassified these products to Restricted Use Pesticides and there are many other changes in the product labels.  These products cannot be sold until they are affixed with the new labels.

 

IMPORTANT:  If you receive the new labels, DO NOT relabel any of your inventory unless you first ensure that your facility is USEPA Registered Pesticide Producing Establishment.  Relabeling can only be performed at a USEPA Pesticide Producing Establishment and you must report the amount you relabel on your annual Pesticide Production Report (PPR) which is due to USEPA on March 1 of every year.  If your relabel product before Dec 31, 2017 you have to report the amount relabeled on your 2017 PPR (which is due March 1, 2018) and if you relabel after January 1, 2018 you must report the amount relabeled on your 2018 report (which is due March 1, 2019).    

 

If your facility is not a USEPA Pesticide Producing Establishment, DO NOT relabel these products.  Contact your distributor or call the phone number on the relabeling instructions you received from the manufacturer, and ask the manufacturer or distributor to make arrangements to perform the relabeling of your products at a registered establishment. 

 

IFCA advises that you DO NOT contact USEPA and request an establisment number just to relabel these products.  Choosing to become a USEPA Pesticide Producing Establishment carries with it additional regulatory compliance responsibilities, and you must file an annual PPR report even if you do not regularly perform repackaging or relabeing activities.  Becoming a USEPA establishment also subjects your facility to additional USEPA directed inspections of your facility; any errors in paperwork, reporting or compliance with the regulations for USEPA Pesticide Producing Establishments carry minimum fines of $5,000 per violation.  

 

If you have bulk inventory of these products, you are most likely already a USEPA Pesticide Producing Establishment. 

If you have any questions about relabeing these dicamba products please contact IFCA at (309) 827.2774.