Section 5: What are the types of labels and labeling?

Supplemental Distributor Labeling

Supplemental distributor labeling includes labels for a product that is registered to one company, but distributed by another company (sometimes referred to as a sub-registrant) under that company's name. These labels must be the same as the labels for the registered product, with the following exceptions:

• Product name.
• Name and address.
• Registration number (EPA Reg. No. xxxx-xx-xxxx, where the third set of numbers refers to the distributor's company number).
• Establishment.

In addition, claims may be deleted, but new claims that differ from the parent label cannot be added to a distributor label.

The parent company must notify the EPA before distribution by submitting a Notice of Supplemental Distribution. EPA does not receive or review supplemental distributor labeling, but EPA can review the distributor company names to ensure that they are not misleading. The parent company is responsible for ensuring that the supplemental distributor is in compliance with these requirements.

Resources

For more details about supplemental distributor labeling, see Chapter 3, Section IV.C of the Label Review Manual.

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