In conjunction with the Consumer Specialty Product Association, EPA has published guidelines for manufacturers that voluntarily disclose information on their product labels and Websites regarding antimicrobial ingredients in pesticides. The guidance clarifies that if a product label contains a Website address, the Website becomes part of the product’s labeling and is, therefore, subject to FIFRA’s misbranding provisions. It also clarifies that under FIFRA, claims on a label cannot be substantially different from claims on a Website.  

The guidance encourages pesticide registrants to (i) disclose all intentionally added ingredients, (ii) link products or Websites to EPA registration numbers, (iii) use bilingual and widely recognized chemical-naming schemes, (iv) include PDFs of material safety data sheets for ingredients subject to OSHA regulations, (v) identify ingredients in their alternative formulations, and (vi) maintain Websites for at least two years after a product is no longer sold.