EPA is now allowing companies to include a QR code or website link on their product labels to provide information on inert ingredients. As of this publication date, this option is only available for antimicrobial pesticide products. Providing this additional information is strictly voluntary for companies, with exception on a case-by-case basis for where it has been required. Although voluntary, providing this information is encouraged for showing transparency.
EPA states that if a company chooses to disclose their inert ingredients, they should include all of them. Any partial lists could mislead the consumer into believing it was a complete list. The Agency also recommends listing ingredients in descending order of weight.
Pesticide producers should note that including a QR code or website link results in the information being subject to FIFRA and EPA review in order to ensure there is no violation of FIFRA’s provisions against misbranding (FIFRA sections 2(q) and 12(a)(1)(E)). The companies including this information need to verify the its accuracy. Companies must also submit an application to EPA for voluntary inert ingredient disclosure. The application identifies the proposed changes on the product label detailing the QR code or website link, and includes a self-certification statement. The self-certification statement includes acknowledgement that any false statements could lead to enforcement actions. EPA’s announcement also mentions that once the Agency gains experience handling this type of labeling, they may allow inert ingredient disclosure applications to be included with other actions.