Frequently Asked Questions
This page compiles our most frequently asked questions regarding Pesticide Products & Devices. If upon review, you still have questions, please reach out to our office.
According to IC 15-16-4-56, a pesticide product is considered the same if it has the same product name, registrant name, EPA Registration Number, labeling (which includes claims and branding), and ingredient statement. If any of these elements are different in the final, marketed product, additional state registrations are required.
Therefore, if a company name or product branding has changed on the labeling, new registrations are required. If a product is sold in five different containers, each with a different type of application equipment, they all require registration.
The following are some examples for when additional registration is required:
- The company name, product name or branding has changed.
- Labeling includes different directions for use.
- Products include different application equipment (i.e., different hoses/dispensers, hose attachments, spray bottle top vs refill).
- The product label identifies different users (commercial vs homeowner) or sites (ornamentals vs lawn).
- Packaged product is a kit or copack with different products (i.e., different scents, pesticides, and/or non-pesticides).
- Products are sold in different colors (i.e., air purifier sold in black, white and red).
- Products are sold for a specific size, location, or site (i.e., 1) small dog, medium dog, large dog; 2) small room, large room).
Below is a list of the most common scenarios where OISC will require label revisions or additional documentation prior to state registration. This list is not all inclusive.
If the label does not include all the directions for use elements under the appropriate header, it will require revisions prior to registration. Directions for Use (DFU) requirements are included in 40 CFR 1560.10(i). This provides detailed information about the placement of the DFU on the label and what is required under the DFU header (156.10.i.2).
Annual Product Renewals
The renewal process is very manual for our office. We manually compile renewals, identify any credits/debits on accounts, notate any international accounts, etc. If, upon review of your renewal, you have any questions, please reach out to our office at:
- We cannot take credit card payments.
- We do not have an online database for you to complete your renewal online.
- We cannot take any checks that are not drawn from American bank accounts (i.e., a Canadian account, cannot be deposited)
- The FULL completed renewal must be returned for processing. This means that the front page and all registration listing pages must be returned to our office with the renewal payment otherwise we cannot process the renewal. If pages are missing or the renewal is not signed, you may have to resubmit it again.
- Do not submit new product applications with your renewal – this can delay both the renewal and new registration.
- Do not send paper labels. Revisions to labels should be sent to our office prior to distribution into the state; please do not wait to send all labeling at renewal time.
- Late fees apply to any renewal received by our office after January 1st of the upcoming year. Please plan accordingly.
- Best practice/recommendations: Send the renewal back to OISC by December 15th and send the renewal certified or with tracking.
Additional Resources:
EPA Resources:
- Label Review Manual
- Pesticide Labeling Q&A
- Labeling Requirements
- 40 CFR
- Pesticide Registration Notices
- Pet Product Mitigation
- Pesticide Devices
- Pesticide Registration Manual
- Minimum Risk Pesticides
- FIFRA: Federal Insecticide, Fungicide and Rodenticide Act and Federal Facilities