EPA’s standards for pesticide containers and filling and refilling those containers are among the most unwieldy set of federal regulations under any statute. These regulations can be complex and lengthy. In this article, we’ve outlined some important points to help you better understand the regulations surrounding repackaging requirements.
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One common scenario in the complex organization of companies in the pesticide industry involves entities that are not registrants of pesticide products repackaging those products in refillable containers. While these refiller companies are not pesticide product registrants, they must obtain an EPA establishment number, which is obtained through a separate registration process. Entities without such registration that repackage pesticides in refillable containers, as well as properly registered entities that do not meet EPA’s relevant repackaging requirements at 40 CFR 165.70, are both subject to Agency enforcement. Read more.