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Pesticide Establishment Registration and Reporting Questions: Bulk Repackaging
For individuals required to register their establishment and file a report on pesticide production, EPA has prepared the following answers to commonly asked questions.
General Information
Definitions
Registration
Reporting
Bulk Repackaging
- My company receives pesticides in large containers and transfers the products to smaller containers with new labels. Do I need to register as a pesticide-producing establishment?
- If I use a railroad siding track where a railroad tank car or hopper car of registered bulk pesticide product is delivered for future transfer into a truck for transport, is the railroad siding considered a repackaging site that needs to be a registered pesticide-producing establishment?
Custom Blenders
Shipping Pesticides
Bulk Repackaging
1. My company receives pesticides in large containers and transfers the products to smaller containers with new labels. Do I need to register as a pesticide-producing establishment?
Yes. Any change to the label or container of a pesticide constitutes "production" and must be done in a registered establishment. In addition, repackaging of bulk pesticides into minibulk tanks or other reusable containers constitutes "production" and must be done in a registered establishment.
2. If I use a railroad siding track where a railroad tank car or hopper car of registered bulk pesticide product is delivered for future transfer into a truck for transport, is the railroad siding considered a repackaging site that needs to be a registered pesticide-producing establishment?
No, the site does not need to be registered but the complete label needs to be on the car or hopper. There are also requirements for any trucking company that transports the product to other locations.
A copy of the pesticide product’s label should be carried by the transporter along with the manifest and shipping records as required under the Hazardous Materials regulations.