What is the legal authority for the conditions set out in the bulk pesticide repackaging policy?
EPA has exercised its enforcement discretion to allow registrants to authorize dealers to repackage registrant’s pesticides, but only to the extent set forth in the policy. The bulk pesticide repackaging policy sets forth the conditions under which a dealer can repackage pesticides without a separate registration for the repackaged pesticide. Please note that the major condition is that the accountability for the product remains with the registrant for the product as well as the repackaging establishment and that the registrant must authorize such repackaging in writing. The legal authority for: 1) the registration requirements is section 3 of FIFRA; 2) the establishment registration and reporting requirements is section 7 of FIFRA; and 3) the recordkeeping requirements is section 8.
