How to Comply with the New Measures on Pesticide Labels and Instructions?

The Measures on the Management of Pesticide Labels and Instructions was officially implemented from 1 January 2018 (hereinafter abbreviated as the Measures). What information do enterprises need to know when preparing pesticide labels and instructions during the transitional period? Below, the detail information prepared by CIRS will give you a comprehensive understanding.

After the Measures officially took effect, can the manufactured products still be put on the market?

Yes. Pesticide products that were manufactured before 31 Dec. 2017 and are complying with the original label regulations can still be put on the market. However, these products must fulfill the following two conditions:

1. The products are manufactured within the validity of the pesticide registration certificate; and

2. The products were manufactured prior to 1 Jan. 2018 and are within their period of validity;

Besides, if the pesticides are prohibited/ restricted to use, then those products should be complied with the regulations of the prohibited/restricted (more info of the prohibited/ restricted pesticides). For instance, triazophos was not allowed to use on vegetables since 31 December 2016. That is to say, even if the products, manufactured prior to that date, are still within the expiration date, they shall not be labeled that they could be applied to vegetables since 31 December 2016. Labels and instructions of pesticides that manufactured after 1 January 2018 must be complied with the requirements of the Measures.

What are the requirements for the new labels of the products manufactured after 1 January 2018?

1. A pesticide label shall label the following contents:

(1) Pesticide name, formulation type, active ingredients and their content;

(2) Pesticide registration certi­ficate number, product quality standard number and pesticide manufacturing license number;

(3) Pesticide category, color bands, product performances, toxicity and mark; (4) scope of use, use methods, dosage, technical requirements and attentions on use;

(5) Fi­rst aid measures in case of pesticide poisoning;

(6) Storage and transport methods;

(7) Date of production, product batch number, shelf life, net weight;

(8) Name and contact information of the pesticide registration certi­ficate holder; (9) Traceable electronic information code;

(9) Traceable electronic information code;

(10) Drawings; and

(11) Other contents required by the Ministry of Agriculture

If a label is too small to contain all the speci­fied contents, it shall at least give a clear indication of the pesticide name, content of active ingredient(s), formulation type, pesticide registration certi­ficate number, net weight, date of production, shelf life, etc. and be attached with the instruction. The instruction should cover all content required above. If the use scope to be registered is too extensive to be listed on the label, a partial scope of use can be marked on the label as required, provided that the instruction attached is marked with the whole scope of use.

2. The following contents, mainly the information of the enterprises and proof of products, can be marked on the labels by enterprises themselves: pesticide quality standard number, pesticide manufacturing license number, date of production, batch number, net weight, contact information of the pesticide registration certificate holder, traceable electronic information code, drawings, etc. Enterprises must be responsible for the authenticity of the information they provided.

3. The following information must be approved by the Ministry of Agriculture: toxicity of products, matters for attention, technical requirements as well as other information related to safety and efficacy of pesticides. Holders of pesticide registration certificate must apply to the Ministry of Agriculture for re-approval if they need to change the approved contents.

4. Label contents required for various pesticides:

(1) A TC (TK) product shall be marked with “this product is a raw material used to process pesticide formulations and shall not be used on crops or in other places”, without information regarding use techniques and methods, except where direct use is allowed upon registration approval;

(2) Restricted pesticides shall be labeled with the words “Restricted for Use” and indicated with special restrictions and requirements;

(3) Pesticides for edible agricultural products shall be labeled with pre-harvest interval, except pesticides for non-food crops; pesticides for seed treatment, including seed dressing, coating and soaking; pesticides used in non-cultivated lands (excluding pasture); pesticides used as pre-emergence soil finishing agent; pesticides that will only be used for one time during the seedling stage; rodenticide products that are not fully broadcasted; household pesticides and other special situations.

(4) Rodenticide products shall be marked with the specifi­ed rodenticide drawing;

(5) Household pesticides for direct use may not contain distinctive color strips;

(6)   The labels for OEM/ toll manufacture pesticides or repacking pesticides shall also contain the pesticide manufacturing license number of the consignee, the consignee’s name and contact information, and the processing and  repacking dates;

(7)   Label of pesticides exported to China may not be marked with the pesticide manufacturing license number but shall be marked with its overseas production place, as well as the name and contact information of the offices or agencies established in China.

5. Unregistered trademark shall not be used in pesticide labels and instructions. If the registered trademark is used on the label, it shall be marked on the four corners of the label.

6. Each minimum pesticide package shall be printed or pasted with an independent label and shall not share one label with other pesticides. All minimum package labels must comply with the requirements of the Measures.

How to prepare and label the traceable electronic information code?

In accordance with the requirements of Article 24 of the Measures, the traceable electronic information code shall be represented by a QR code or other forms allowing the scanning and identi­fication of such information as the pesticide name and the name of the pesticide registration certi­ficate holder. The information code shall not contain any words, symbols and drawings inconsistent with the Measures. In accordance with the ‘Measures for the Administration of 2D Code on Pesticide Label’, the 2D code on pesticide label shall be either a QR code or a DM code. The 2D code is composed of a traceable website, a unit identification code and others. The unit identification code consists of 32-bit Arabic numbers. Pesticide enterprises can apply for the products traceable code (traceable website+ unit identification code) through the national pesticide quality traceable system and print the 2D codes based on the downloaded document.

Since 1 January 2018, pesticides imported into China or manufactured by Chinese producers must label a compliant 2D code. The 2D code can be marked in any place of the label without approval from the Ministry of Agriculture. Enterprises must make sure that the 2D code can be recognized when being scanned and can be used smoothly in every link of the production and distribution. It is worth noting that one 2D code shall correspond to one specific sales packing unit. Besides, pesticide enterprises should ensure the security of the traceable information and 2D codes, and prevent their 2D codes from losing or being used by illegal businesses.

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