Bilingual Labeling Questions & Answers

The following are frequently asked questions and corresponding answers about the bilingual labeling requirements in PRIA 5. This is a living document and will be updated as questions arise during the implementation of PRIA 5.

This Q&A is intended to be a compliance aid and does not take the place of reading the regulations.

On this page:

• Translations/Spanish Translation Guide for Pesticide Labeling
• Timing
• End-use products versus other products
• Accessibility and format
• Non-notification
• QR codes
• Pointer statements
• Supplemental distributors
• First aid statements
• Agricultural versus non-agricultural products
• Antimicrobials and Safety Data Sheets (SDSs)
• Co-regulators and stakeholder engagement
• Enforcement and tracking

Translations/Spanish Translation Guide for Pesticide Labeling

Do the requirements for bilingual labeling apply to the entire label, or just certain sections? 

Registrants may translate an entire label, however, only the sections of the pesticide product labels in the Agency’s Spanish Translation Guide for Pesticide Labeling (or Spanish Translation Guide) must be translated for each registered pesticide product released for shipment. Three of the sections below are new additions in the 2024 release of the Spanish Translation Guide:

• “Keep out of reach of children” statement (KOOROC) statement)
• Restricted Use Pesticide (RUP)
• Misuse statements
• Signal word
• First Aid statements
• Precautionary statements
• Personal Protective Equipment (PPE) requirements
• Engineering Controls (NEW in 2024)
• Environmental Hazards (NEW in 2024)
• Physical or Chemical Hazards language (NEW in 2024)
• Storage and disposal instructions and container handling statements

Do registrants have to use the language as provided in the Spanish Translation Guide for Pesticide Labeling? For labels already translated into Spanish, do translations need to be updated to correspond with the Spanish Translation Guide?

EPA encourages use of the language in the Spanish Translation Guide to assist with the requirement for Spanish labeling to be “true and accurate.” However, use of the specific language from the Spanish Translation Guide is not required. The registrant must ensure that “true and accurate” Spanish translations are included for each section of the label that is included in the Agency’s Spanish Translation Guide. Labels that have been translated to Spanish prior to the passage of PRIA 5 do not need to be updated or retranslated, provided that they meet the PRIA 5 bilingual labeling requirements. As the Spanish Translation Guide is updated in the future, the registrant is responsible for ensuring labels incorporate translations for all sections in the updated guide.

If an RUP statement is based on environmental hazards (such as toxicity to aquatic organisms) and not on acute toxicity to humans, does that portion of the RUP statement need to be translated into Spanish as well?

Yes, the December 2024 version of the Spanish Translation Guide includes translations of the RUP statement for environmental hazards. Therefore, that section of the label must be translated into Spanish as well. Restricted Use Classification statements (40 CFR 156.10(j)(2)) must be translated into Spanish regardless of the reason for classification. 

If labels are being updated through non-notification, who is responsible for ensuring the accuracy in the translation/labeling?

The registrant is responsible for ensuring that the translation is true and accurate. However, in the context of supplemental distribution, the distributor is considered an agent of the registrant for all intents and purposes under FIFRA, and both the registrant and the distributor may be held liable for violations pertaining to the distributor product.

Do the PRIA 5 bilingual labeling requirements replace the Spanish labeling requirements for foggers?

No, fogger Spanish labeling requirements are mostly for the “Directions for Use” section of the label. Spanish translation requirements under PRIA 5 do not supersede any underlying Spanish labeling requirements deemed necessary to protect the public (40 CFR 156.10(a)(3)), such as those that have been approved for foggers.

Timing

When are Spanish translations required to be updated on product labels?

PRIA 5 provides a timetable for when labels will be required to be updated with the Spanish translations (or a link to the translation via scannable technology or other electronic methods readily accessible on the product label). See table below for specific requirements.

As EPA updates the Spanish Translation Guide with additional translations over time, would this automatically change the label language requirements, or would there be a timetable for phasing these in? How will EPA communicate changes/updates to the Spanish Translation Guide?

As the Spanish Translation Guide is updated in the future, the registrant is responsible for ensuring labels incorporate translations for all required sections in the updated guide according to the timing outlined in PRIA 5.

PRIA 5 provides a timetable outlining when labels will be required to be updated depending on the type of product (agricultural versus non-agricultural).

For agricultural use pesticide labels, companies must update their product label with the new information within one year after the date of publication of the updated Spanish Translation Guide for Pesticide Labeling or the latest EPA approved label (whichever is earlier).

For antimicrobial and non-agricultural use pesticide labels, companies must update their product label with the new information within two years after the date of publication of the updated Spanish Translation Guide for Pesticide Labeling or the latest EPA approved label (whichever is earlier).

PRIA 5 requires the Agency to notify registrants within 10 days of updating the Spanish Translation Guide for Pesticide Labeling. Notification will be given through a Federal Register Notice and an OPP Update within 10 days of the publication date.

What do the PRIA 5 bilingual labeling deadline dates refer to (i.e., date released for shipment, date submitted to states, date that product is out in channels of trade)?

The PRIA 5 deadline for bilingual labeling refers to when a registered product or supplemental distributor product, is released for shipment. A product becomes released for shipment when the producer has packaged and labeled it in the manner in which it will be distributed or sold or has stored it in an area where finished products are ordinarily held for shipment (40 CFR 152.3). 

If registrants already submitted Spanish bilingual labeling to their state for the state registration review process, will they have to update their labeling when the Spanish Translation Guide is updated? What is the deadline for registrants to comply with the new updates on the Spanish Translation Guide?

With every updated version of the Spanish Translation Guide that is published, registrants will have one year from that date for agricultural pesticide products, and two years from that date for non-agricultural pesticide products to add Spanish translations for the new required sections of their pesticide labels; in accordance with PRIA 5 (FIFRA section 3(f)(5)(C)(iv), 7 U.S.C. § 136a(f)(5)(C)(iv)). The December 2024 version of the Spanish Translation Guide does not affect or change the implementation deadlines provided in PRIA 5.

End-Use Products v. Other Products

Does the Spanish translation need to appear on the end use product label? What about technical product labels (manufacturing use products)?

The Spanish language translation must appear on the product container or a link to such translation via scannable technology or other electronic methods readily accessible on the product label.

The bilingual labeling requirements of PRIA 5 applies specifically to end-use product labels and does not impose bilingual labeling requirements on technical labels (manufacturing use products).

For end use product labels, the registrant has the option of either including the Spanish language translation on the product container or a link to such translation via scannable technology or other electronic methods readily accessible on the product label.

There are exceptions for antimicrobial pesticide products and non-agricultural/non-RUP pesticide products. For these categories, compliance can be achieved through labeling that includes a link to the safety data sheets (SDS) in Spanish via scannable technology or other electronic methods readily accessible on the product label in lieu of including a translation or a link to the label translation.

Are FIFRA 25(b) products subject to the PRIA 5 bilingual labeling requirements?

Minimum risk pesticides (40 CFR 152.25(f)) are exempt from registration requirements of FIFRA (apart from meeting the conditions for the exemption itself). Therefore, they are not under obligation to meet the PRIA 5 bilingual labeling requirements in FIFRA.

Are devices subject to the PRIA 5 bilingual labeling requirements?

Devices (40 CFR 152.500) are not required to be registered under FIFRA Section 3. Therefore, they are not under obligation to meet the PRIA 5 bilingual labeling requirements in FIFRA.

Accessibility and Format

Since internet access may be a problem for some pesticide users, can the translated text be placed on the label?

Yes, the Spanish translation can be included on the label if the registrant chooses to do so. Physical labels would be helpful to facilitate the availability of Spanish labeling in areas that do not have access to the internet or cell phone service.

What is the acceptable web site configuration and the requirements for posting Spanish label translations electronically?

There are no requirements for the configuration, format, or layout of the website where the Spanish translation is available, so long as the Spanish translation is readily accessible electronically through scannable technology or other electronic methods.

What format is acceptable for providing multiple languages on a label? For instance, can labels do the following:

• Display all sections of the label first in English and then all the required sections in Spanish afterwards or in a separate section? 
• List bilingual text section by section where needed (i.e., all Precautionary Statements provided in English, then Spanish, then all Environmental Hazards in English, then Spanish)? 
• List bilingual text side-by-side (English on left and Spanish on right)? 

There is no prescribed format in PRIA 5. The registrant should select one of the above options and be consistent within a label with the approach that is selected. 

Could the Spanish translation be given in an audio and/or visual (such as a video with subtitles) formats in addition to the written translation?

Although not specified under PRIA 5, registrants may link to an audio and/or visual translation (as long as the translation is deemed true and accurate) in addition to, but not as a replacement for, the written translation (pursuant to 7 USC 136(p)). The use of audio and/or visual translations is optional. 

Non-Notification

Label changes will be done through non-notification. What does this mean? 

Non-notification means that changes may be made to a pesticide label without notifying EPA. Label submissions requesting approval of Spanish labels or including placeholder notes to the reviewer referring to the allowance for future Spanish translation will not be reviewed or acknowledged as notifications or amendments by EPA.

Is a full label translation still done through non-notification? Would a full label translation require a PRIA action and label review by EPA?

Registrants can choose to translate the full label, though only the sections of the label included in the Spanish Translation Guide are required to be translated by PRIA 5. Label changes involving only the incorporation of translations, irrespective of scope, can be made without notifying EPA.

When new language is added to labels in English that coincides with the sections that need to be translated, should these changes be added to the Spanish translations via non-notification?

Yes, if a registrant updates or revises their English label text, they should add the corresponding Spanish translations to their label via non-notification after the English text is approved. 

According to PRIA 5, the Spanish translation can be available via scannable technology or other electronic methods readily accessible on the product label. On pesticide labels, can registrants add a QR code or website link to the Spanish translation via non-notification?

Yes, the QR code or website link with Spanish translations can be added to the label via non-notification. Any other QR code information must be submitted to the Agency for review.

Can a registrant submit a label with Spanish language text to be reviewed?

No, PRIA 5 specifies that bilingual labeling be implemented via non-notification and, as such, EPA does not intend to review Spanish translations. 

How will EPA handle subsequent label changes after Spanish was added to labels through non-notification?

Updates to existing Spanish label language can be done via non-notification. EPA will not review the bilingual labeling text as part of the routine registration process. 

Once a QR code is added to the label via non-notification, is there any issue with the QR code being on the subsequent master label submission?

It depends. If the QR code is solely for bilingual labeling, a placeholder for the QR code (not the QR code itself) may be included on subsequent master label submissions. If the QR code is multi-purpose (for example, it also contains product information and Bulletins Live information), registrants are responsible for following the established regulatory pathways (e.g., notifications and/or amendments) for non-bilingual labeling FIFRA actions. EPA will not review bilingual labeling as part of the routine registration process. 

QR Codes

Does the QR Code need to be linked to the registrant’s website, or can the website be maintained by a third party?

There is no requirement under PRIA 5 for where the QR code links to as long as the Spanish translation is readily accessible; therefore, the Spanish translation can be linked to the registrant’s website or a website maintained by a third party. However, the registrant and distributor engaged in supplemental distribution of the pesticide product are responsible for ensuring the translation is true and accurate regardless of whether the website containing the translation is maintained by a third party.

Can one QR code or website address be created for one company where the user can search across multiple products, or does it need to be one unique QR code or website per product?

Yes, a web address can be created where the user can search across multiple products. PRIA 5 does not specifically address whether one QR code or website address can contain multiple product translations. The statute requires that a link to a translation via scannable technology or other electronic methods be readily accessible. 

If the QR code is placed on the master label, does a specific webpage need to be listed, or can a placeholder be included on the label to submit the label to EPA for review?

EPA will not review the bilingual sections of labels or bilingual labeling accessible via scannable technology or other electronic methods as part of the routine registration process. However, please be aware that in circumstances where end-users are directed to a website, the web content becomes labeling under the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) and must comply with applicable labeling requirements. As discussed under Supplemental Distributors, placeholders with different options to access the translation can also be added to the master label to provide flexibility to supplemental distributors. 

Are QR codes and webpage links on the product label considered labeling?

Yes, everything on the product label and the linked webpages are considered labeling, as defined under FIFRA § 136(p)(2). 

A label may already have an existing QR code or website address that is used for a reason other than bilingual labeling. Can the required Spanish translation be posted as a prominent link on that existing website versus adding an additional QR code or website address to the label?

Yes, registrants may use a number of methods to ensure that translations are readily accessible. For example, one option is a separate QR code for the Spanish labeling. Another option is to use an existing website or QR code. If a registrant chooses to use an existing website or QR code for all labeling – including Spanish labeling – the required Spanish translations should appear on the first page of the linked website, be clearly labeled, identifiable as the Spanish labeling required under PRIA 5 and separated from all other website labeling, to ensure that it is “readily accessible.” A third option is a QR code that pulls up a “menu” of hyperlinked text, including hyperlinked text linking to Spanish labeling. If using this option, the hyperlinked text linking to the Spanish labeling should be written in Spanish (for example, “Etiquetas en español”) and should appear toward the top of the list, so that people with limited English proficiency can easily locate the translations without having to navigate English text. (Note: These options are meant to serve as examples and do not represent an exhaustive list of acceptable ways to comply with the PRIA 5 requirements.) 

Note that, a QR code (or other electronic method) containing the Spanish translation is to be added via non-notification. However, if there are changes or updates associated with the QR code other than to the bilingual labeling portion, registrants are responsible for following the established regulatory pathways (e.g., notifications and/or amendments) for those changes or updates. EPA's Office of Pesticide Programs will not review sections of the website that include bilingual labeling as part of the routine registration process. 

Is there a requirement for the size of the QR code on the label?

There is no requirement for the size of the QR code; however, it should be legible and accessible. The pointer statement (the posted text explaining the purpose of the QR code) has a minimum size requirement of at least 6-point type (40 CFR 156.60). 

If the registrant is choosing to use QR codes for products that have multiple components, such as a bottle, a booklet or leaflet, and an outer packaging (not a shipping container), is the QR code required to be stickered onto all components?

QR codes can be added by sticker. However, the stickering needs to be done in an EPA producing establishment. 

The sticker must be securely attached, which means that it can reasonably be expected to remain affixed during the foreseeable conditions and period of use (40 CFR 156.10(a)(4)). 

The sticker must be placed on the product label. Registrants have the option to include the sticker on additional components but it is not required. 

Pointer Statements

Pesticide users are unlikely to know to utilize a QR code for Spanish labeling without label language explaining what the QR code will show. Can brief explanatory and pointer statements regarding the QR code also be added to the label by non-notification?

Yes. Adjacent to the QR code, text (pointer language) can be added via non-notification that explains the purpose of the QR code as long as the text is only for the Spanish translation. For example: “Scan QR Code for Spanish Label” translated to “Escanee el código QR para la etiqueta en español” or other similar phrases explaining the purpose of the QR code. 

Can pointer language be used to assist the reader in finding Spanish text on a label?

Pointer language can be added by non-notification at the discretion of the registrant to direct the user to Spanish translations on a different part of the pesticide product label. For QR codes with Spanish translations, pointer language should be adjacent to the QR code. 

Must the pointer statement specific to bilingual labeling be near the QR code to be a non-notification?

Pointer statement refers to text or pointer language that explains the purpose of the QR code. Although PRIA 5 does not specifically address where the location of the pointer statement should be in relation to the QR code, the Agency prefers for the pointer statement to be adjacent to the QR code, to facilitate access and understanding. 

Supplemental Distributors

Can supplemental distributors include bilingual label language and other label elements necessary to comply with PRIA 5 via non-notification (QR codes, etc.) even if it varies from the master label? (#26)

No, there have been no changes to supplemental distributor labeling regulations (40 CFR 152.132). Registrants and supplemental distributors should work together to ensure compliance with PRIA 5 and the regulation.

Can the registrant of the master label and the sub-registrants of supplemental distributor labels use different methods for placing their Spanish translations on the final printed label? For example, if the supplemental distributor uses a QR code on the final printed label, can the primary registrant place the translation directly on their final printed label?

Supplemental distributor labels may only vary from the master label in the five specific ways listed at 40 CFR 152.132. However, primary registrants who want to give supplemental distributors flexibility could include placeholders for multiple optional methods of compliance on their master labels, such as a QR code, Spanish text and links. Supplemental distributors could then choose from these options on the master label based upon what works best for their product. In that case, the registrant’s final printed label and the supplemental distributor’s final printed label might provide the translation by different methods, but both would be consistent with the options offered on the master label. 

 Note that the translated text itself must remain the same. 

 Registrants and supplemental distributors should work together to ensure compliance with PRIA 5 and the regulations. 

First Aid Statements

On all Toxicity Category 1 (DANGER) products (agricultural, non-agricultural, and antimicrobial), where do the Spanish First Aid label statements need to appear on the product container in relation to the English version of the First Aid label statements?

All translated portions of the label may appear either through text on the product container or a link to such translation via scannable technology or other electronic methods readily accessible on the product labeling. While not a requirement, registrants may include the Spanish first aid label statements for Tox Category I products on the front panel. Antimicrobial pesticide products and non-agricultural products that aren’t RUPs may also comply via a translated SDS. 

Agricultural Use v. Non-Agricultural Use Products

If a non-RUP pesticide product has both agricultural and non-agricultural uses, should this product follow the timeline for Spanish translation as an agricultural product?

Yes, if more than one pesticide product type for bilingual labeling could apply to a specific product, the earliest deadline would apply to the product.

When referring to the PRIA 5 deadlines for bilingual labeling, what is an agricultural product? What is the difference between non-agricultural products versus ‘all other pesticide products’? Are animal products, considered to be non-agricultural or an ‘all other pesticide products’?

An “agricultural product,” for the purpose of PRIA 5 bilingual labeling requirements, is a product that includes an “Agricultural Use Requirements” statement. Pesticide products may be labeled with an “Agricultural Use Requirements” statement and/or a “Non-Agricultural Use Requirements” statement in the “Directions for Use” section of the label. Whenever a pesticide product bears "Agricultural Use Requirements" statements on a label, it requires compliance with the Agricultural Worker Protection Standard (40 CFR 170). Even if the product label in question has both an “Agricultural Use Requirements” statement and a “non-Agricultural Use Requirements” statement, it is still considered an agricultural product if the label includes an "Agricultural Use Requirements” statement. 

 “All other pesticide products” (for purposes of PRIA 5 deadlines for Bilingual Labeling categorization) are agricultural, antimicrobial, and non-agricultural pesticide products, classified as acute Toxicity Categories III and IV. 

 Animal products are either products used on domestic animals (pets) or livestock. Because the definition of “agricultural use product” generally aligns with the Worker Protection Standard, animal products, regardless of species or use, are not agricultural products. Animal products are considered “non-agricultural” products under PRIA 5; their PRIA 5 deadlines for bilingual labeling are dependent on their Toxicity Category, found in 7 U.S.C. § 136a(f)(5)(B)(ii)(II). 

Antimicrobials and Safety Data Sheets (SDSs)

Which pesticide products may provide SDSs in Spanish? Do specific SDS statements need to be included on the EPA master label?

Antimicrobial pesticide products and non-agricultural pesticide products that are not classified as restricted use may, in lieu of including a translation, provide a link to the SDS in Spanish (PRIA Section 702.5 (B.ii) (I &II)). SDSs are viewed as labeling pursuant to PR Notice 92-4 (pursuant to 7 USC 136(p))). 

No, PRIA 5 does not require that specific SDS statements appear on the master label. Rather, PRIA 5 requires that implementation be via non-notification with a link to a Spanish translation via scannable technology or other electronic methods “readily accessible” on the end use product label. 

Can antifoulant paints comply with PRIA 5 requirements via translated SDSs? (#49)

Yes, antifoulant paints that are not RUPs may, in lieu of including a translation or a link to the translation, provide a link to the SDS in Spanish via scannable technology or other electronic methods readily accessible on the product label. 

Does the registrant need a dedicated link for each product that goes directly to that specific product’s safety data sheet (SDS), or can the link be to an SDS landing page that contains all the registrant’s SDSs?

The link can be to a landing page. PRIA 5 does not specifically address whether one QR code or website address can contain multiple product translations. However, the statute does require that the link to the translation (whether via scannable technology or other electronic methods) be “readily accessible.” 

Co-Regulators and Stakeholder Engagement

Could states expedite reviews of bilingual label revisions if a registrant provides an affidavit that certifies the sole modification made to the label was the translation of the existing label text into Spanish?

It is up to the individual state if will accept an affidavit or self-certification.

How will the implementation of bilingual labeling requirements in PRIA 5 be a collaborative process?

EPA has conducted various meetings, webinars and focus groups with a variety of stakeholders. The Agency is planning to continue to work with states, industry and the public on developing implementation plans for the various bilingual labeling requirements of PRIA 5. These implementation plans include a process to help make pesticide product labels accessible to farmworkers and other pesticide users and tracking labels translated into Spanish.

Will bilingual language be required on the state pesticide applicator certification plans? Will states be required to have applicator certification training material in Spanish and Spanish speaking trainers?

There’s no requirement for states to have Spanish versions (bilingual language) in their pesticide applicator certification plans and states are not required to provide training material in Spanish.

States can choose to develop materials and deliver in other languages, as long as the requirements of the applicable regulation (Certification of Pesticide Applicators [40 CFR §171]) are met in full.

Enforcement and Tracking

What happens if a final printed label does not have the Spanish translation?

The registrant must ensure that the labels include Spanish translations of the required elements, or a link to such translation via scannable technology or other electronic methods, and that they are readily accessible. If the final printed label does not include the translations by the relevant deadline, the product may be considered misbranded pursuant to section 2(q) of FIFRA.

What do state lead agencies (SLAs) do if they find issues with the translation and scannable codes, or lack thereof? Does EPA have a plan to address issues with translations and codes when states bring problematic labels to EPA’s attention?

EPA encourages SLAs to share concerns through existing communication channels (regional contact, project officer, or technical contact).

Yes, in cases involving widespread circumstances, EPA will engage the broader SLA community through established forums.

How will misuse be handled when misuse could have been the result of not having Spanish translations on end use labels or possibly due to those translations being inaccurate?

Misuse will be handled using the existing mechanisms. Use related enforcement in states and territories is governed by the primacy framework established under sections 26 and 27 of FIFRA (7 USC 136w-1 and 2). Tribes are not eligible for primacy. In Indian Country, tribes can enforce applicable tribal code. However, EPA enforces FIFRA. 

How will compliance with the bilingual labeling provisions of PRIA 5 be monitored, and if the provisions are not followed, how will they be enforced?

EPA and State Lead Agencies will continue to follow their existing compliance monitoring and enforcement processes. The Agency released a draft plan to track the adoption of bilingual labeling. EPA will finalize the tracking plan after considering public comments.