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.

1. Do the requirements for bilingual labeling apply to the entire label, or just certain sections?
   • Registrants may translate an entire label, however, only the health and safety sections of the pesticide product labels are required to be translated. Specifically, PRIA 5 specifies that the following sections of the label included 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:
     • Keep out of reach of children (KOROC statement)
     • Restricted use pesticide (RUP)
     • Signal word
     • First aid statements
     • Precautionary statements
     • Personal protective equipment (PPE) requirements
     • Misuse statement
     • Storage and disposal instructions

2. 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. If 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.

3. 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).

PRIA 5 Bilingual Labeling Requirements

Pesticide Product Type	Bilingual Labeling Due
Restricted Use Pesticides (RUPs)	December 29, 2025
Agricultural Products (Non-RUPs)
Acute Toxicity Category I	December 29, 2025
Acute Toxicity Category II	December 29, 2027
Antimicrobial and Non-Agricultural Products:
Acute Toxicity Category I	December 29, 2026
Acute Toxicity Category II	December 29, 2028
All Other Pesticide Products	December 29, 2030

4. 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?
   • If 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.

5. 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.

6. 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.

7. Are devices subject to the PRIA 5 bilingual labeling ?
   • 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.

8. 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.

9. 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.

10. 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 health and safety portions of the label 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.

11. 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.

12. 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.

13. How will the implementation of bilingual labeling requirements in PRIA 5 be a collaborative process?
    • The Agency 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.

14. Why are only the health and safety portions of the label included for translation?
    • PRIA 5 requires the translation of the parts of the labeling included in the Spanish Translation Guide for Pesticide Labeling. The Spanish Translation Guide contains the health and safety portions of pesticide labels. The Spanish translations ensure that workers have access to important information to protect themselves from pesticide exposure, and to get appropriate help if exposed to a pesticide product. The remaining sections on the pesticide label can be translated if chosen to do so.

15. 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.

16. 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.

17. 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.

18. 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 can be added to the label via non-notification if it includes only the Spanish translation. Any other QR code information must be submitted to the Agency for review.

19. 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.

20. 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?
    • Although PRIA 5 does not specifically address whether one QR code or website address can contain multiple product translations, the statute requires a link to a translation via scannable technology or other electronic methods be “readily accessible”. The Agency’s preferred approach is for there to be one unique QR code or website linked to the Spanish translation per product.

21. 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. Near the QR code, text (pointer language) can be provided 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. Such pointer language can be added to the label via non-notification, as long as the QR code is only for the Spanish translation.