Pesticide Containers

• Pesticide container regulations
• Applicability of container requirements
• Refillable containers and repackaging
• Nonrefillable containers
• Container handling instructions on pesticide labels
• Recycling pesticide containers
• Interim pesticide container repair policy
• Additional resources

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Pesticide Container Regulations

The pesticide container regulations establish standards for pesticide containers and repackaging as well as label instructions to ensure the safe use, reuse, disposal and adequate cleaning of the containers. Pesticide registrants and refillers (who are often distributors or retailers) must comply with the regulations, and pesticide users must follow the label instructions for cleaning and handling empty containers. 

Applicability of Container Requirements 

• Label requirements. All pesticides are potentially covered by the container-related label requirements. Certain types of pesticides or containers may be exempt from specific statements.
• Container and repackaging requirements. Certain pesticides are exempt from the container and repackaging requirements:
  • Manufacturing-use products.
  • Plant-incorporated protectants.
  • Certain antimicrobial pesticides.

All other pesticides are potentially covered by the container and repackaging requirements although certain types of pesticides or containers may be exempt from specific requirements.

• Summary. For a description of which pesticides are exempt and which must comply with some or all of these regulations, see Table 2: Products Subject to the Nonrefillable Container, Refillable Container and Repackaging Regulations. 
• Flow chart. Shows which pesticides are exempt and which must comply with some or all of these regulations.

Refillable Containers and Repackaging

Refillable containers are containers that are intended to be refilled and reused more than once to sell or distribute pesticides. Pesticide registrants and refillers must comply with the refillable container and repackaging regulations.

• Refillable Container Summary. For a description of the refillable container requirements, see Table 4: Refillable Container Requirements. 
• Repackaging Summary. For a description of the repackaging requirements see Table 5: Requirements for Repackaging Pesticide Products into Refillable Containers.  

• Flow Charts. These flow charts are based on the scenario that a refiller has a portable refillable container to be filled with a specific pesticide and is trying to determine how to comply with the refillable container and repackaging regulations. The scenario assumes that:

  • the facility complies with all of the repackaging regulations in 40 CFR 165.60 – 165.70 (such as having entered into a contract with the pesticide’s registrant and being a registered producing establishment); 
  • the pesticide is subject to the refillable container and repackaging regulations (e.g., it is not a manufacturing use product or an antimicrobial product that meets all of the exemption criteria); and
  • the container is subject to the refillable container and repackaging regulations because it is being used to sell or distribute the pesticide.
• Service container flow chart. Determine whether a container is a refillable container subject to the regulations or a service container, which is not subject to the requirements.
• Large container flow chart. Steps for a portable refillable container larger than 119 gallons to comply with the refillable container and repackaging requirements.
• Small container flow chart. Steps for a portable refillable container 119 gallons or smaller to comply with the refillable container and repackaging requirements.

Nonrefillable Containers

Pesticide registrants must comply with these regulations for pesticides that are sold or distributed in “one-way” or disposable containers.

• Nonrefillable Container Summary. For a description of the nonrefillable container requirements, See Table 3: Nonrefillable Container Requirements.
• Rinsing Test Procedures. EPA’s test procedure for rinsing containers for the residue removal standard in 40 CFR 165.25(f).

Container Handling Instructions on Pesticide Labels

The pesticide container regulations require pesticide labels to include statements identifying the container as nonrefillable or refillable and providing instructions on how to handle and clean it. Pesticide registrants must ensure that labels have the required information. Pesticide users must comply with the instructions on the label.  

• Label Summary. For a description of the requirements for container handling instructions on pesticide labels, see Table 6: Container Labeling.
• Chapter 13 of the Label Review Manual provides guidance on developing container handling instructions on pesticide labels in Section VI.

Recycling Pesticide Containers

Many pesticide containers can be recycled after they have been emptied and rinsed thoroughly.  For more information:

• Ag Container Recycling Council . ACRC recycles plastic containers that are 55 gallons or smaller. 
• The Pesticide Stewardship Alliance . TPSA compiled information about companies that recycle containers larger than 55 gallons.

Interim Pesticide Container Repair Policy

• Container Repair Interim Policy. This policy establishes a process for pesticide retailers and distributors to apply for EPA’s approval to repair minor damage to pesticide bags under certain conditions.
• As of December 2017, EPA has approved container repair policies for:
  • Walmart/Sam’s Club.
  • Home Depot.
  • John Deere Landscapes.
  • Lowe's.
• The Michigan Department of Environmental Quality Retail Environmental Workgroup has developed a Pesticide Container Repair Guide and Templatefor retailers wanting to seek approval for a minor repair program.

Additional Resources

• Chapter 13 of the Label Review Manual provides guidance on developing container handling instructions on pesticide labels in Section VI.
• Pesticide Environmental Stewardship Guidance on Pesticide Containers 
• Pesticide Disposal
• A Snapshot of the Pesticide Container and Containment Rule. A two-page brochure that summarizes the container and containment regulations. 
• FAQs. Common questions and clarifications
• Container and Containment Regulations. The full text of these regulations at 40 CFR Part 165.
• Container Handling Label Regulations. The full text of these regulations at 40 CFR Part 156 Subpart H.