Ag Volume 5
Printable version 
Ag Labelling Code
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Ag Volume 5
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Printable version |
Ag Labelling Code
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Ag Labelling Code |
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Chaper 1: INFORMATION REQUIRED AND LABEL LAYOUT1.1 IntroductionThis publication provides guidelines for preparing labels for agricultural chemical products. Assessing and approving labels is a key aspect of the registration of agricultural chemical products by the APVMA. All of the key information required on labels is outlined in this Code of Practice. The Code does not, however, attempt to include all the situations and all the specific words that may be included on labels. While the main subject areas are indicated, and some prescribed or required wording is specified, in most cases only examples of suitable wording are listed. The statements may not be required or be appropriate for all circumstances. Registrants must submit copies of draft labels to the APVMA for approval before printing. 1.2 What is a label?A label is defined as the written, printed and related graphic matter on, or attached to, the container in which the product is directly packed and the outside container or wrapper of the retail package, if there be any. A label includes a tag leaflet, sticker, brand, stamp, mark, stencil or written statement. The label may often be the only source of information, instruction and advice to the user of a product. If the label is read, understood and its directions followed, the likelihood of agricultural chemicals causing an adverse effect is remote. It is therefore important that, when preparing a label, the designer consider:
In cases where the size of a container precludes placement of all the necessary information on a single panel, the label can be divided into two parts (for example, a label plus a fold-out leaflet or booklet, or a labelled bottle placed inside a box which is also labelled). The ‘label’, in these cases, refers to a combination of the two parts. The label for the product is not complete until each of the two parts is complete. 1.3 Registration requirementsThe assessment and approval of labels is a key aspect of the registration of agricultural chemical products by the APVMA. Legislation that applies to the assessment and approval of labels for agricultural chemical products includes:
1.4 Products covered by the Agvet CodesThis publication covers the labelling requirements for agricultural chemical products as defined in the Agvet Codes (see Glossary at Appendix 13). The Regulations may declare a class of substances or mixture of substances to not be an agricultural chemical product. The Regulations should be consulted to determine whether a product is deemed to be an agricultural chemical product and therefore subject to this labelling code. If uncertainty exists about whether a product is an agricultural chemical product, the Agricultural and Veterinary Chemicals Evaluation Section of the APVMA should be contacted. Applicants wishing to have a label approved under the National Registration Scheme may contact the APVMA for additional information but should be aware that the APVMA can only assess a label if it is part of a complete application. 1.5 General information required on labelsThe Agvet Code stipulates that a label must contain adequate instructions to cover every point relevant in the following list:
The label must contain specific labelling information for each of the points listed above, if applicable. This information is to be placed on the label in the order listed below. The figure in brackets after each requirement indicates the relevant section in Chapter 2 that gives details on content and layout:
Warranty statements, disclaimers regarding liability, logos such as drumMuster and barcodes may also be included. These must be placed in such a way as not to interfere with the layout of the requirements listed above. 1.6 Label LayoutThe size and type of container determines the space available for labelling and, therefore, the format or layout of a label and the space available for each item on the label. More space and a larger typeface should be allocated for key information. Space for items such as barcodes and hazard symbols must be taken into account. In doing so, care must be exercised to ensure that:
1.7 Placement of InformationMain panel and ancillary panels A panel refers to a distinct portion or division of the label. A label will be easier to read and follow if the necessary information is spread over two or more panels rather than being squashed onto a single panel. The label should be made as large as possible. Small type and cramped layout should be avoided as they are difficult to read and instructions may not be clear to users. When there are two or more panels on a label, one panel is designated the main panel while the others become ancillary panels. The main panel, as the name suggests, is the most prominent panel and must contain the following items:
The name and address of the registrant, formulator or distributor (paras 2.58–2.59) may also appear on the main panel, depending on available space. The remaining items are generally included on the ancillary panels. Where possible, they should appear in the order listed in para. 1.2. A sample label is shown in Appendix 1, Label Layout. ‘Bottle-in-box’ or ‘bag-in-box’ If the product to be sold to end users consists of a bottle or bag in an outer box, both the outer box and the inner bottle or bag must be labelled. However, in the case of a bag in a box, if the bag is firmly attached to the inside of the box and is not designed to be removed, labelling of the bag is not required. Outer boxes that are for shipping purposes only do not require full labelling. These labels are covered by other legislation such as Dangerous Goods. Boxes containing one or more bags or sachets, which are measure packs, must be labelled according to the requirements in paras 1.21–1.25 on measure packs. When the bottle (or bag) is sufficiently large to carry a complete label, that label of the bottle or bag must include all the required information. However, if the size of the label does not allow all the required information to be included, the label for the bottle (or bag) must include, as a minimum, the following:
The label for the bottle or bag must also include the following statement on the main panel of the bottle (or bag) label after the statement of claims for use: Before using product, read directions on outer pack. eg the label for the outer pack must contain all labelling requirements including the following statement on the main panel after the statement of claims for use: The bottle (or bag) must not be sold separately. Carton with inner plastic bladder/container ‘Carton with inner plastic container’ refers to cartons in which the inner plastic container or bladder is not intended to be removed during use, and is not glued or affixed to the outer carton (e.g. Cubidor® packs). The minimum labelling required on the inner plastic container is:
If the product contains a scheduled poison, the collar of the inner plastic container is to be labelled ‘POISON’, by either an embossed or otherwise permanently affixed label. The outer pack must be fully labelled and also include the following statement on either the main panel after the statement of claims for use or another prominent position: DO NOT remove plastic inner container from carton until empty. Labels with leaflets and booklets If the size or shape of a container cannot accommodate all the required label information, or the recommendations are too numerous to be listed clearly, some information can be printed in a leaflet or booklet which is supplied with each container. In this case, the leaflet or booklet is part of the label. The leaflet or booklet must include the following items:
The label of the primary pack (immediate container) must contain the following items:
Measure packs Measure pack means a sealed container which contains a measured quantity of chemical product for use on one occasion and one or more of which is enclosed in a primary pack. Measure packs must bear the following items:
Measure packs must include the following statements in either upper or lower case letters of not less than 2 mm in height: Not to be sold separately. If the measure packs are manufactured from water soluble material, the following words must also be included in either upper or lower case letters of not less than 2 mm in height: Water soluble packaging. Keep dry. If it is not possible to print directly on to the water soluble pack, these requirements must be printed on an outer protective bag. The following statement must be printed in either upper or lower case letters of not less than 2 mm on the main panel of the outer pack, as part of the contents statement: Contains [...] measure packs which it is illegal to sell separately. Presentation or promotion containers Presentation or promotion containers may include two or more products that may be used either as a mixture, or separately, such as:
The amount of information that must appear on labels for presentation or promotion packs depends on the type of material the outer pack is made of. If it is made from clear plastic or similar material, which allows the main panel details - including first aid and safety directions of each chemical product contained in the pack - to be easily read, no further labelling is required. If the main panel is not clearly, visible, the following information must be included on the outer pack:
CHAPTER 2: EXPLANATORY NOTESThis chapter explains the information that must be placed on labels if they are to meet the Code of Practice for Labelling of Agricultural Chemical Products. Also included is advice on label formatting. The instructions apply to all labels and follow the same numerical sequence presented in Chapter 1. 2.1 Signal HeadingA person shall not sell or supply a scheduled poison unless it conforms with labelling and poison scheduling requirements of the current edition of the A summary of the appropriate signal headings and other required wording is shown below. This summary accords with the requirements established by the Trans-Tasman Harmonisation Working Party established to progress harmonisation of Australian and New Zealand labelling and packaging requirements for drugs and poisons. The relevant signal headings as listed in Part 2 of the 16th edition of the SUSDP are: Schedule 7: DANGEROUS POISON Schedule 6: POISON Schedule 5: CAUTION The current edition of the SUSDP should be consulted for more detailed information on these requirements and on additional requirements that apply to dry chlorinating compounds and flammable liquids. 2.1.1 Presentation of signal headingsDangerous Poison, Poison or Caution Where the expression DANGEROUS POISON, POISON or CAUTION is required on the label, it must be:
Keep Out of Reach of Children Where the expression KEEP OUT OF REACH OF CHILDREN is required on the label as part of the signal heading, it must be:
For products which do not contain any scheduled poisons, this statement must not appear as a signal heading. If the statement is included on the label of such a product (and this is voluntary), it must be shown in the storage and disposal section. Read Safety Directions Before Opening or Using The statement READ SAFETY DIRECTIONS BEFORE OPENING OR USING3 (see para 2.4) is required whenever safety directions are shown on the label. This may include some products which do not require any other signal heading (i.e. they are not scheduled poisons). Where this expression is required on the label, it must be:
In the case of ready-to-use packs such as aerosols, the alternative statement READ SAFETY DIRECTIONS BEFORE USING is applicable. 2.1.2 Other cautionary words or phrasesProducts containing an aqueous solution of paraquat For products containing an aqueous solution of paraquat, apart from the signal words described above, the following cautionary statements must be written: CAN KILL IF SWALLOWED The above-mentioned statement must be:
Antifouling paints The signal heading for anti-fouling paints is determined by the SUSDP under the following directions:
WARNING If the paint contains a substance listed as Schedule 5, or listed in Appendix A or B, or a substance listed in the First or Second Schedule of the Uniform Paint Standard but present below the listed level, it does not have to be labelled as a poison. The words KEEP OUT OF REACH OF CHILDREN, if shown, should be in the storage and disposal section. The words READ SAFETY DIRECTIONS BEFORE OPENING OR USING are required only when safety directions are required on the label. 2.2 Distinguishing name of the productThe distinguishing name of the product is the name allocated to the product. It is the name that appears on the label as well as being the registered name of the product. Generally, the distinguishing name includes all of the words that appear between the signal heading and the active constituent statement. Words, numbers or phrases included in company logos or trademarks, which are also positioned between the signal heading and the active constituent statement, may not automatically be included as part of the distinguishing name, at the discretion of the APVMA. To be acceptable, a distinguishing name must:
The distinguishing name must not be offensive or contain any offensive words or phrases. Nor should it be misleading. When figures are included, they should relate to the level of active constituent in the product expressed in metric units or to some other feature of the product acceptable to the APVMA. Letters (that do not form a word) may only be used when they are formulation type codes and must be consistent with the international coding system for pesticide formulation types. The use of terms such as ‘Plus’, ‘Extra’ ‘Extra Strength’, ‘Double Strength’, ‘Tropical Strength’ or ‘Professional Strength’, in the distinguishing name are only acceptable if:
2.3 Active constituents, solvents and other scheduled ingredientsThe active constituent(s) is/are the substance(s), that are primarily responsible for the biological activity of the product. This biological activity together with the proposed uses makes the product an ‘agricultural chemical product’. The label must include all active constituents, together with any scheduled solvent or other ingredients contained in the formulation that are also scheduled poisons. 2.3.1 Active constituent statementAn active constituent statement must:
Use of common names The name of the chemical used in the active constituent statement must conform with the common name of the substance(s) recommended by Standards Australia in AS 1719-1994 (or its revision) or approved by Standards Australia for addition to the Standard. If no common name has been recommended, an active constituent may have a common name prescribed under legislation. If Standards Australia has not published a recommendation, those of the International Organization for Standardization (ISO) or the British Standards Institute (BSI) may be used. If no common name has been nominated by Standards Australia, ISO or BSI, Recommended Names for Chemicals Used in Industry (BS2474) should be used for reference to the appropriate chemical name. If a common name is not listed in any of the above, the chemical name, which should conform with the IUPAC system of nomenclature, should be used. A trademark or trade name should not be used as the name of an active constituent except when it becomes an approved common name. If there is a particular Australian Standard that applies to the active constituent, an appropriate brief statement may be included in brackets after the active constituent, for example: 900 g/L HIGH TEMPERATURE CREOSOTE (conforming to AS 1143 ). Where the active constituent of the formulation specifies a particular isomeric ratio, this must be included in the active constituent statement. Concentration Where applicable, the concentration of active constituent must be clearly stated in front of the name of the active, for example: 800 g/L 2,4-D present as the ethyl ester All units of mass or volume should be represented by their correct symbols, namely, ‘g’ (grams), ‘kg’ (kilograms), ‘mL’ (millilitres), or ‘L’ (litres). Expressions of concentration which are not acceptable on their own include, but are not limited to, ‘w/w’; ‘w/v’; or ‘%’. Where salts and esters of active materials are present, the amount shown on the label should apply only to the active ion or grouping and be shown as: 500 g/L 2,4-D present as the triethanolamine salt. The manner of stating certain active constituents is set out in Appendix 2, Uniform Expression of Active Constituents. Mixtures Where two or more active constituents are present in the end-use product, the following conditions apply: the active constituents must be shown one under another in descending order (highest to lowest) based on the concentration of each active constituent present; and when synergists are present, even when present at higher levels than the active constituent they must be shown after the main active constituent(s), for example, piperonyl butoxide as synergist for pyrethrins. 2.3.2 SolventsLabels must specify solvents where these are listed in the schedules of the SUSDP. A solvent statement must:
SOLVENT [...] g/L LIQUID HYDROCARBONS or 2.3.3 Other scheduled ingredientsAny other ingredient which is a scheduled poison, but not an active constituent or solvent, must also be shown on the label. The statement must:
[HEADING] [...] g/L [NAME OF POISON4] 2.3.4 Anticholinesterase compoundsThe statement ‘an anticholinesterase compound’ is required on labels for certain organophosphorous or carbamate compounds. Examples of active constituents requiring this statement are listed in Appendix 3. Where required, the statement must appear immediately below, following or beside the active constituent statement for each active constituent with anticholinesterase activity. For example: 750 g/kg ACEPHATE (an anticholinesterase compound) The statement must be prominent and written in letters at least 1.5 mm in height. It can be in upper or lower case letters. If a product contains several active constituents, some of which require the anticholinesterase statement, an asterisk (*) may be used after the relevant compounds and the anticholinesterase statement shown below the active constituent statement. For example:
The requirement for including an anticholinesterase statement does not apply to:
2.4 Mode of action identification symbolsThe mode of action identification symbol allows users to distinguish between similar products with different modes of action. It is part of a labelling strategy in the overall management of resistance to herbicides, insecticides and fungicides. The symbols assigned to various active constituents are listed in Appendix 4 (herbicides), 5 (fungicides) or 6 (insecticides). If the active constituent is not listed in appendix 4, 5 or 6, contact AVCARE regarding inclusion in an appropriate group. 2.4.1 SymbolsThe mode of action symbol should be visible at the point of sale. It should be included on the main panel of all labels (except home garden and domestic products, swimming pool products, antifouling paints or industrial fungicides such as timber treatments). The mode of action symbol must:
Example 1: Product with single active constituent
Example 2: Product with two active constituents
Example 3: Product with different types of active constituents
2.5 Statement of claims for useUnless the distinguishing name of a product is sufficiently descriptive, the label must include a concise statement of the purposes for which the product is to be used. This statement must be positioned immediately beneath the active constituent statement or the mode of action identification symbol, as appropriate. Some examples of claims for use statements follow:
If a product has many uses, a general statement such as follows can be made: For control of a wide variety of weeds in various situations as per the Directions-for-Use Table. Labels may also include pictures or diagrams as part of the statement of claims for use as long as the illustrations are consistent with, and related to, the approved uses of the product. 2.6 Restricted chemical productsThe Agvet Code stipulates that a product prescribed by the Regulations as a ‘restricted chemical product’ must include the following statement: RESTRICTED CHEMICAL PRODUCT - ONLY TO BE SUPPLIED TO OR USED BY AN AUTHORISED PERSON. This statement must be shown immediately beneath the statement of claims for use and must be printed in bold-face, sanserif, upper case letters of not less than 2 mm in height. This requirement applies to products that have been specifically declared to be a restricted chemical product in the Regulations. Restricted agricultural chemical products as at June 2001 are listed in Appendix 7. 2.7 Contents/net contents‘Net contents’ should be used for products sold by mass, and ‘Contents’ for products sold by volume. The contents of a product should be stated in metric units. Units of mass or volume should be written in full or represented by their correct symbols according to relevant State and Territory weights and measures legislation. Liquids should be shown as ‘mL’ (millilitre/s) or ‘L’ (litre/s). Solids, semi-solids, pastes or aerosols should be shown as ‘g’ (gram/s) or ‘kg’ (kilogram/s). 2.8 Name and address of registrant, formulator or distributorUsers of a product should be able to identify and, if the need arises, contact the person or company responsible for a product. To facilitate this, the label must include the name and street address (not a post office box) of either the registrant, the formulator or the distributor. The contact person or company may be qualified by the words ‘Packed for’, ‘Distributed by’ or ‘Sold by’. An emergency contact telephone number (NOT a ‘000’ number only) must be shown on the label to enable users to contact a responsible person in an emergency. 2.9 Directions for useThe directions for use required on a label include instructions on how, when and where the product is to be used. Limitations on use that are aimed at minimising hazards to crops, animal safety, human health and the environment might also be included. The directions for use section of a label is divided into the following subsections:
2.10 RestraintsA restraint is a limitation placed on the use of a product. A limitation on use will only be considered a restraint if the following conditions apply:
Appendix 8 contains examples that will help to determine when a statement is a restraint. Restraint statements must:
2.11 Directions for use tableA directions for use table contains several elements of label information essential to the proper use of the product. This information will most frequently (but not always) be set out in tabular form in the sequences shown in Appendix 9, Directions-for-Use Table Headings. Where a product is intended for use on tree or vine crops, the directions for use must be shown in the format given in Appendix 11. Crop/situation The specific crops, groups of crops or situations in which a product will be used should be listed in alphabetical order to assist users in locating the desired information. This is particularly important on labels that list many uses. Crop groups used should conform to the Codex Classification of Foods and Animal Feeds, published by the Codex Alimentarius Commission. Pests, diseases, weeds controlled The common name for the pest, weed or disease, based on the appropriate current references listed below, should be used:
Full scientific (Latin binomial) names should be used for pests, weeds or diseases only where there is a possibility of confusion. Rate The rate of application must be stated in clear terms suitable for the intended method of application. The rate should, whenever possible, be expressed:
If a product may be used in combination with another product, the application rate for the product may change when it is mixed according to instructions on another registered product. If a specific mixture is recommended on product labels, manufacturers of such products must show, on each product label, the proposed rates and directions-for-use information on how to mix and apply the chemical combination. Critical comments The critical comments column should contain information that, when read in conjunction with the restraints and general instructions, is sufficient to allow accurate use of the product for all purposes indicated. More specifically, the critical comments column should contain information on one or more of (but not necessarily all of or limited to) the aspects of product use listed below:
For herbicides, the terms ‘pre-emergence’, or ‘post-emergence’ refer to crop stages and not weed stage, unless the label clearly specifies otherwise. State Inclusion of a separate ‘State’ column is not necessary unless the label requires it for clarity. Where a product is approved in less than all States and Territories and the use pattern is similar, the approved States/Territories should be identified by including them in brackets after the heading ‘Directions for Use’, eg Directions For Use (ACT, Vic. only). Unless otherwise indicated, a particular use or uses will be considered to be approved for all States/Territories. In other words, there is no need to include the term ‘All States’. For the purposes of this labelling code, and hence for labelling of agricultural products in general, the term ‘All States’ includes the Northern Territory and the ACT. Where differences between States occur for a particular use, the information may be incorporated into the use-table in either the ‘crop/situation’, the ‘pest/diseases/weeds’, the ‘rate’, or the ‘critical comments’ column, as is most appropriate. For example, if Queensland requires a higher rate of application, then the entry for the ‘rate’ column may be shown as: 10 mL (20 mL — Qld only) per 100L 2.12 ‘Not to be used ...’ statementA label must include, in bold-face, sanserif, capital letters of not less than 2 mm height, the following statement immediately below the Directions for Use table: NOT TO BE USED FOR ANY PURPOSE, OR IN ANY MANNER, CONTRARY TO THIS LABEL UNLESS AUTHORISED UNDER APPROPRIATE LEGISLATION. 2.13 Other limitations and prohibitionsAny other general limitations on use which may be necessary for human safety, public health or environmental protection must, if required, follow the above statement. Examples include: DO NOT USE THIS PRODUCT IN THE HOME GARDEN. IN TASMANIA, THIS PRODUCT MUST NOT BE APPLIED BY AIRCRAFT WITHOUT THE SPECIFIC APPROVAL OF THE REGISTRAR OF CHEMICAL PRODUCTS. IN WESTERN AUSTRALIA, FOR USE BY BULK GRAIN HANDLING AUTHORITIES ONLY. These statements must be printed in bold-face, sanserif, capital letters of not less than 2 mm height. Each statement is to start on a separate line. 2.14 Withholding periodsThe purpose of withholding periods (WHPs) is to avoid unacceptable residues of agricultural chemicals and their metabolites in raw agricultural commodities, and food for humans or animals. The time in a withholding period statement must be shown as a figure in:
The withholding period statement must be on a separate line immediately below the ‘NOT TO BE USED FOR ANY PURPOSE’ statement and the ‘any other limitations and prohibitions’ statements (if any). It should be in a bold-face, sanserif font of upper case letters with a minimum height of 1.5 mm. Each statement should be on a separate line. The heading WITHHOLDING PERIOD(S) must appear before the statement(s). If there are two or more different withholding periods, and the label is in a tabular form, a ‘WHP’ column must be included in the table, in addition to the statements below the table. If all uses have the same withholding period and the label is in tabular form, only the statement below the table need appear. If a number of crops have the same withholding period, the crop names must appear before the statement, for example:
2.14.1 Combined grazing/harvesting withholding periodsIf a use requires both harvest (H) and grazing (G) withholding periods, the label must identify these by including in the table either (H) or (G) after the appropriate figures. It is important that a key be included below the table with statements to show clearly the meaning of (H) and (G). Examples of withholding period statements are as follows:
2.14.2 Withholding periods not requiredStatement No. 14 in the above list, ‘NOT REQUIRED WHEN USED AS DIRECTED’, should be used when the APVMA determines that no withholding period is needed between application of a product and harvesting, grazing etc. 2.15 General InstructionsGeneral Instructions include any information required by the user but not already included under the Directions for Use. General Instructions may include information on:
2.16 Herbicide resistance warningA warning about resistant weeds must be included in the general instructions for all herbicide products (except home garden products) under the subheading ‘Resistant Weeds Warning’. The statement should also be included in all product literature.
Companies may expand on this with specific do/do not statements required to properly manage the risk of herbicide resistance to their product/product’s mode(s) of action. 2.17 Fungicide resistance warningA warning must be included under the subheading ‘Fungicide Resistance Warning’ in the General Instructions for all fungicide products, except home garden products and products for ‘industrial’ purposes (e.g. timber treatments, antifouling paints). The statement should also be included in any product literature. The following warning should be used on all products containing a single active constituent:
Companies may expand on this with specific do/do not statements required to properly manage the risk of fungicide resistance to their product/products mode(s) of action. The following warning should appear on all fungicides containing two active constituents:
Companies may expand on this with specific do/do not statements required to properly manage the risk of fungicide resistance to their product/products mode(s) of action. 2.18 Insecticide resistance warningA warning about insecticide resistance must be included under the subheading ‘Insecticide Resistance Warning’ in the General Instructions for all insecticide products except home garden products. The statement should also be included in all product literature. The following warning should be used on all products containing a single active constituent:
Companies may expand on this with specific DO/DO NOT statements required to properly manage the risks of insecticide resistance to their product/product’s mode(s) of action. The following warning should appear on all insecticides containing two active constituents:
Companies may expand on this with specific DO/DO NOT statements required to properly manage the risks of insecticide resistance to their product/product’s mode(s) of action. 2.19 CompatibilityAll products listed in the compatibility section must be registered (at the time of label approval) and should be suitable for mixing with the product 2.20 Precaution statementsPrecaution statements aim to minimise health risks to humans or animals from approved use(s) of a product. Such risks may be due to direct exposure to the product or from contamination of food by the product. The statements should be set out clearly under the heading ‘Precautions’ and can be chosen from the examples listed below, or as appropriate to the product and its use.
Restrictions which apply to planting further crops in the treated area may also be required, especially when designed to avoid unacceptable residues or poor performance of subsequent crops. 2.21 Re-entry periodsSome of the more toxic agricultural chemical products may be required to carry a statement about entry into treated crops/areas. In such cases, the following statement(s), or suitable alternatives, must be included in the ‘Precaution’ section under the heading ‘Re-entry Period’:
2.22 Protection statementsProtection statements aim to minimise hazards to crops, native and other non-target plants, livestock (including bees), wildlife, fish, crustaceans and the environment through approved use of the product. Protection statements should be selected from the examples listed below or appropriate statements for particular products and situations should be submitted for approval. These statements must be set out clearly under the following headings, as appropriate to a product and its uses: 2.22.1 Protection of crops, native and other non-target plantsThe following general statement must be included on herbicides under the heading ‘Protection of crops, native and other non-target plants’:
The above statement may be included on labels for other products where relevant. A further statement must also be included on phenoxy herbicides7 and other Group I herbicides:
2.22.2 Protection of livestockThe following general statements may be included on products under the heading ‘Protection of livestock’:
2.22.3 Protection of wildlife, fish, crustaceans and environmentThe following general statements may be included under the heading ‘Protection of wildlife, fish, crustaceans and environment’:
2.23 Storage and disposal statementsStorage and disposal statements must be set out clearly under the heading ‘Storage and Disposal’. The statement “Keep out of reach of children” can be shown first if not required in the signal heading. 2.23.1 Storage statementsIf a container or package (e.g. carton) or its contents may be significantly damaged by moisture, the following statement should be given:
If a container or package is impermeable to moisture (e.g. steel drums with weather-proof labels), the following statement is acceptable:
All Schedule 7 poisons must include the following statement:
Storage Directions that differ from those above may be used for products needing specific storage conditions to maintain the chemical and physical integrity of the material or package for at least two years (or until the expiry date). For these products, the following statement may also be included:
Refer to paras 2.137–2.139, ‘Date of Manufacture and/or Expiry date of product’ for further information on date-controlled products. 2.23.2 Disposal statementsSuitable instructions about the proper method of disposing of excess prepared spray, spent dip (if applicable), empty containers and other packaging must be included. Appropriate disposal statements follow. It may be appropriate for registrants to ask chemical suppliers if they operate a reuse or recycling scheme. In most States, suppliers are able to accept triple-rinsed containers of some chemicals for reuse and recycling. Reference to drumMuster should be included for eligible container types. Disposal directions which differ from those listed below may be included as long as justification is provided to support the proposed statements. For refillable containers
For metal drums and plastic containers
For paper bags
For plastic and foil bags
For glass bottles
For small containers For small containers of 1 kg/1L or less (e.g. measure packs) the following abbreviated statement is acceptable:
For containers for formulations which are used direct For formulations which are not diluted with water before use (ULV, ready to use etc.) the following statement should be used:
For spent dips When the product can be used as a post harvest dip appropriate instructions must be included as to the correct method of disposing of the dip contents. This information may also include a method for neutralising the active constituent in the dip prior to disposal. The applicant should provide an appropriate statement. For various containers accompanied with a leaflet If a label leaflet is to be used as part of the label for various containers which have different disposal instructions, the following disposal statement may be shown on the label leaflet in place of the full disposal instructions:
2.24 Safety DirectionsSafety Directions which relate to safety in handling, use and storage of a product can be obtained from If no statement in the handbook is appropriate, an application can be made to the APVMA for recommendation of appropriate statements. Statements additional to those listed as mandatory in the handbook may be included, provided they are reasonable or do not contradict the mandatory statements. The following conditions apply to layout of safety directions:
2.25 First Aid InstructionsFirst aid statements can be obtained from the If no statement in the handbook is appropriate, an application can be made to the APVMA for recommendation of an appropriate statement. The following conditions apply to layout of first aid statements:
2.26 Material Safety Data SheetThe requirement to include Material Safety Data Sheets (MSDS) for products is stated in relevant State/Territory occupational health and safety legislation. When MSDS are required, product labels must refer users to the MSDS by inclusion of a statement such as the following:
2.27 Emergency informationThe requirements of the Australian Code for the Transport of Dangerous Goods by Road and Rail (ADG Code), which are incorporated into relevant State legislation, must be adhered to in labelling of any products classified under the ADG Code as ‘dangerous goods’. The requirements are set out in the Code and may include:
Inquiries on specific labelling issues arising from the ADG Code should be directed to one of the ‘Competent Authorities’ listed in the Code. 2.28 Batch numberThe batch number of a product should preferably be printed on the bottom of the front panel of the label or container or be suitably affixed to the label or container. The batch number may comprise either numbers or letters or a combination of numbers and letters and may include the prefix BN. The appropriate batch number should be printed adjacent to this heading so as not to be confused with any other numerical codes. 2.29 Date of manufacture and/or expiry date of productThe Date of Manufacture of a product and, if applicable, the Expiry date, should preferably be printed on the bottom of the front panel of the label or container, or be suitably affixed to the label or container. These dates may comprise numbers or letters, or a combination of numbers and letters, in English. Normally expiry dates are only required if a product cannot be stored for at least two years. Registrants must provide an expiry date for those chemical products referred to in the Code and the Regulations as ‘date-controlled chemical products’. Appendix 10 lists chemicals which are determined to be date-controlled chemical products in the Regulations as at June 2001. Both the date of manufacture and the expiry date must be included on the label for these products. A suitable prefix should be included to distinguish the Date of Manufacture from the Expiry date. For example, date of manufacture may include the prefix ‘DOM’, while the expiry date may include the prefix ‘EXP’. The appropriate date of manufacture and expiry date should be printed adjacent to these headings so as not to be confused with any other numerical codes. 2.30 APVMA label approval numberA unique number, allocated by the APVMA, must be included on the bottom of either a one-panel label or the ancillary panel of an approved label. The expression ‘APVMA Approval No.’ must be included in front of the number. Where label space is extremely limited, the statement ‘APVMA (number)’ may be used. The APVMA will use this approval number to verify the registration status of products. The number must not be written or displayed in any way that implies that the APVMA recommends, warrants or guarantees the use of the product. This would include using letters that are large in comparison with others on the label or prefixing the expression with words that imply that the APVMA recommends, warrants or guarantees the use of the product. Chapter 3: GENERAL REQUIREMENTSGeneral requirements applicable to the labelling of agricultural chemical products, including font size, securing of labels, and prohibited statements are outlined in this chapter. 3.1 Label to be securely attachedEvery label for a product must be printed on or securely attached to the outside of the container or pack of the product. Leaflets or booklets, if used, should be attached to the container in plastic pockets or other suitable secure holding methods. 3.2 PrintingExcept as otherwise directed, all wording must be:
All wording on a label for which there is no minimum type size specified earlier in this publication must have a minimum letter height of 1.5 mm. Letters with ascenders or descenders, such as b, f, g, h, l, t, etc., are to be a minimum of 1.5 mm. Letters without ascenders or descenders, such as a, e, i, o, u, m, r, etc., are to be a minimum of 1 mm. This minimum print size should only be used where space is extremely limited. Larger print, that is 2 mm or greater, is easier to read. Users are more likely to read larger print and follow the instructions. 3.3 Terms to be avoidedAccording to the Agvet Code, a label must not include any statement or expression that claims (however the claim is stated) that:
3.4 Terms such as ‘natural’Use of terms such as ‘natural’, ‘naturally derived’ or ‘nature’s way’ must be qualified according to the following:
3.5 General environmental claimsEnvironmental claims for marketing - a guideline, released by the Trade Practices Commission in February 1992, provides information on the use of environmental claims in marketing and avoiding misleading claims. 3.6 Comparatives and superlativesTerms such as ‘the best’, ‘the most effective’ or ‘superior control’ should not be used. Some other comparative terms may be permitted if suitable data is presented to justify their inclusion. 3.7 Indefinite termsGeneralised and imprecise terms such as ‘insects’, ‘weeds’, ‘bugs’, should be avoided in claims or Directions for Use statements. However, when all species of a pest type are controlled, a general term such as ‘caterpillars’ is sufficient rather than specifying individual pests. 3.8 Advertising statementsAdvertising statements are not to be included on labels. Cross-referencing to other products may be included on a label only if the products are part of an approved spray program or if compatibility between products has been demonstrated. Reference may be made to products to be used in tank mixes for which specific approval has been obtained from the APVMA. 3.9 Advertising literature, product technical bulletins and promotional tagsAll claims for use and information contained in advertising literature and technical bulletins should be consistent with the information contained on the corresponding product labels. Claims inconsistent with those on approved labels are not permitted unless appropriate permits are obtained. 3.10 BarcodesBarcodes are an optional item which may be shown on labels. Provided no changes are made to the label text, and label layout complies with the requirements of this labelling code, the addition or deletion of barcodes need not be advised to the APVMA. Chapter 4: HOME GARDEN AND DOMESTIC PEST CONTROL PRODUCTS4.1 DefinitionHome garden and domestic pest control products are products which contain an agricultural chemical and are available to the general public via normal retail outlets. Home garden products are for use on vegetables, fruit, trees, ornamentals, lawns and on other areas around private dwellings9, for the control of diseases, insect pests and weeds as well as snails, slugs and rodents. Domestic pest control products are primarily used inside private dwellings to control common insect pests such as cockroaches, ants, spiders, silverfish, flies, mosquitoes, fleas etc. In addition, for both home garden and domestic pest control products, the following apply:
Appendix 3-1 of Part 3 of the Ag Requirements Series Guidelines for Registering Agricultural Chemicals gives guidelines for pesticides to be used by householders. 4.2 IntroductionWhile the general philosophy of this Code should still apply to home garden and domestic pest control products some adaptation will often be required. The need for this adaptation arises because home garden and domestic pest control products are used on a small scale plus the majority of people using home garden and domestic pest control products have:
In order to make the labelling of these products more ‘user friendly’, this chapter allows the:
The aim of this protocol is to encourage both simplicity and flexibility in the labelling of home garden and domestic pest control products. 4.3 Labelling Home Garden and Domestic Pest Control ProductsProducts covered The types of home garden and domestic pest control products to which this chapters applies include the following:
Home garden products do not include animal health, food storage or industrial products. Domestic chemical products do not include those products used primarily by the pest control industry. Swimming pool products are regarded as having both domestic and commercial applications and are not covered by this chapter. Aerosol products harmonised with New Zealand have specific requirements as detailed in Chapter 5. What goes on to the label?
Where to Place the Information Main Panel The main panel for home garden and domestic pest control products follows the requirements set out in this code for agricultural products, but with some minor adjustments. The areas where the requirements are the same include the signal heading; distinguishing name; active constituent statements and all situations pertaining to them such as common name, solvents, mixtures, descriptive Australian Standard, and anticholinesterase statement; contents, company name and address and APVMA approval numbers. Signal words and phrases A home garden product contains an agricultural chemical that is classified as exempt from poisons scheduling or a schedule 5 or 6 poison in the SUSDP. Schedule 7 poisons, which require the signal warning DANGEROUS POISON, are considered to be too toxic for use by householders or home gardeners and must not be labelled as home garden or domestic pest control products. Home garden products are required to follow the requirements for signal headings as detailed in chapter 2 for substances classified as exempt from scheduling or in schedule 5 or 6. Statement of claims for use Statements of claims for use or ‘Broad Claims’ are necessary for agricultural home garden and domestic pest control products. The requirements specified in the code still apply, although by adopting the following format the ‘Broad Claims’ statement may become easier to read. Where a number of pests, weeds or diseases are to be included, or where there is a particular pest in various situations, the broad claims may be clearly shown by putting the information in point form. For example:
The inclusion of statement of claims for use in the form shown above is only possible if space permits. However, the inclusion of the phrase ‘… in the home garden’ should be included in all statement of claims for use to emphasise to the user that the product is intended for use in the home garden. Similarly, the inclusion of a phrase such as ‘….in the home’ or ‘… for domestic use’ should be included in all statements of claims for use where practicable for domestic pest control products. Prohibition and Restriction Statements These statements are not required. Restricted agricultural chemicals will not be allowed to be used in these situations. Emergency Information Panel The information specified in the Dangerous Goods Code for this area does not need to be included on labels. Ancillary Panels The ancillary panel should include information on how to prepare for use, use, store, and dispose of the product. This information should not only be simple, clear and concise, but should also be written and structured in such a way as to make it comprehensible to the majority of users. ‘How to use’ section The information on how to use a home garden and domestic pest control product should usually set out in a tabular format under the panel heading ‘HOW TO USE’. Because many differences from the Ag Labelling requirements occur in this section each of the requirements will be dealt with separately under appropriate subheadings. Restraints The subheading ‘Restraints’ is not required. However, the principle of including statements pertaining to a restraint should be maintained. The definition of a restraint is the same as for agricultural products. The statements should appear as the first item in the ‘How to Use’ section and should begin with the words ‘DO NOT’, for example:
Plants/Situations The table column containing the plants or situations being treated should have an appropriate heading such as ‘Plant(s)’ or ‘Area(s)’, depending on the use of the product. The specific plant, groups of plants or particular situations should be listed in alphabetical order for ease of locating the information. When a plant or a group of plants, whether it is vegetable, fruit or ornamental, is to be included in the ‘How to Use’ section, the names used must be readily understood even by those with limited gardening knowledge. The terms commonly used on agricultural products, such as pome fruit, stone fruit, brassicas, root vegetables, legume vegetables, cucurbits, etc. are not necessarily the most appropriate for home garden products. Terms, such as citrus, which are in regular use in the community are acceptable. To avoid confusion and be consistent with the food groupings as recognised by other standards (such as the MRL Standard and the Codex Classification of Foods and Animal Feedstuffs), group terms, such as brassicas and cucurbits, if they need to be used, must follow the following format:
This is by no means an exhaustive list. A degree of discretion and flexibility is needed when including specific groups of plants onto labels. Pests, Diseases, Weeds Controlled The common name only should be used for the pest, disease or weed, based on the appropriate current references listed in chapter 2. Scientific names should only be used on home garden labels when needed to avoid confusion. It is highly unlikely that scientific names would be required on the labels of domestic pest control products. Some examples of alternative names that may be used are ‘sap sucking insects’, ‘leaf eating insects’, ‘grass weeds’ or ‘broad leaf weeds’. These alternative names would help overcome a problem that occurs with the majority of users, that is, limited ability to identify the particular pest, disease or weed. Care needs to be taken in developing an alternative name because in some cases collective terms, for example ‘mildews’ and ‘mites’ may be inappropriate. The term ‘mildew’ would only be acceptable for some fungicides which control both downy and powdery mildew. Additionally, depending on the spray program (dormant trees versus active trees), unnecessary and unsuccessful pesticide use could be promoted by the use of the term ‘mites’ on a dormant spray label because the particular mite is not an over-wintering species. State Unless it is otherwise indicated, for example ‘QLD only’, a particular use will be judged as being approved in all States and Territories. In other words, the term ‘ALL STATES’ is not required. Where differences between States occur for a particular use it should be incorporated into the ‘How to Use’ section in either the ‘Plant’, ‘Pest’, or ‘How to Apply’ column. There is no need to include a separate ‘State’ column. When listing the States for a particular use list the State(s) and follow with the word ‘ONLY’. For example ‘NSW, VIC, WA ONLY’. The method of application should be stated in clear terms suitable for the intended rate of application. For home garden and domestic pest control products the rate can either be expressed in terms of product dilution, for example:
Home garden products containing a dust may not necessarily have a definite rate of application. For example, statements such as:
Giving precise recommendations for rates of dilution and rates of application is difficult because of the large variety of home garden products. However some general guidelines which apply to rates are:
‘How to Apply’ The basic requirements of the Critical Comments section as discussed in chapter 2 would still apply. However, the heading of this column should be changed to a more meaningful title such as ‘How to Apply’. For a particular plant/area situation some indication should also be given as to when, where and how much product should be used. The following statement must be shown immediately after the ‘How to Use’ section of the label:
Withholding periods This information should appear as one or more statements immediately below the limitations on use statement, that is following the statement required in para 4.43. All the requirements concerning the setting and publishing of withholding periods are the same as specified in chapter 2. Definition The withholding period (WHP) for home garden products is the period that must elapse between the last spray, dusting, or application of the pesticide and the picking of plant products for human consumption. Statement The withholding period should be shown as a figure in days or weeks as specified in chapter 2. There is no need to include either a ‘WHP’ column in the ‘How to Use’ table, as is required for agricultural products, or ‘Withholding Period’ heading at the beginning of the withholding period statements. Examples of Withholding Period Statements These statements differ from those on agricultural products by starting with the words ‘DO NOT PICK’, as distinct from ‘DO NOT HARVEST’. Since pesticides can be applied as either a spray, dust, granules etc. the method of application should be reflected in the withholding period statement. Some examples are:
If certain plants have the same withholding period the statements can be combined for example:
Statements should be in bold face sanserif capital letters of not less than 2mm in height, and each statement should be written on a separate line. ‘How to prepare’ This heading replaces the ‘General Instructions’ heading which is required for agricultural chemicals. A heading such as ‘HOW TO PREPARE’ conveys a better idea of the information contained thereunder. The ‘How to Prepare’ section should contain information concerning:
Additionally, this section should also contain, if applicable, statements such as:
plus a specification of how much spray should be mixed for an area of garden or for a specific number of plants, for example:
These statements should assist the end users to prepare the appropriate amount of pesticide thus minimising the need to dispose of excess prepared product. Mode of Action Information relating to the mode of action of the product need not be placed on home garden labels. Mode of action statements would only clutter up the |
