Can a registrant add an expiration date to a supplemental label if there is not an EPA-accepted and stamped supplemental label that also has the expiration date?
No, the registrant cannot add an expiration date without EPA’s approval. With the exemption of limited changes EPA has allowed changes to be made through notification or non-notification, all labeling changes must be approved by EPA. Supplemental labels are part of the labeling for a registered product and therefore must be reviewed and accepted by EPA before any amendments to that label are allowed (see 40 CFR 152.44(a) for more information). However, the Agency would like all supplemental labeling to have expiration dates and highly encourages registrant to add expiration dates using the amendment process.
