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Following up on LC06-0059, can a registrant add the phrase “Produced for” to their label without notifying EPA (as a non-notification – per PRN 98-10)?

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Following up on LC06-0059, can a registrant add the phrase “Produced for” to their label without notifying EPA (as a non-notification – per PRN 98-10)?

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PR Notice 98-10 section IV.D, changes in name and address, indicates that non-notification would be appropriate for changes in the name and address of a registrant provided these comply with other regulatory requirements. As described in 40 CFR 156.10(c), use of qualifiers such as “produced for” are considered as part of the name and address element of a label. Use of the qualifier “Produced for” in connection with the name and address can be done via non-notification.

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