Products Requiring Registration
Minnesota law states that “Each pesticide with a unique United States Environmental Protection Agency pesticide registration number or a unique brand name must be registered with the commissioner.” Accordingly, alternate brand name, distributor products are required to be registered.
Do alternate brand names or distributor labels require registration?
Minnesota law states that “Each pesticide with a unique United States Environmental Protection Agency pesticide registration number or a unique brand name must be registered with the commissioner.” Accordingly, alternate brand name, distributor products are required to be registered.
No, a basic producer’s product does not need to be registered before a supplemental distributor’s version of the same product can be registered.
Does a basic producer's product need to be registered before a supplemental distributor's version of the product can be registered?
No, a basic producer’s product does not need to be registered before a supplemental distributor’s version of the same product can be registered.
| Definition | Example | Is additional registration required? |
|
|---|---|---|---|
| Kits | A kit includes multiple products and can contain one or more FIFRA-regulated products, along with, in some cases, one or more non-FIFRA products. Each product in the kit is separately packaged and labeled – just as it would be if sold separately. The kit consists of an outer container, such as cardboard box, which houses the separately packaged FIFRA and non-FIFRA products placed inside the outer container |
Lice Kit
Pool Care Kit
|
Yes, if the product is sold/marketed under a new name (different from the name of each pesticide product inside), and/or each product label is not completely visible from the outside of the package. For specific registration guidance please see Section 3 Pesticide Registration |
| Co-packs | A co-pack is when two or more pesticide products
Each container must bear, or be accompanied by, full labeling, and the full labels of both containers must be visible. If the outermost packaging obscures any part of the labeling of the pesticides, the full labels must be duplicated and attached to the outermost container. |
Co-packs direct the user to mix the two products together before application. |
No, currently registered products that are simply packaged together without the addition of a new name, with each pesticide label completely visible from the outside of the package would not be required to hold a new/separate registration with the state. |
| Multipacks | A multipack is when two or more pesticide products with the same EPA Registration Number are packaged together. Each container must bear the full pesticide label. | This could include different scents and different names but the same EPA Registration Number. | No |
| Shrink Wrapped MPPT | When MPPT products are packaged together through shrink-wrapping so the full immediate container labeling for the pesticide is available to the consumer at the point of purchase | Multipacks can sometimes be sold as shrink-wrapped MPPT | No |
Does Minnesota require registration of Multiple Products Packaged Together (MPPT)?
| Definition | Example | Is additional registration required? |
|
|---|---|---|---|
| Kits | A kit includes multiple products and can contain one or more FIFRA-regulated products, along with, in some cases, one or more non-FIFRA products. Each product in the kit is separately packaged and labeled – just as it would be if sold separately. The kit consists of an outer container, such as cardboard box, which houses the separately packaged FIFRA and non-FIFRA products placed inside the outer container |
Lice Kit
Pool Care Kit
|
Yes, if the product is sold/marketed under a new name (different from the name of each pesticide product inside), and/or each product label is not completely visible from the outside of the package. For specific registration guidance please see Section 3 Pesticide Registration |
| Co-packs | A co-pack is when two or more pesticide products
Each container must bear, or be accompanied by, full labeling, and the full labels of both containers must be visible. If the outermost packaging obscures any part of the labeling of the pesticides, the full labels must be duplicated and attached to the outermost container. |
Co-packs direct the user to mix the two products together before application. |
No, currently registered products that are simply packaged together without the addition of a new name, with each pesticide label completely visible from the outside of the package would not be required to hold a new/separate registration with the state. |
| Multipacks | A multipack is when two or more pesticide products with the same EPA Registration Number are packaged together. Each container must bear the full pesticide label. | This could include different scents and different names but the same EPA Registration Number. | No |
| Shrink Wrapped MPPT | When MPPT products are packaged together through shrink-wrapping so the full immediate container labeling for the pesticide is available to the consumer at the point of purchase | Multipacks can sometimes be sold as shrink-wrapped MPPT | No |
| Type of Product | MDA response |
|---|---|
| Pesticide spray adjuvants | No, Minnesota does not register or regulate adjuvants/additives. |
| FIFRA25(b) minimum risk pesticides | No, Minnesota does not require registration of FIFRA 25(b) minimum risk pesticides. For more information visit: EPA Minimum Risk Pesticides Exempted from FIFRA Registration. |
| Manufacturing Use Pesticides (MUPs), technical grade pesticides, and /or pesticides used for formulating | Yes, Minnesota requires registration of MUPs, technical grade, formulating use pesticides. |
| Pest control devices | No, Minnesota does not require registration of devices used to control pests. For more information about what qualifies as a device and the differences between pesticides and devices, visit the EPA's guide, Pesticide Devices: A Guide for Consumers. |
| Physical barrier products | No, a physical barrier product is not required to be registered in Minnesota if it is not required to be registered with EPA. For more information visit: EPA Office of Pesticide Programs Barrier Products Clarification Document |
| Plant incorporated protectants (PIPs) | No, however permits for experimental use and distribution are needed. For more information visit: EPA Overview of Plant Incorporated Protectants. |
| Products distributed by Supplemental distributors | Yes, these products registrations are not dependent on the manufacture’s original product (2 part EPA number) being registered in the state prior to the distributor products and can be registered at any point during the registration period. |
| Fertilizer/pesticide combination products | Yes, each grade of fertilizer that contains a pesticide is considered a unique brand of fertilizer and requires separate registration as a specialty fertilizer in addition to registration as a pesticide. |
| The EPA Reg. No. OR the name of my product(s) has changed | Yes, when an EPA Reg. No. or a product undergoes a name change a new registration is required for the state of Minnesota. Furthermore, the pesticide with the old Reg no. must continue to be registered separately or discontinued. |
| Type of Product | MDA Response |
|---|---|
| Product with a separate label for each scent (examples: lavender, citrus, vanilla) | Each scent is considered a separate registration. |
| Product with a separate label for each color (examples: blue, green, red) | Each “color” is considered a separate registration. |
| Product with a separate label for each quantity (examples: 1 gallon, 5 gallons, 10 gallons) | Only one registration is needed if the product comes in different quantities, if the labels are otherwise identical. |
| Different cat or dog weight or age ranges for the same flea and tick product (examples: 1 to 5 pounds, 6 to 10 pounds) | Each label with a different weight range needs a separate registration. |
| Different grades of fertilizer in a weed-and-feed product | Each label with a different fertilizer grade needs a separate registration. |
| Alternate brand names or distributor labels | Each pesticide with a unique United States Environmental Protection Agency pesticide registration number or a unique brand name must be registered with the commissioner (MINN. STAT. § 18B.26). Accordingly, alternate brand name, distributor products are required to be registered. |
| Definition | Example | Is additional registration required? |
|
|---|---|---|---|
| Kits | A kit includes multiple products and can contain one or more FIFRA-regulated products, along with, in some cases, one or more non-FIFRA products. Each product in the kit is separately packaged and labeled – just as it would be if sold separately. The kit consists of an outer container, such as cardboard box, which houses the separately packaged FIFRA and non-FIFRA products placed inside the outer container |
Lice Kit
Pool Care Kit
|
Yes, if the product is sold/marketed under a new name (different from the name of each pesticide product inside), and/or each product label is not completely visible from the outside of the package. For specific registration guidance please see Section 3 Pesticide Registration |
| Co-packs | A co-pack is when two or more pesticide products
Each container must bear, or be accompanied by, full labeling, and the full labels of both containers must be visible. If the outermost packaging obscures any part of the labeling of the pesticides, the full labels must be duplicated and attached to the outermost container. |
Co-packs direct the user to mix the two products together before application. |
No, currently registered products that are simply packaged together without the addition of a new name, with each pesticide label completely visible from the outside of the package would not be required to hold a new/separate registration with the state. |
| Multipacks | A multipack is when two or more pesticide products with the same EPA Registration Number are packaged together. Each container must bear the full pesticide label. | This could include different scents and different names but the same EPA Registration Number. | No |
| Shrink Wrapped MPPT | When MPPT products are packaged together through shrink-wrapping so the full immediate container labeling for the pesticide is available to the consumer at the point of purchase | Multipacks can sometimes be sold as shrink-wrapped MPPT | No |
Minnesota law states that “Each pesticide with a unique United States Environmental Protection Agency pesticide registration number or a unique brand name must be registered with the commissioner.” Accordingly, alternate brand name, distributor products are required to be registered.
No, a basic producer’s product does not need to be registered before a supplemental distributor’s version of the same product can be registered.
