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Pesticide Establishment Registration and Reporting
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Section 7 requires that production of pesticides, active ingredients or devices be conducted in a registered pesticide-producing or device-producing establishment. ("Production" includes formulation, packaging, repackaging, labeling and relabeling.) Production in an unregistered establishment is a violation of the law. Information on pesticide establishments is tracked through the Section Seven Tracking System. Limited information on establishments is available through a FOIA request.
Establishments that produce pesticides, active ingredients or devices, including companies or establishments that import into the United States, must first obtain a company number; second, register the establishment, then file initial and annual production reports with EPA.
- 1. Obtain a Company Number - A One-Time Requirement
Registrants who plan to “produce” pesticides or pest control devices must obtain an EPA Company Number first. If your company has an existing EPA Product Registration Number, then you have a Company Number and can proceed with applying for an Establishment Number(s).
- You must apply for and receive your Company Number before requesting an establishment number.
- If your company is a licensed contractor of another company, you must have your own Company Number.
- The Company Number can be used for multiple establishments owned or operated by the same company.
- 2. Register Each Establishment - A One-Time Requirement
EPA assigns a unique number to each establishment that produces any pesticide, active ingredient or device. FIFRA requires that each producing establishment must place its EPA establishment number on the label or immediate container of each pesticide, active ingredient or device produced.
Registering an establishment is required once.
Use EPA Form 3540-8 to request an establishment registration number
- 3. File Initial and Annual Production Reports (Reporting Production and Distribution Information)
Initial Reports: An initial report is due to EPA 30 days after the company is notified of their pesticide-producing or device-producing establishment number. Submit reports to the pesticide establishment coordinator where your company headquarters is located.
Annual Reports: Thereafter, each facility that produces pesticides or devices must submit a report to EPA annually, by March 1st. The report includes:
- Name and address of the producing establishment
- Pesticide production information such as product registration number, product name and amounts produced and distributed
An annual report is required, even when no products are produced or distributed.
All establishments, domestic and foreign, must submit a report to EPA.
For foreign establishments, the amount reported should only be that amount which is produced for import into the United States, not to other countries.
Failure to File
Failure to file an initial or annual production report is a violation of FIFRA, and may result in termination of the establishment’s registration, civil penalties up to $7,500 per violation or criminal penalties. In addition, it is unlawful to knowingly falsify all or part of any pesticide production information reported on EPA Form 3540-16.
Establishment Inactivation Request
If your establishment is no longer producing pesticides, active ingredients or devices including repackaging and relabeling, please submit a letter requesting inactivation of your establishment to the pesticide establishment coordinator where that establishment is located. Upon inactivation, it is illegal to sell or distribute any pesticide, active ingredient or device in the United States or to export a product out of the United States. Inactive foreign establishments may not import any pesticide, active ingredient or device into the United States. Inactive foreign establishments may not import any pesticide, active ingredient or device into the United States.
Use EPA Form 3540-16 to report production and distribution information.