Supporting and Revised Documents
Q1: How do I provide updated/revised labels and safety data sheets(SDS)?
A1: Submit them in one of the following ways:
Q2: What are the requirements for labels submitted electronically?
A2: All labels must be submitted electronically and meet the following criteria:
- Marketplace/container label
- Text-searchable PDF
- Free of printer-proof/production comments, lines, and measurements
- Fit on 8.5 X11” sheets of paper without requiring format changes
- Clear and readable when printed without additional magnification required
- All pages must be right-side up with no requirement for rotating pages to be readable
Q3: When should I provide revised supporting documents?
A3: Please submit a copy of revised product labels throughout the year as they become available. DO NOT submit them Nov 1 to Dec 31 during renewal season. Describe label revisions in the body of the email or in an attached PDF.
Q4: Are CDs an acceptable way to submit supporting documents?
A4: No. CDs are not accepted.
Q5: Are paper labels and supporting documents accepted?
A5: No. Paper labels and supporting documents are not accepted.
Q6: Does Montana require EPA form 8570-5 for supplemental registrations?
A6: Yes. Provide an EPA pin-punched or date-stamped version of the form.
Q1: Does Montana require registration of adjuvants, surfactants, or devices?
Q1: When are renewals emailed and mailed out to registrants?
A1: Renewals are emailed and mailed on Nov 1 annually.
Q2: When are renewals due annually?
A2: Renewals are due by Dec 31 annually.
Q3: Is there a late fee for renewals received after Dec 31?
A3: Montana has no late fee but begins sending notices of non-registration on January 1 to start into the enforcement process for unregistered products in the channels of trade.
Registration of Co-packs, Multi-packs, and Kits
Q1: Does Montana require registration of co-packs, multi-packs, or kits?
A1: No. Individual products within the pack or kit must be registered. Please provide a copy of the label for these products for reference by pesticide enforcement agents in marketplace inspections.
Q1: Does Montana require registration of 25(b) products?
Q2: What is required for a 25(b) product application?
A2: A label, safety data sheet, statement of formula, efficacy data, payment, and application for each product.
Q3: Can I submit a copy of the label for my 25(b) product for review to see if it meets Montana’s requirements?
A3: No. A complete application must be submitted prior to any review.
Discontinuation and Cancellation
Q1: Does Montana have a discontinuation period?
A1: Yes. Montana has a 2-year discontinuation policy. The product must be paid for and registered for both years to complete discontinuation. For example, the product could have moved into ‘Discontinued Year 1’ in 2018. Then moved into ‘Discontinued Year 2’ in 2019. Then the product would have until December of 2023 to move out of the channels of trade in Montana, but the four remaining years would not be paid by the registrant. This would be the full six years as noted in the Montana Code Annotated (MCA) 80-8-201 (10a-b).
Q2: Can products be cancelled in Montana?
A2: A product can only be cancelled if it is completely out of the channels of trade in Montana. At letter must be supplied by the registrant verifying that from the date of the letter, there is no product in the channels of trade in Montana. No payment is required.
Products Requiring Separate Registration
Q1: Does Montana require separate registration for alternate scents of the same product?
A1: Yes. For example, fresh scent and unscented versions of otherwise identical products must be registered separately.
Q2: Does Montana require separate registration for alternate container sizes of the same product?
A2: Separate registration is only required if the alternate container size has differing information on the container from other container sizes. For example, separate registration would be required if the storage and disposal information varies due to the container size difference.
Q3: Does Montana require separate registration for different weight classes?
A3: Yes. Separate registration is required for different weight classes. For example, one product is for dogs under 12 pounds and another product is for dogs 12 to 25 pounds.
Q4: Does Montana require separate registration for different colors?
A4: Yes. For example, antifouling paints come in different colors and the colors are on the label.
Q5: Does Montana require separate registration for alternate brand names?
A5: Yes. Alternate brand names must have their own separate registration from one another.
Q6: Does Montana require approval or registration of 2(ee) recommendations?
A6: No. Montana does not require registration or approval of section 2(ee) use recommendations. We request that registrants send us all 2(ee) bulletins for our records. Recommendations do not require additional state registrations but are considered a part of the label and must be consistent with FIFRA Section 3 labeling requirements.