When Labels Change: Staying Compliant in the Field

Hello everyone. Most farmers and applicators do their best to follow the rules. The saying “the label is the law” is something we all know, and it isn’t just a slogan—the pesticide label is legally enforceable. But labels aren’t set in stone. Seasons change, rules change, and sometimes the label printed on the jug isn’t the newest one anymore. So what happens if a person tries to do everything right, only to later find out the label they followed was outdated?

The Responsibility Lies With the Applicator.

Under federal and state law, the applicator is responsible for following the current label.

Even if:

• The jug came with an older label

• Nobody mentioned a change

• Or the retailer didn’t know either

The applicator is still expected to use the most up-to-date instructions.

Why Jug Labels Aren’t Always Current

Chemical manufacturers are allowed to sell product that still has older labels on it. A label change could have come through after those containers were already printed and shipped. That means the printed label doesn’t always tell the whole story anymore, making it harder for you to stay compliant.

How to Protect Yourself

Here are good habits that go a long way:

• Check CDMS, Agrian, or the manufacturer’s website before using a product.

• Print or save a PDF of the label for your spray records.

• Write down the label revision date in your spray log.

• Double-check 24(c) local-use labels, because those can change year-to-year.

If you can show you were making a genuine effort to follow the most current rules, most inspectors will work with you rather than issue fines.

Could You Still Get in Trouble?

Technically, yes. If an inspection shows the product was used in a way that doesn’t match the current label, you could be found out of compliance. But there’s a big difference between a simple mistake and intentional misuse.

If your record keeping shows:

• You checked for current labels

• You documented what you used

• You made a good effort to follow the rules

Then most of the time it’s treated as an education opportunity—not a punishment.

Bottom Line

The applicator carries the responsibility—but also the control. By getting in the habit of checking labels before spraying and keeping good records, you protect yourself, your farm, and your right to keep using these chemistries in the future.

Staying informed is part of being a good steward, and good stewardship is something farmers take pride in.

Hope everyone had a wonderful holiday season. -Dwayne