By Tony Herber
Last updated on January 15, 2026
The US EPA has released a Proposed new PRN 98-10 – Guidance for Notifications, Non-Notifications, and Minor Formulation Amendments.
The updated guidance aims to create processing efficiencies for both the Agency review staff and pesticide registrants. This document, once finalized, will govern the processes by which minor changes to registered pesticide labels can be made. To aid in review and commenting, EPA has also released a Summary Table of Significant Changes between PR Notice 98-10 and Proposed PR Notice 2025-XX which highlights what the Agency views as the most significant changes made to the guidance.
These documents have been released for public comment only and are not yet able to be used. EPA is accepting public comments for 45 days (due February 19th, 2026) which may result in changes when the final guidance is published. The SRC Team is working with the ACC Center For Biocide Chemistries and Household and Commercial Products Association to provide comments prior to the deadline. SRC Federal VP of Regulatory Services, Tony Herber, has reviewed the guidance and provided a high-level summary of the key changes proposed in the guidance document:
Proposed Label Change Notifications:
- EPA has formally clarified that a label does not need to be provided with an ABN submission or change.
- Changes to packaging statements, via notification have added criteria, including that any packaging change that alters the composition of the packaging originally tested, or will modify the container handling instructions, may not be made via notification.
- Requires Logos and Graphics related to certifications such as USDA, Kosher, or Design for the Environment (DfE) to be made via amendment.
- Botanical and plant-derived active ingredient claims for antimicrobials must be made via amendment.
- Optional listing of all inert ingredients on the label may be done via notification, using the same chemical names as on the CSF
- Allows revisions to a 100% repack label to match identically the Master label to be made via notification.
- Allows for referral statements to be edited via notification.
- Allows Marketing claims that are substantially similar to approved claims to be added via notification.
CSF Changes Via Notification
The new guidance would allow the following changes to be made via notification:
- Revising inert ingredients on the CSF to match supplier trade names
- Correction of typos, ingredient brand names, and ingredient ownership changes to be made.
Changes to Non-Notification Guidance
The new guidance would allow the following changes to be made via non-notification:
- Adding websites and scannable links or their placeholders
- Adding “Do Not Flush” graphics and statements
- Making “New Formula” claims
- Updating organism names to an officially recognized alternate name
- Adding bacteria or virus to the end of an organism name
- Making Warranty statements not related to performance or safety
Changes to Minor Formulation Amendment Guidance
- Added eligibility for Fragrance Notification Program changes to be submitted as minor formulation amendments
The SRC Team continues to monitor the draft guidance and work with applicable trade associations to provide comments to EPA. Please contact your SRC consultant for questions on the guidance.
