What Is The APVMA Agricultural Labelling Code? - Cohesion Labels

The Australian Pesticides and Veterinary Medicines Authority (APVMA) 'Agricultural Labelling Code' explains the information that must be included on labels if they are to meet the legislative requirements. It also provides examples of acceptable wording for certain statements where specific words are not mandated by legislation. If you are manufacturing agricultural chemical products, you need to be aware of what this code entails!

To help break things down, we've compiled this overview of what information the Agricultural Labelling Code dictates needs to be included on your labels. (Please note: This is just an overview. Consult the Agricultural Labelling Code for information about where these details should be placed on a label, legibility requirements, and more specific details that may apply to you).

• Signal heading: Your label must contain the appropriate signal words required by the current Poisons Standard. 
• Product name: The label must include the name of the chemical product. This does not have to be the same as the distinguishing name recorded in the APVMA Register for the chemical product.
• Constituent statements: The label must include the name and proportion of all active constituents, even if they are not scheduled poisons. The label must also include a declaration of any solvent, or other constituents contained in the formulation, that are scheduled poisons.
• 'Mode of action' indicator: The ‘Mode of action’ identification indicator allows users to distinguish between similar products with different modes of action. The indicator is part of a labelling strategy in the overall management of resistance to herbicides, insecticides and fungicides. Current ‘Mode of action’ tables are available on the CropLife Australia website. If a product is of a type not covered by the CropLife arrangements, you may propose suitable labelling for it, however you must provide relevant justification.
• Statement of claims for use: Unless the name of a product describes the intended uses, the label must include a concise statement of the purposes for which the product is to be used.
• Restricted chemical product statements: A product declared by the Agvet Code Regulations to be a restricted chemical product must, if it is going to be supplied, include the following statement on the label:
  RESTRICTED CHEMICAL PRODUCT – ONLY TO BE SUPPLIED TO OR USED BY AN AUTHORISED PERSON
• 'Net contents' statement: The net contents of the container of the product must be stated on the label. Its regulations, units of mass or volume must be metric, and be written in full or represented by their correct symbols.
  Liquids must be expressed by reference to volume, usually as mL (millilitre/s) or L (litre/s). Solids, semi-solids, pastes or aerosols must be expressed by reference to mass, usually as g (gram/s) or kg (kilogram/s). When a liquid is liquefied gas, it may be considered as an aerosol and expressed in kg.
• Name and address of the person primarily responsible for marketing the product: The address shown on the label must be an Australian street address (not a post office box) and must include a contact telephone number (not a 000 number only).
• Directions for use: The label must include adequate directions for use of the product. It must include an adequate directions for use table, including the crop or situation where the product may be used, the pests controlled or the purpose of use, the rate of application and other instructions that are critical for correct use.
• Restraints: A restraint is a limitation placed on the use of the product, and it must be included on the label. This includes restraints relevant to managing spray drift, where relevant to the product type. 
• 'Not to be used' statement: A label must include the following ‘Not to be used’ statement:
  NOT TO BE USED FOR ANY PURPOSE, OR IN ANY MANNER, CONTRARY TO THIS LABEL UNLESS AUTHORISED UNDER APPROPRIATE LEGISLATION.
• Other limitations and prohibitions: Any other general limitations or prohibitions on use that may be necessary for human safety, public health or environmental protection must be included on the label.
• 'Withholding period' statement: Labels must include any ‘Withholding period’  statements that are required to avoid unacceptable residues of agricultural chemicals and their metabolites in raw agricultural commodities, and food for humans or animals.
  If the product is for use on crops, animals or situations where residues of the chemical might arise, but the APVMA determines that no withholding period is needed between the application of a product and harvesting or grazing, or if that interval is defined by other critical comments such as a limitation on crop growth stages at which application can occur, the following statement must be shown:
  NOT REQUIRED WHEN USED AS DIRECTED
• 'Trade advice' statements: The label must include any ‘Export interval’ statement or ‘Trade advice’ statement that is required to avoid unacceptable residues of agricultural chemicals and their metabolites in food- or feed-producing commodities that may be exported, where those residues have the potential to unduly prejudice Australian trade.
• General instructions: General instructions include any information that the user needs to be made aware of that is not already included under the ‘Directions for use’ statement or elsewhere on the label.
• Resistance warnings: Where a label is required to include a ‘Mode of action’ indicator, the label must also include a warning that identifies the ‘Mode of action’ group to which any active constituent belongs and warns that weeds, insects or diseases may develop resistance to products of that group and this will reduce the effectiveness of the product.
  The resistance groups and warning statements are established by CropLife Australia reference groups. 
• Compatibility statements: The inclusion of general information on compatibility is not a relevant particular of a label and is not mandatory. This statement is not checked or considered by the APVMA in approving a label.
  If it is necessary to warn of specific incompatibility of the product with other products, you must do this in the ‘General instructions’ section. This would be considered by the APVMA in approving the label.
• 'Precaution' statements: The label must include any ‘Precaution’ statements necessary to minimise health risks to humans or animals from approved uses of a product. Such risks may be due to direct or indirect exposure to the product or treated materials, or from contamination of food, clothing or housing by the product.
• 'Protection' statements: The label must include ‘Protection’ statements necessary to minimise hazards to crops, native and other non-target plants, livestock (including bees), wildlife, fish, crustaceans and the environment through approved use of the product.
• 'Storage and disposal' statements: Suitable instructions on storage of the product must be included on the label. If the product is included in Schedule 7 of the current Poisons Standard, these storage instructions must include the instruction that the product must be stored in a locked room or place away from children, animals, food, feedstuffs, seed and fertilisers.
• Safety directions: The label must include safety directions that relate to safety in handling, mixing and using of the product. Guidance is given in the APVMA First Aid Instruction and Safety Directions Handbook that contains information on first aid instructions, safety directions, warning statements and general safety precautions for agricultural and veterinary chemicals.
• First aid instructions: The label must include first aid instructions from the APVMA First Aid Instruction and Safety Directions Handbook that contains information on first aid instructions, safety directions, warning statements and general safety precautions for agricultural and veterinary chemicals.
• Batch number: The inclusion of a batch number is required.
• Date of manufacture and/or expiry date: The inclusion of the expiry date and date of manufacture is required, when applicable.
• APVMA approval number: The label must include the distinguishing number of the label for the product. This number is unique to each label and is allocated by the APVMA.
• Dangerous goods and worker safety legislative requirements: Where other legislation requires that labels include other statements or information, such as information relating to transport of dangerous goods and workplace health and safety, these statements must be shown in a distinct panel or clearly delineated box.

Making sure your label meets the requirements for approval by the APVMA may seem overwhelming. However, an experienced label manufacturer can make the process straightforward and ensure your label artwork is compliant!