Producing Pesticides in the US: Establishment, Reports and Records
Register the establishment, report production every year by 1 March, and keep batch, receipt and shipping records for EPA.
In Short
- Register before you produce.
- Report yearly, even at zero.
- Batch IDs on every record.
The Chemical Manufacturing Guide
Approved formulas. Tested batches. Correct labels out the door.
- Which rules reach your plant
- Raw material to store
- Charge, watch, adjust, release
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The Chemical Manufacturing Guide
Approved formulas. Tested batches. Correct labels out the door.
Product registration gets a pesticide label approved. Producing it also needs a registered establishment, a yearly production report and records EPA can inspect, under 40 CFR parts 167 and 169. This guide covers those producer duties and how batch records support them. It is orientation, not regulatory advice. Sources checked 4 Oct 2026.
Register the Establishment
Under 40 CFR 167.20, any establishment where a pesticidal product is produced must be registered with EPA; custom blenders are excepted. Production includes formulating, packaging, repackaging and relabeling.
More on register the Establishment
The establishment number appears on the product label, so registration has to exist before labeled product leaves.
Report Every Year
Section 167.85 requires each producer to report, for each establishment, the amount of each pesticidal product produced and sold or distributed in the past year and estimated for the current year. The first report is due within 30 days of first registration, then every year on or before 1 March, even when nothing was produced.
Records 40 CFR 169.2 Expects
| Record | Keep |
|---|---|
| Product, EPA reg. no., amount and batch ID | 2 years |
| Device brand names and quantities | 2 years |
| Receipts of pesticides and actives | 2 years |
| Shipments | 2 years |
- Product, EPA reg. no., amount and batch ID
- Keep
- 2 years
- Device brand names and quantities
- Keep
- 2 years
- Receipts of pesticides and actives
- Keep
- 2 years
- Shipments
- Keep
- 2 years
Books and Records
Section 169.2 lists records producers keep: product name, EPA registration number, amount and batch identification for every batch produced, with the batch ID on all production control records; receipts of pesticides and active ingredients; and shipments. Many of these are kept for two years; some records have different periods, so read the section for each record type.
Batch discipline supports all three
A consistent batch ID that runs from raw material receipt through blending, packaging and shipping makes the annual report a query, not a hunt, and lets you answer an EPA records request quickly. Approved formulas, label versions and pack counts should match the registered product.
Worked Example: the Production Year
- Before productionEstablishment registered with EPARegulatory
- All yearBatch IDs on every production control recordProduction
- JanuaryProduced, sold and estimated amounts compiledRegulatory
- By 1 MarchAnnual report submitted, even if zeroRegulatory
States and Quality
Many states register products and some regulate producers. Separately, product quality, label accuracy and stewardship programmes matter to customers and regulators.
More on states and Quality
Treat EPA records as a minimum and keep quality records alongside them.
Questions
Is product registration enough?
No. The establishment where it is produced must also be registered under 40 CFR 167.20, unless you are a custom blender.
When is the annual report due?
On or before 1 March each year, covering the past year and estimating the current year. File even if you produced nothing.
How long are batch records kept?
Production records under 169.2(a) are kept for two years. Check each record type in the section.
Where does V5 fit?
V5 keeps formulas, batch records, lots, receiving, shipping and labels linked. It does not file with EPA; your regulatory team does.
Practical orientation, not legal advice. Rules differ by jurisdiction; your quality and compliance team decides what applies.
Keep reading
Global Agrochemical Quality & Compliance Readiness Guide
Biopesticide & Microbial Registration Readiness Guide
Pesticide Residue Limits for Exporters: EU 396/2005 and US Tolerances
EU REACH for Agrochemicals: 1907/2006 Meets 1107/2009
FAO/WHO Pesticide Specifications (JMPS) Readiness Guide
Pesticide Product Registration: FIFRA Section 3 and EU 1107/2009