Food Protection Trends - May/June 2021 - 364

FIGURE 1.

UNDERSTANDING EPA-REGISTERED LABELS
Once a product is registered with the EPA, its master
label is accessible to the public through the PPLS or the
NPRIS (see Regulation of Sanitizers and Disinfectants,
above). The master label is a comprehensive document that
contains a great deal of information about the product, such
as functions, safety information, use directions, use sites,
efficacy claims, and marketing claims. Commercial, package,
or market labels are developed from the master label and are
what the end users see on sanitizer or disinfectant containers.
The label on the product container has the most relevant
and useful information for the end user. This information
cannot deviate from the language on the master label, which
is registered with the EPA. Additional information from
the master label may be used in marketing materials, such
as brochures, websites, and other advertising forms. It is
important to note that a product can be sold under a different
name than the one that appears on the master label. The most
important parts of a commercial antimicrobial product label
are presented in Figure 1 and are also described below.
*	EPA registration number. On the product label, the
registration number is displayed as " EPA Reg. No. "
followed by two or sometimes three sets of numbers.
Because products may be marketed and sold under
different brand names, they might have the same EPA
registration number. Products made by a supplier or
distributor (i.e., not a manufacturer) have three sets of

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Food Protection Trends May/June

numbers; the last set of numbers identifies the supplier,
who is not the same as the manufacturer. If the first
two sets of numbers match a registration number that
is on one of the EPA lists (e.g., List N), the product is
equivalent to the listed product. For example, if " EPA
Reg. No. 12345-12 " is on List N, then all products
labeled EPA Reg. No. 12345-12-#### are an equivalent
product, because the last set of numbers identifies the
supplier or distributor.
*	Format. The product label indicates if the product is in
an RTU format (does not require any dilutions) or if it
is a concentrate (liquid or powdered) that needs to be
diluted as specified by the label before being used.
*	Directions for use. The use instruction section presents
valuable information on dilution, contact time (see
below), and whether the product can be sprayed, wiped,
mopped, and so on. It also lists precleaning steps or
whether or not a potable-water rinse is required.
*	Dilution. A concentrated product will have precise
instructions for use, listing ounces per gallon and ppm to
help the end user achieve the correct concentration. The
efficacy of some antimicrobial products may be affected
by the hardness of the water used to prepare the diluted
product. For this reason, manufacturers test the efficacy
of the product in hard water. The label will indicate the
water hardness level at which efficacy testing was done,
such as an instruction to dilute 2 oz/gal of sanitizer in
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