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Janitorial
All Containers›Shop by use case›Janitorial›Repackaging a pesticide›The refillable container standardShop all janitorial →
Repackaging a pesticide

The refillable container standard

By Dwight Davis, Founder

Updated

On this page8
Condition four is the one we cannot help with, and saying so is more useful than selling you a jug.

What the standard requires

A pesticide product that is not a DOT hazardous material must be packaged in a refillable container that, if portable, is designed, constructed and marked to comply with an enumerated list of 49 CFR requirements applicable to a Packing Group III material, including parts 178 and 180.

Marked is the operative word

The marking is how a container records that it was built and tested to a specification. A container that is physically similar to a compliant one but carries no marking is not a compliant container, because the marking is part of the requirement.

And if the product is DOT hazardous, it is the full set

Where the pesticide meets the definition of a hazardous material in 49 CFR 171.8, it must be packaged according to 49 CFR parts 171 through 180, or under a special permit. That is specification packaging with performance testing behind it.

Nothing in our catalog carries that marking

Measured across all 2,150 products: no UN specification marking of any kind. So no container we sell is a refillable pesticide container within subpart C, and buying one here will not satisfy condition four.

Parts 178 and 180 are why

Part 178 sets packaging specifications and the tests a design has to pass; part 180 covers continuing qualification and maintenance. Together they describe a container with a documented life, which is a different product from a stock jug.

Where to get one

From a packaging manufacturer that builds and marks to specification, and the registrant’s own written description of acceptable refillable containers is the document that tells you which. Ask them for it.

What we can supply honestly

Containers for janitorial chemistry that is not a pesticide. That is a real and substantial category, and the rest of this property treats it as the main use for this shelf rather than a consolation.

References

40 CFR 165.45, Refillable container standards. Paragraph (a)(1) requires a non-DOT-hazardous pesticide in a portable refillable container to be designed, constructed and marked to comply with an enumerated list of 49 CFR requirements for a Packing Group III material, including parts 178 and 180; paragraph (b) requires full 49 CFR parts 171-180 packaging where the product is a DOT hazardous material. law.cornell.edu
40 CFR 165.65, Registrants who distribute or sell pesticide products in refillable containers, which requires a written refilling residue removal procedure adequate to ensure the product does not differ from its confidential statement of formula, a written description of acceptable refillable containers, and management of any rinsate from a non-diluent solvent under Federal and State regulations. law.cornell.edu
40 CFR 165.70, Refillers who are not registrants. Paragraph (b) sets the five conditions under which a registrant may let you repackage their product into refillable containers, including an EPA-registered refilling establishment and a written contract; paragraph (c) makes repackaging without them a violation of section 12 of the Act for which both you and the registrant may be liable. law.cornell.edu
Written from federal regulation, not from a plant floor. FIFRA is administered by EPA and the states have their own pesticide programs on top of it. Nothing here is a registration, a contract or a finding that a container complies; those are the registrant’s, the lawyer’s and the container manufacturer’s to give.