What goes wrong

The container was not compliant

Updated October 2026

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How it happens Marked is why performance is not enough Parts 178 and 180 describe a different product Our whole catalog fails this The registrant has a list Residue removal is part of the same package of duties So ask for both documents before buying anything Ask us and we will tell you no References

It held the product, it did not leak, and it was not a compliant container.

How it happens

A stock HDPE jug is chemically suitable, strong and the right size, so it gets used. Nothing about using it reveals that the rule asks for a container designed, constructed and marked to a specification.

Marked is why performance is not enough

A container that would pass the tests but carries no marking has no record that it did. The marking is the evidence, and the standard requires it alongside the design and construction.

Parts 178 and 180 describe a different product

Part 178 sets the specifications and the tests; part 180 covers continuing qualification and maintenance. A specification container has a documented life and a retest regime, which a stock jug does not.

Our whole catalog fails this

Measured across all 2,150 products, nothing carries a UN specification marking. We would rather publish that than let it be inferred from a product page that says nothing either way.

The registrant has a list

A registrant selling in refillable containers must develop a written description of acceptable refillable containers for the product. That document is the answer to this question and it is theirs to give you.

Residue removal is part of the same package of duties

The registrant must also develop a written refilling residue removal procedure adequate to ensure the product does not differ from its confidential statement of formula. A compliant container used without that procedure is still a problem.

So ask for both documents before buying anything

The acceptable container description and the residue removal procedure. Together they tell you what to buy and how to operate it, and neither is something a packaging supplier can provide.

Ask us and we will tell you no

We would rather lose the order than describe a stock jug as a compliant refillable pesticide container. The same query that produced this finding is the one that excluded a whole property from this library for the same reason.

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.