HB Ad Slot
HB Mobile Ad Slot
DPR Issues California Notice 2025-08 Adding and Revising Multilingual Translation on Pesticide Labeling
Monday, June 30, 2025

On June 26, 2025, the California Department of Pesticide Regulation (DPR) issued California Notice 2025-08 announcing that pesticide registrants may add or revise multilingual translation of its labels by non-notification. With this change, DPR now is consistent with the U.S. Environmental Protection Agency’s (EPA) decision to allow pesticide registrants to add the required Spanish-translated sections on its labels by non-notification as part of the Spanish translation requirements under the Pesticide Registration Improvement Act of 2022 (PRIA 5). Prior to Notice 2025-08, if a registrant wanted to add multilingual translations to its marketing labels, it was required to submit these label changes as an amendment. While Notice 2025-08 now allows the addition or revision of multilingual translation to DPR-registered labels to be made as a DPR non-notification,” DPR adds, however, that registrants may not add or revise “multilingual labeling elements if the English version is not previously listed and has not been reviewed and accepted by DPR.”

DPR states it expanded the scope of allowable translated labels falling under non-notification to include “all languages and allow for translation of the entire product label.” DPR notes it is allowing non-notification for translation of the entire product labels, which is not required by EPA, to acknowledge the diversity of the spoken language within California’s agricultural workforce.

As part of DPR’s implementation of the new procedure, DPR states it will allow the addition or revision of multilingual translations of previously approved labels either directly on the container or through web-based links (e.g., websites or QR codes) without notification to DPR. DPR notes, however, that registrants are responsible to ensure that all translated language on the label is a true and accurate representation of the accepted English language. For the web-based links, DPR states that explanatory text can be added via non-notification that explains the purpose of the website or QR code, such as “Escanee el código QR para etiqueta española” (i.e., “Scan QR Code for Spanish Label”), but states that it intends to maintain discretion to review the multilingual language and potentially require revisions to translations when appropriate. Additionally, DPR states that the full English-accepted labeling must appear on a product’s container label. Specifically, “[m]ultilingual labeling can be used in addition to English labeling but may not replace the required English label.”

When submitting an application through DPR’s new online system, California Pesticide Electronic Submission Tracking (CalPEST), DPR requires the pesticide applicant to agree to DPR’s Terms and Conditions, including a self-certification statement that the multilingual translations are correct and accurate. It states:

I certify that all multilingual translations printed on the pesticide product labels or other collateral labeling, including labeling found through web-based links (i.e., website or QR code), submitted for registration, are a true and accurate representation of the English labeling elements.

HTML Embed Code
HB Ad Slot
HB Ad Slot
HB Mobile Ad Slot

More from Bergeson & Campbell, P.C.

HB Ad Slot
HB Mobile Ad Slot
 
NLR Logo
We collaborate with the world's leading lawyers to deliver news tailored for you. Sign Up for any (or all) of our 25+ Newsletters.

 

Sign Up for any (or all) of our 25+ Newsletters