Monsanto v. Durnell · ¶20

EPA’s comprehensive regulatory role does not end with the pesticide’s initial registration and label approval. If the manufacturer wants to modify the label, it typically must go through an amended registration process. FIFRA provides that if “the labeling . . . for a pesticide is changed, the registration shall be amended to reflect such change if the [EPA] Administrator determines that the change will not violate” FIFRA. §136a(f )(1). EPA regulations further provide that “any modification” to the “labeling” of a “registered product must be submitted with an application for amended registration.” 40 CFR §152.44(a); see §152.50 (listing required contents of registration and amended registration applications).

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