Use of Distributor Products Under a 24(c) Special Local Need (SLN) Registration

The United States Environmental Protection Agency (U.S. EPA) has recently informed our Department that all Special Local Needs (SLN) are to be issued only for the basic manufacturer’s product. U.S. EPA considers the distributor product the same as the basic manufacturer’s product. Therefore, a separate SLN registration is not needed to use the distributor product.

To be consistent with U.S. EPA’s position, this letter is informing you that the Department will allow any distributor product currently registered in California to be used in conjunction with an SLN based on the basic manufacturer’s product. As you know, a distributor product can be identified by having the first two sets of numbers in the EPA Registration Number identical to the basic manufacture’s EPA Registration Number. If an EPA Registration Number has three sets of numbers, it is a distributor product. A basic manufacture’s EPA Registration Number has only two sets of numbers separated by a hyphen.

When doing compliance monitoring for SLN applications, a distributor product may be used in place of the basic manufacture’s product. The only difference is that distributor product’s EPA Registration Number will have a third set of numbers that is not on the SLN and the brand name may differ from the basic manufacturer’s product.

If you should have any questions, contact your Senior Pesticide Use Specialist for your County.

Sincerely,