Labeling in the US generally has several categories:

Full labeling which requires full feeding studies for human consumption,
i.e.. in honey, wax etc, efficacy work-usually over 2years minimum,
environmental impact studies ..... All this costs many Million dollars.

24C label allows the addition of a pest on to a FULL label that is not
currently on that label. It is usually registered specific to a particular
state or group of states. As an example, if a product like Apistan was fully
registered for varroa and then we found it was active on another pest in a
particular state where that pest was present, the State with the
manufacturers OK could apply for a 24c label for that pest in that State. It
is on a state by state basis

A section 18 label is an emergency label and is only granted in EMERGENCY
situations where there is NO OTHER PRODUCT THAT WILL CONTROL A PARTICULAR
PEST. The manufacturer CANNOT REQUEST THIS TYPE OF LABEL  but must allow it.
The EPA is very strict about issuing these emergency labels. They are very
specific to the areas where the product will be used,  the total amount used
and users are tracked and many times field inspected. The user better have a
copy of the section 18 label in his possession while using the product.
These labels will not be issued on a cost basis because a  particular
product is cheaper than an existing one
The label is issued for a specific time period, sometimes a matter of months
and usually the longest is a year.
Some states have cried "wolf" in the past and have now a very difficult time
getting section 18 as the EPA has difficulty in believing said states "
cries as emergency"

I hope this puts the different types of labels in perspective.
Also consider the manufacturers economic position of having to recover their
multi- million dollar costs from a low volume product OR even developing
something like essential oil which probably are NOT patentable.

Dan Veilleux
Vilas, NC

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