Stewardship Tip Sheet: Tamper-Evident Packaging Requirements

Posted on | by Justin Harrison

As a bulk site operator handling TELONE™ by Teleos soil fumigant, you play a crucial role in maintaining the integrity and security of the product. When transferring TELONE™ from a stationary tank into refillable containers, such as cylinders or minibulks, you are classified by the EPA as a repackager. This classification means you must comply with federal pesticide regulations, which include using tamper-evident packaging (TEP), ensuring proper labeling, and strictly adhering to container requirements. Following these regulations helps protect your customers, your facility, and the TELONE™ brand.

1. Under FIFRA and EPA’s container-containment regulations (40 CFR Part 165), repackagers must:

  • Apply a tamper-evident device to each refillable container after filling.
  • Ensure all containers are durable, compatible with TELONE™, and adequately maintained for reuse.
  • Operate under a written and current repackaging agreement with Teleos Ag Solutions.
  • Maintain refill and seal records for at least three years.
  • Train all personnel involved in the filling, sealing, labeling, and handling of TELONE™.

2. Tamper-Evident Packaging – What Counts?

Tamper-evident devices provide clear visual evidence if a container has been opened or compromised. Acceptable methods include:

  • Heat-shrink bands over fill ports or valves
  • Serialized security seals or tamper-proof cable ties
  • Wire locks or breakaway tags that must be cut to access

These must be applied immediately after filling and must not be reusable. If a seal is broken or missing, quarantine the container and notify your Teleos contact before releasing it for use or transport.

3. Labeling & Packaging – Your Responsibilities

When repackaging TELONE™, you must ensure that each refillable container is:

  • Labeled with the exact product name and EPA registration number. These labels can be ordered by your TELONE™ Specialist at Teleos, or available on www.teleosag.com.
  • Marked with your EPA establishment number (“EPA Est. No. XXXXX-XX”).
  • Labeled with a lot or batch identifier that links the container to your site’s refill log.
  • Carrying all required precautionary and hazard statements as provided in the Teleos-provided refillable container label.
  • Packaged in a container that meets DOT requirements for hazardous materials, including proper closures, venting, and secure valve caps.

4. Best Practices for Compliance

  • Use only containers authorized for reuse, in good condition, and compatible with TELONE™.
  • Keep TEP materials secure and inventory-controlled at the site.
  • Document every refill with details on the container ID, date, operator, and seal/lot number.
  • Maintain a site SOP that covers cleaning, refilling, sealing, labeling, and loading procedures.
  • Train employees to inspect containers, apply TEP, verify labels, and respond to seal issues.
  • Review your procedures regularly and report any discrepancies immediately.

Why It Matters

Following EPA repackaging requirements is essential. Not complying can result in serious consequences, such as stop-use or stop-sale orders, hefty civil penalties, and federal enforcement actions. Non-compliance may also lead to the loss of your authorization to refill TELONE™ or increase the risk of contamination, misapplication, or injury in your operations. It’s important to understand the potential liability for both your business and your customers. Make compliance a priority to protect your interests.

Disclaimer:
The resources and information provided are meant purely for educational discussion, contains only general information about legal matters, and is not to be construed as advice. Please note that any information or resources provided are not legal or regulatory advice, and should not be treated as such. You must not rely on the information provided as an alternative to legal advice from your attorney or other professional services. Teleos Ag encourages readers to consult with counsel, and their local, county, and state regulators. We make no representations or warranties, express or implied, in relation to the information provided through our resources and blog posts. It is the readers responsibility to know the laws related to 1,3- D, appropriate PPE, Licensing, etc., in his or her City, County, State, and Country.

Justin Harrison
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