^sd S7>,^ US Environmental Protection Agency
Office of Pesticide Programs
^	Specifications for Text PDF
^PROltP Product Labels
January 2008

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US EPA, Office of Pesticide Programs - Creation and Submission of Electronic Labels
January 17, 2008
Full Specifications for Text .PDF Electronic Labels revised 1/17/2008
NOTE: The following guidance is provided for creating and submitting product labels in electronic format to EPA. Submission of electronic labels to
EPA is voluntary but if done then two specifications are mandatory: the label must be a text .PDF (not an image .PDF) and the .PDF file name
format must be used. Registrants are requested to adhere to the remaining guidance whenever possible although some variation is permissible.
Questions, comments, and suggestions are welcome. Send to the ombudsman related to your product. Check the EPA website periodically for
updates to this guidance. EPA is currently using Adobe® Acrobat® 7.0.0. The guidance below should work with Adobe® Acrobat® 5.0 or above or
any software that adheres to the standards of that software.
1. Composing the Original Regulatory Label
Feature
Specification
Comments
The pesticide product
paragraphs and tables
etc. that are used on t
label submitted to EPA for regulatory approval should be formatted for 8.5" x 11" paper using text in
>; do not use columns. This regulatory label does not need to be formatted with the layout, graphics, colors,
he final printed label used on the product. The wording, not the layout, is critical on the regulatory label.
Software
Use any word processing or desktop publishing
software.
One of EPA's goals in selecting .PDF as the standard
text exchange format is to allow registrants to use any
software to create original product label.
The .PDF and CD-ROM submitted to EPA must be
formatted for Microsoft® Windows®. Format
conversion software may be needed if original
document is from Macintosh®, Unix®, et al.
Paper Size
8.5" x 11"

Paper Orientation
portrait or landscape

Margins
Minimum margins: 0.5" on all sides
Leave 1.5" x 1.5" (minimum) blank space
somewhere on first page.
You must leave sufficient blank space (1.5" x 1.5"
minimum) on the first page of a label for placement of
the EPA accepted stamp. This blank space can be
anywhere on first page; the placement is not
prescribed.
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US EPA, Office of Pesticide Programs - Creation and Submission of Electronic Labels
January 17, 2008
1. Composing the Original Regulatory Label
Feature
Specification
Comments
Font Size
12 point preferred for most text
6 point minimum
Follow label requirements in 40CFR156 and in the
Label Review Manual regarding minimum font sizes
for various components of label.
Font Type & Style
True Type®, Open Type® , or Postscript® Type 1
Arial or Times New Roman preferred
Do NOT use proprietary fonts or printer dependent
fonts. These can not be embedded in .PDFs.
Acrobat will try to use a substitute font but this may
alter label appearance. When converting to .PDF,
embed all fonts used in the document It is
recommended that the .PDF be created on the same
computer on which the original source document was
created so the same fonts are available. Using the
"when embedding fails - cancel job" option will make it
obvious when font problems exist (often due to
proprietary fonts).
Page Numbering
Number all pages.
Page numbers are extremely helpful and should be
used on the regulatory label submitted to EPA.
Tables
Use the software's "table" function rather than
tabs or blank spaces to create tables.
Use of tables is encouraged since they improve label
comprehension. Text in tables created using your
software's table function converts well to .PDF,
retaining the correct appearance and readily exporting
to other software. Use of tabs or spaces to create the
look of a table may not convert to .PDF correctly and
may not result in readily exportable data.
Columns
Recommended -
Do NOT use columns.
Note: Tables are acceptable.
Placing text in newspaper type columns often makes
it difficult to use the Acrobat text compare tool.
Columns may be used on final printed labeling but are
discouraged on the label submitted to EPA for review.
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US EPA, Office of Pesticide Programs - Creation and Submission of Electronic Labels
January 17, 2008
1. Composing the Original Regulatory Label
Feature
Specification
Comments
Color
Text: black
Graphics: grey scale preferred
Regulatory labels are frequently photocopied in
black/white. Colors may be used but they must not
interfere with ability to read or photocopy the label.
Graphics
Logos, drawings, diagrams, photographs, etc. are
allowed if they do not interfere with required text.
Anv required label text within or surrounding graphics
must be readable as text by the computer. See tip on
checking for text versus graphics under "Quality
Assurance" below.
Editing Marks
Do NOT include redline, strikeout, highlighting, or
other editing marks.
Exception: Can use square brackets to indicate
editorial comments which do not appear on final
printed label.
PDF label should be based on a "clean" version of the
proposed label. Do not use editing marks indicating
changes from the previous version of label. Acrobat
will add these markings when the label comparison is
run at EPA.
Square brackets can be used to indicate text which is
not part of the final printed label (e.g. notes to EPA
reviewer) or to indicate graphics to be inserted in final
printed label (e.g. skull/crossbones).
Label version
identification
Recommended -
Include a unique label identifier (version code) and
short description of changes at start or end of
label. The format of this version code is left to the
registrant and is not currently prescribed by EPA.
The goal is to distinguish various versions of a label.
The required format for the .PDF filename will
distinguish the electronic file. To distinguish paper
prints of the regulatory label it is recommended that
the label text include a code number and short
description of the changes since the last label version.
It may be useful to print the code number on the final
printed labeling (this is voluntary) but do not include
the description of changes.
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US EPA, Office of Pesticide Programs - Creation and Submission of Electronic Labels
January 17, 2008
2. Creating a Text .PDF Electronic Label
Feature
Specification
Comments
Conversion to
.PDF
PDF must be created directly from electronic
source document.
DO NOT SCAN PAPER LABELS (with or
without optical character recognition).
Goal is to create a text .PDF rather than an image
.PDF to allow for text comparison. Do not submit
scanned label images. This specification is different
than that for data studies where scanning is a last
resort option.
PDF Software
Use any software that creates a text .PDF
(version 1.4 or higher) and which can control the
required job options specified in this document
(e.g. embedding fonts).
To verify version information open the finished .PDF
label and check the document properties:
¦	Application - any software; often tied to software
used to create original source product
label (e.g. Acrobat .PDF Maker® for
Microsoft® Word®).
¦	Producer - any software (e.g. Adobe® Acrobat®
Distiller® 5.x (or higher))
¦	Version - .PDF 1.4 (Acrobat® 5.x) or higher
PDF Version
PDF Version 1.4 or higher
Verify as described above.
PDF Creation
Settings - general
Manually configure .PDF creation software using
the settings below (compatibility, fonts, etc),
or
If using Adobe® Acrobat® Distiller® then you
can download the file "Adobe Acrobat Distiller
Job Options" from the EPA website to
automatically configure settings.
These directions apply to Adobe® Acrobat® Distiller®.
If using other .PDF creation software, consult that
program's documentation to achieve these results.
Place "Adobe Acrobat Distiller Job Options" file
(downloaded from EPA website) on hard drive under:
C:\Program Files\Adobe\Acrobat 7.0\Distillr\Settings
When creating label .PDF, set Adobe® Acrobat®
Distiller® default settings to "EPA Label Print."
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US EPA, Office of Pesticide Programs - Creation and Submission of Electronic Labels
January 17, 2008
2. Creating a Text .PDF Electronic Label
Feature
Specification
Comments
Resolution
600 dpi minimum

Page Size
8.5" x 11"

Font Embedding
Embed all fonts
When embedding fails: cancel job
Goal is to embed all fonts used in document to ensure
correct formatting, appearance, and printing of
document. It is recommended that the .PDF be
created on the same computer on which the original
source document was created so the same non-
proprietary fonts are available. Using the "when
embedding fails - cancel job" option will make it
obvious when font problems exist (often due to
proprietary fonts).
Do NOT use proprietary fonts. These can not be
embedded in .PDFs. Acrobat will try to use a
substitute font but this may alter document format,
appearance, and print.
Security
Do not use any security on the .PDF.
do not encrypt document
do not require password to open document
do not require password to print or edit document
Goal is to enable EPA to compare .PDF files, mark
comments on .PDF label, and print.
Note: Security options may change in future.
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US EPA, Office of Pesticide Programs - Creation and Submission of Electronic Labels
January 17, 2008
2. Creating a Text .PDF Electronic Label
Feature
Specification
Comments
Bookmarks -
Product Label
Optional.
If used, it is recommended that registrant bookmark
the major label sections and bookmark the crops/sites.
Bookmark
Hierarchy
If used, limit to no more than four levels in either
full submission or within a single document.
Consensus is that people get lost when there are more
than four levels.
Indexing
Not required at this time.
This includes both the document properties as well as
indexing using the Adobe® Acrobat® cataloging
capability.
Electronic
Signatures
Not implemented at present
Electronic submissions must include Certification with
Respect to Label Integrity pending development of
Agency policy and standards on electronic signatures.
Mixing Data files
and Label files
Do not mix. Regulatory label must be in its own
file (see file naming convention below) separate
from data studies or forms. Submit label, data,
Notice of Filing, etc. each on a separate CD-
ROM.
E-label must be in a separate .PDF file on a separate
CD-ROM. If electronic versions are submitted, submit
separate CD-ROMs for e-label, e-data studies, and e-
Notice of Filing since each disk is filed in a different
location, [note: this will probably change in the future when a full
electronic submission system is developed.]
File Size
No limit
PDF has no limit on file size but the computer used to
create or read the file may introduce constraints.
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US EPA, Office of Pesticide Programs - Creation and Submission of Electronic Labels
January 17, 2008
2. Creating a Text .PDF Electronic Label
Feature
Specification
Comments
File Naming
Convention -
Product Label
Finished .PDF text label file MUST use this file name format:
-...PDF
where:
 = 6 digit company number part of registration number; use leading zeros so that field is
6 digits
= mandatory dash symbol
 = 5 digit product sequence number part of registration number; use leading zeros so
that field is 5 digits; for new products which do not yet have product numbers assigned
use "xxxxx" in this field
. (period) = mandatory field separator
 = date of submission using 4-digit year; use leading zeros for month and day, if
needed; note that order is year, month, day to facilitate simple sorting1
 = optional version identifier if needed to distinguish file versions with same date field;
consider initial submission to be version "a" but do not include the "a" in the file name;
if needed, the first version identifier used in the file name would therefore be "b"; use
letters (b, c, d, etc); do NOT separate version from date with period or space
. (period) = mandatory field separator
 = optional descriptor; any additional useful information (reason for amendment,
company's document identifier, product name, etc); can include several fields
separated by periods if desired2
. (period) = mandatory field separator
PDF = mandatory file extension
Note: use leading zeros to fill co#, prod#, and yyyymmdd fields (but do not use spaces)
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US EPA, Office of Pesticide Programs - Creation and Submission of Electronic Labels
January 17, 2008
2. Creating a Text .PDF Electronic Label
Feature
Specification
Comments
File Naming
Convention -
Product Label
(continued)
1	Note: Date can be either date the product label is submitted or created. It is not critical which date is
used but "" MUST create a unique identification code different from any other file for
this registration number. Use date version letter if necessary to distinguish files with same registration
number and date.
2	Note: Full path and file name is limited to 200 characters although some older software may have
problems displaying names longer than 60 characters.
Do not use spaces in the registration number or date sections of the filename (ok in the optional id section).
Use only characters allowed by Windows file naming conventions (eg. no "*", etc.).
examples:
minimum fields
001234-00123.20010215.PDF
all fields
123456.12345.20050919.add crops.PDF
123456-12345.20050919b.correct celery.PDF
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US EPA, Office of Pesticide Programs - Creation and Submission of Electronic Labels
January 17, 2008
2. Creating a Text .PDF Electronic Label
Feature
Specification
Comments
Quality Assurance
Print the .PDF product label and compare to
original source print.
It is suggested that printed .PDF product labels
be used as the paper copies of label required for
submission.
Check .PDF file to make sure label is text, not
graphic.
It is registrant's responsibility to make sure that the
.PDF label matches the original source label. Do not
assume .PDF is accurate without visually checking it.
Errors are usually obvious in terms of formatting (e.g.
last line of original source page moves to first line of
next page in .PDF version) or fonts that will not print
correctly (usually due to use of proprietary fonts). Be
sure to look at start and end of each page and to look
at any unusual symbols, fonts, or graphics included in
label.
Using a print of the .PDF label (rather than print of
original source document) will help registrant ensure
that the submitted paper label is the same as the
submitted electronic label as stated on the Certification
with Respect to Label Intearitv.
To check if label is text or graphic, open .PDF label in
full Adobe® Acrobat® and try to select text using the
"select" tool. If words can be highlighted with select
tool then you are working with text .PDF; if they can
not be selected then you probably have a graphic
(image). The text select tool highlights a word at a
time; the graphic select tool highlights rectangular
areas so that you can split words, lines, and letters.
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US EPA, Office of Pesticide Programs - Creation and Submission of Electronic Labels
January 17, 2008
3. Submitting a Text .PDF Electronic Label to EPA
Feature
Specification
Comments
What to Submit
1.	All required paperwork (cover letter, form
8570-1, data compensation, CSF, etc. as
needed).
2.	Five paper copies of the label.
3.	PDF file of proposed product label on CD-
ROM.
4.	Certification with Respect to Label Intearitv
form (signed).
Label formats:
Submit five paper copies of the proposed label plus
one electronic copy of the proposed label on a CD-
ROM. If submitted, e-data, e-Notice of Filing, etc
should each be on a separate CD-ROM. It is
suggested that you print the paper copies from the
electronic .PDF. You may also include an optional
paper copy of the label with redline/strikeout or similar
editing marks showing changes since last version
(although this is not necessary when electronic labels
are available for comparison) but do NOT use this
mark-up version when creating the .PDF label.
Electronic label file name:
Label files MUST use file naming convention above so
the file can be automatically loaded into a database
record identified by parts of this file name. If label files
are incorrectly named the .PDF label will not be used.
Certification form:
Use one certification form per product.
Submission
Medium
Compact Disk (CD-ROM).
CDR (write once) type CD-ROM is preferred to ensure
that the registrant's original files can not be altered.
The .PDF and CD-ROM must be formatted for
Microsoft® Windows®. Format conversion software
may be needed if original document is from
Macintosh®, Unix®, et al. Do not submit floppy disks.
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US EPA, Office of Pesticide Programs - Creation and Submission of Electronic Labels	January 17, 2008
3. Submitting a Text .PDF Electronic Label to EPA
Feature
Specification
Comments
How & Where to
Submit
Send via courier service to OPP physical
location:
Document Processing Desk 7502P (E-SUB)
U.S. EPA - Office of Pesticide Programs
2777 South Crystal Drive
Arlington, VA 22202
Do NOT send via US mail. The irradiation procedures
currently used on Washington, DC mail will damage
the CD-ROM.
history of significant changes
10/2/07	recommend not to use columns
1/17/08	put e-label on it's own CD-ROM; use separate CD for data, Notice of Filing, etc.
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