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Consumer information

One of the purposes of the ACVM Act is to ensure the provision of sufficient consumer information about agricultural compounds. The term ‘consumer’ is not defined in the Act, so it has been interpreted to mean those people purchasing and using agricultural compounds and veterinary medicines. Therefore, the labelling requirements imposed by the ACVM Group are intended to provide the information needed by the users to use a product appropriately and safely.

Initially, it was intended to limit labelling requirements to information related to the risk areas specifically mentioned in subsection 4 (a) of the ACVM Act (risks to trade in primary produce, agricultural security and animal welfare). This was decided on the basis that other agencies, i.e. Ministry of Health, Occupational Safety and Health, Ministry of Transport, ERMA NZ and the Commerce Commission, would take responsibility for specifying consumer information requirements and approve labels in regard to matters relevant to the legislation they administer.

Presently the ACVM Group, on behalf of other agencies, approves all aspects of labels for animal remedies and pesticides. Members of the pharmaceutical and agricultural chemical industries and user groups advised that this system is practical and efficient, and more likely to produce labels that contribute to the effective management of the range of risks posed by the use of agricultural compounds or veterinary medicines.

The ACVM and HSNO Acts have now commenced and the ability of other agencies to impose practical and effective labelling controls that can be translated into useful label statements has been tested. It is clear that, to meet its statutory obligation as specified in subsection 4 (c) of the ACVM Act, the ACVM Group is the only agency in a position to impose product-specific labelling requirements and to approve label content.

Because the ACVM Act does not specify what consumer information is relevant, the ACVM Group considers that any information that is needed to use a product appropriately and safely is relevant to its statutory responsibility.

Consequently, it will require labels to include information that assists the users to avoid or mitigate adverse effects across the full range of risks that Government expects to be managed. This includes risks to the safety of the users, other people who might be exposed, and the environment in general, as well as the targeted plants and animals. The kind of information that may be required is discussed in the article below.

The ACVM Group will approve the label content rather than necessarily approving the final label itself because it does not consider that it should take on the responsibility of an editorial check on final labels. However, since the layout of the label has an impact on the message communicated, applicants may find it more convenient to present a mock-up version or even the final label itself for approval.

Requirements for conditions on labels

Under the ACVM Act, conditions on the registration of a trade name product must be put on the public register. However, not all the conditions may be relevant to or appropriate on the label (for example, conditions on importation or manufacture are usually not relevant). In addition, most ACVM conditions will be as general as possible (unless there is a need to be specific), whereas the label will ‘translate’ the general conditions to the intended uses.

In the future, the ACVM Group intends to require all information that is needed to use a product appropriately and safely to be provided on the product’s label (label includes outer packaging or leaflets provided with the product). The requirement will be made under section 4 of the ACVM Act, which states that one of the purposes of the Act is to "ensure the provision of sufficient consumer information about agricultural compounds" (see above).

Users can expect to find statements on the labels about:

• any prohibitions/limitations on use;
• safety or contraindication warnings;
• any obligations on users in regard to use, disposal, record keeping or reporting; and
• any other matter that must be brought to their attention.

Registrants will be required to provide the ACVM information on use with the product.

Where necessary, registrants will be required to make it clear when there is a statutory obligation on the user or any other person to comply with a particular label statement.

Registrants will not be required to put on the label any matter that encourages a use of the product for any purpose that was not recommended by the registrant. Therefore, users may have to consult the public register to find out if a product can be used for purposes other than those stated on the label.