Container design
40 CFR Part 165, Subpart C addresses applicable DOT design capability, durable individual identification and protection of product openings.
PCC Rule
PCC capability depends on the complete IBC configuration.
For a pesticide sold or distributed in a refillable IBC, EPA Pesticide Container and Containment (PCC) regulations can add requirements beyond the usual product-compatibility and DOT questions.
Keep the questions separate
Container, refilling and facility rules do different jobs.
“Pesticide” means more than insecticide. Depending on a product's intended claims and use, EPA-regulated pesticides can include herbicides, fungicides, rodenticides, disinfectants, sanitizers and other products intended to prevent, destroy, repel or mitigate pests.
Refilling controls
Subpart D addresses the registrant–refiller relationship, acceptable-container descriptions, product integrity, inspection, cleaning, labeling and records.
Facility containment
Containment requirements attach to specified storage, dispensing and refilling facilities and activities—not merely to the presence of an IBC.
Terminology matters: Part 165 defines “refillable” by intended repeated filling with pesticide for sale or distribution. A commercially reconditioned IBC is not automatically a refillable pesticide container. Under Subpart D, an existing refillable container that fails inspection may be refilled after repair, reconditioning or remanufacture only when the work complies with the relevant DOT requirements and the container meets the applicable Subpart C standards.
Subpart C configuration
Verify the installed accessories and capabilities.
Individual identifier
A durable, clearly visible serial number or other code must distinguish the individual IBC. It belongs on the outside of the container, not on a removable lid, cap or other closure; an ordinary removable product label is insufficient.
Lid / fill opening
Subpart C addresses the fill opening: it must have a one-way valve, tamper-evident device or both. The installed lid or cap, seal and related fittings must provide the required protection.
Valve / discharge opening
Subpart C addresses the discharge opening: it must have a one-way valve, tamper-evident device or both. The valve, cap and protective device must remain intact and functional.
Other product openings
Each additional opening other than a vent—including an integral pump opening when material could be introduced through it—requires equivalent protection.
Controlled vent
The vent is excepted from the opening-control requirement, but must be designed to minimize introduction of material through it.
DOT design capability
The portable IBC must satisfy the design, construction and marking standards incorporated by Subpart C for the pesticide's DOT status. A non-HAZMAT pesticide is not automatically outside these design requirements.
Product-specific compatibility
The registrant's written acceptable-container description must identify compatible materials and the information needed to confirm the configuration. The full set of fittings—such as gaskets, lids, valves and caps—is part of the complete evaluation. Regulations may use formal terms such as closure or appurtenance when addressing these items.
Important: Clean Tank does not provide legal advice regarding PCC compliance. Customers remain responsible for determining the requirements applicable to each pesticide, container and activity.
Actual accessory examples
Opening protection must be evaluated on the installed IBC.
These photographs show examples of pesticide-IBC accessories. They illustrate hardware features only; they do not establish that a container is acceptable for a particular pesticide or refilling activity.
Before each refill
Hardware must remain intact and the container must remain eligible.
Identify prior contents
Determine prior pesticide held in the IBC. The container may only be refilled with the same product.
Inspect the IBC
Inspect the exterior, the interior when possible, and the valves, caps and other fittings (appurtenances). Damage, illegible required markings or missing opening protection can cause the IBC to fail the pre-refill inspection.
Follow the registrant documents
Use the written contract, label, residue-removal and acceptable container disposal procedure, applicable to the specific pesticide.
Accessories are necessary, but they are not a stand-alone certification. The intended pesticide, label, registrant documentation, container history and condition, DOT status, refilling activity and applicable federal and state facility rules still control the final determination.
Primary sources
Verify the rule applicable to the activity.
EPA — what “pesticide” means
Open EPA definition →
EPA pesticide-container guidance and refillable-container flow charts
Open EPA guidance →
40 CFR Part 165, Subpart C — refillable-container design
Open current eCFR →
40 CFR Part 165, Subpart D — pesticide repackaging
Open current eCFR →
40 CFR Part 165, Subpart E — federal containment structures
Open current eCFR →
Washington WAC 16-229 — bulk-pesticide containment
Open current Washington rule →
This page provides general education, not legal advice or a pesticide-specific packaging determination.
Container configuration