October 24, 2022


To:         U.S. Cotton Gins

From:    Chris Berry, Chairman


Attention Required – PBI Management, Sampling and Packaging Performance


New educational material has been developed to reflect the best management practices of PBI tag placement and usage, as well as best sampling methods to prevent instances of mismatched tags.

The attached PBI Management document outlines the proper placement of PBI and safety tags on bales. These tags should be placed on the front and back of the rounded side of the bale between the first and third bale strap below the head closures. PBI tags should never be placed on the heads, feet or flat sides of the bale. Additionally, placing PBI or other tags under bale bagging and against the cotton in a bale is not acceptable, even when clear bagging is used. These practices can cause the tag to become lost or hinder the warehouse’s ability to scan the barcodes.

Securing PBI or other tags to bale bags using fine wire or metal fasteners is strongly discouraged. These small wires, if not removed completely, can cause serious damage to mill equipment, pose a fire hazard, and contaminate the cotton. The JCIBPC’s “A Guide for Cotton Bale Standards” is available to reference the differences between grade A, grade B, and unacceptable bales.

While there were significant improvements made during the 2021 crop, instances of mismatched PBI tags and sample coupons continue, despite extensive communications efforts conducted during the ginning season by the USDA Agricultural Marketing Service (AMS) Cotton and Tobacco Program, the National Cotton Council and others, as seen in the attached letter.

Mismatching incidents often involve PBI tags from one roll and sample coupons from a separate roll where all numbering series digits were not matched when one or both rolls were changed. Additionally, there have been instances when gins start the season with a PBI number that was used in the previous year, leading to duplicate number errors. In each of these cases, AMS has confirmed that the tag mismatches and duplications involved gins with automatic baggers. Even when gins rely on traditional PBI tags that have the AMS sample coupon attached to the bottom of the tag, mismatches may occur if proper sample handling/bale tagging procedures are not followed.

A Cotton Sampling Procedures poster was developed jointly by the USDA and NCC and was distributed to all U.S. gins earlier in the summer. This poster outlines the minimum standard for cotton sampling procedures. Gins wanting to use paper sleeves may do so if the submitted sample meets the other requirements as outlined on the poster. A copy of this poster is attached for your reference.

A new online form is now available to report packaging material performance or incidents where packaging materials failed to meet gin, warehouse or mill expectations. This tool will electronically log any issues submitted and send this report directly to the NCC for review. It should take less than five minutes to complete the report and is available to all gins and warehouses. Please use the following link to open the Bale Tie and Bag Incident Reporting Form. 

Continued communication between gins and warehouses is extremely important in mitigating many of the issues outlined above. In addition, relating to fire safety, it is important to let your warehouse know if you have a fire or hot bale. That bale or group of bales should be set aside to ensure that they no longer pose a potential hazard. The warehouse should then be notified that these bales had been suspect and monitored.

If you have questions or need additional information, please contact Lauren Krogman from the National Cotton Council at lkrogman@cotton.org or 901-274-9030.


PBI Management Flyer
2022 Mismatch PBI Letter
Cotton Sampling Procedures Poster