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25(b) Products

(Exempt EPA Products)


The EPA has a program that does not subject pesticides to federal registration if the active and inert ingredients are “minimum risk” and are included on both the acceptable list of active ingredients and inert ingredients respectively. These products are allowed to make claims that they kill and repel their pests without registration, but they are not allowed to make public health claims or that they protect human health. For example, they can claim they kill mosquitoes, but the label cannot say that it prevents malaria by killing mosquitoes. Basically, there are four conditions that must be met to qualify for this program:

Condition #1 - The active ingredients must be one of the following:

Malic Acid

Mint and mint oil

Peppermint and peppermint oil

2-Phenethyl propionate (2-phenylethyl propionate)

Potassium sorbate

Putrescent whole egg solids

Rosemary and rosemary oil

Sesame (includes ground sesame plant) and sesame oil

Sodium chloride (common salt)

Sodium lauryl sulfate

Soybean oil

Thyme and thyme oil

White pepper

Zinc metal strips (consisting solely of zinc metal and impurities)

Castor oil (U.S.P. or equivalent)

Cedar oil

Cinnamon and cinnamon oil

Citric acid

Citronella and citronella oil

Cloves and clove oil

Corn gluten meal

Corn oil

Cottonseed oil

Dried Blood


Garlic and garlic oil


Geranium oil

Lauryl sulfate

Lemongrass oil

Linseed Oil

Condition #2
The inert ingredients must be classified as List 4A “Inert Ingredients of Minimal Concern” which can be found by clicking here.

Condition #3
All the ingredients must be listed on the label by name and percentage by weight.

Condition #4
The label must not make any human health or public health claims. Also, the labels cannot imply that the product has been reviewed or endorsed by the EPA. Therefore, the label cannot possess either a registration or an establishment number.

Though the U.S. EPA does not require registration, exempt 25(b) products are required to be registered in 40 states and the District of Columbia. And some of these states also have their own labeling and data requirements for these products. Therefore, before the final label is designed, please let KRK Consulting LLC review your label so that it will be acceptable for registration in all 40 states and the District of Columbia. Also, if you are interested in registering in any of the 40 states or the District of Columbia, please contact KRK Consulting LLC and indicate which states you are interested in registering and KRK Consulting LLC will contact you if registration is required in those states and the cost to do so.


Review Label for Exempt Product   $197

State Registration   $97 per state (plus applicable state fee)

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