Certain products that meet the conditions of “Minimum Risk Pesticides” are exempt from registration with the EPA. This exemption is provided in 40CFR §152.25 and the EPA lists 6 Conditions that must be met.

Most importantly, the active and inert ingredients in the product must be included on the acceptable list of active ingredients and inert ingredients from Minimum Risk pesticides, 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.

While these products do not require registration with the EPA, there are 41 states where 25(b) Minimum Risk Pesticides need to be registered. KRK Consulting LLC can review 25(b) product labels and assist with state registrations.