Can you make and sell citronella candles?
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Yes, and your words decide the law. Sold as an outdoor scented candle, a citronella candle is a candle. The moment its label, listing or photos say or suggest it repels mosquitoes or other pests, it is a pesticide under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and it must be registered with EPA unless it meets every condition of the minimum risk exemption in 40 CFR 152.25(f), often called 25(b). Even then, states may require their own registration; Maine's Board of Pesticides Control voted unanimously on July 10, 2026 to accept a policy requiring registration of citronella candles with 3 percent or more citronella. This page sets out both routes and wording that keeps a candle a candle.
When a candle becomes a pesticide
CandleScience, quoting EPA, explains that a pesticide is "any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest," and that citronella candles "are only regulated by the EPA if they're sold using pesticide claims" [1]. A claim does not need the word "repel." CandleScience gives "bug off, fly away, or mosquito finito" as examples EPA treats as pesticide claims, and says images of pests or pest habitats can count too [1]. Selling an unregistered pesticide can bring EPA enforcement, including notices of warning and civil penalties [1].
So you have three choices:
| Route | What it takes | Who it suits |
|---|---|---|
| Sell a citronella-scented candle with no pest claims | Candle rules only; careful wording everywhere you sell | Most small makers |
| Meet every minimum risk (25(b)) condition and make limited pest claims | Exempt from EPA registration; ingredient, label and claim conditions; state registration where required | Makers willing to restrict ingredients and register by state |
| Register the product with EPA as a pesticide | Full federal registration | Beyond the scope of a small candle business |
The minimum risk conditions, one by one
EPA's page on the minimum risk exemption lists six conditions a product must meet (last updated August 31, 2026) [2]. The regulation itself is 40 CFR 152.25(f) [3].
| Condition | What it requires | What it means for a candle |
|---|---|---|
| 1. Active ingredients | Only those listed in Table 1 of 152.25(f)(1) [2][3] | "Citronella" is listed in Table 1, as are lemongrass oil, geraniol, cedarwood oil, peppermint oil and others [3] |
| 2. Inert ingredients | Only those permitted by 152.25(f)(2): listed specific substances (Table 2), commonly consumed foods, animal feed items and edible fats and oils under 40 CFR 180.950 [2][3] | Every other ingredient in the candle, including each component of any fragrance oil and dye, must be permitted |
| 3. Ingredients on the label | All ingredients listed; actives by label display name with their percentage by weight; inerts by label display name [2][3] | A full ingredient list on the candle label |
| 4. No public health claims | No claims to control organisms that threaten human health; linking a pest to a disease is prohibited [2] | EPA: "controls mosquitoes" is acceptable; "controls mosquitoes that can transmit malaria, encephalitis, West Nile virus or the Zika virus" is not [2] |
| 5. Company name and contact | Producer's name, or "Packed for," "Distributed by" or "Sold by" a named company, prominently on the label, with street address, ZIP code and telephone number [2][3] | More contact detail than an ordinary candle label carries |
| 6. No false or misleading statements | EPA's examples include "Chemical-free," "Kills all insects" and "Recommended by EPA as safe and exempt"; website and advertising are also covered [2] | Your listing copy counts, not only the label |
What Tables 1 and 2 contain for a candle maker
| Ingredient | Listed? (40 CFR 152.25(f), eCFR up to date as of October 19, 2026) [3] |
|---|---|
| Citronella | Table 1 (active) |
| Lemongrass oil, geraniol, cedarwood oil, peppermint oil, clove oil, rosemary oil, thyme oil, cinnamon oil | Table 1 (active) |
| Paraffin wax | Table 2 (inert) |
| Hydrogenated soybean oil | Table 2 (inert) |
| Beeswax | Table 2 (inert) |
| Carnauba wax | Table 2 (inert) |
| Stearic acid | Table 2 (inert) |
| Cotton | Table 2 (inert) |
| Coconut oil | Not in Table 2; edible fats and oils are a separate permitted category under 180.950(c), so ask EPA whether your coconut wax qualifies |
| A blended fragrance oil | Only if every component is on Table 1 or permitted as an inert; ask your supplier for the full composition and check each one |
Two practical consequences. First, an ordinary candle fragrance oil is a blend whose components you probably cannot see, so a 25(b) citronella candle usually means citronella and other listed oils alone. Second, a retailer protocol shows how buyers check this: Kohl's candle protocol 100-Z (February 2025) says minimum risk products must not show an EPA registration or establishment number, and asks the manufacturer for a California Registration Certificate for citronella candles, exempting one whose only inert ingredient is paraffin wax [4]. That is one buyer's requirement. California's own rule, from its Department of Pesticide Regulation, is that a 25(b) product which does not meet the state's exemption criteria must be registered; the row on state rules that apply to candles gives the source, and DPR can tell you whether your candle qualifies.
States: registration even when EPA exempts
EPA says that exempt products do not need EPA registration, but "states may require registration under state laws" [2], and that "The states are not required to permit the sale of an exempted product simply because it is exempted" [5]. CandleScience gives the same warning: "states are not required to honor Minimum Risk Pesticide exemptions" [1].
Maine is a current example. A staff memo to the Maine Board of Pesticides Control, dated July 10, 2026, proposed a framework for registering 25(b) citronella candles [6]:
| Product (Maine proposed policy) | Registration | Efficacy data |
|---|---|---|
| More than 3% citronella, no claims | Yes | No |
| More than 3% citronella, "soft" claims (non-specific marketing or performance claims about a pest) | Yes | No; accepted on EPA's 3% active ingredient justification |
| More than 3% citronella, explicit repellency claims | Yes | Yes; must meet the AAPCO 75% threshold |
| Less than 3% citronella, or labeled "not for repellency" | No | No |
The memo's text also says registration is required "for products with 3% or more citronella" [6], so neither document settles a candle at exactly 3 percent; ask the Board. The Board's minutes record a motion "to accept proposed policy," carried unanimously, on July 10, 2026 [7]. Neither document gives an effective date or fee. If you sell into Maine, or any state, ask that state's pesticide regulator before you ship. The other state rules that reach candles are in one table on state rules that apply to candles.
Wording that keeps a candle a candle
From CandleScience's labeling guidance [1]:
| Use | Avoid |
|---|---|
| The word "citronella" in the product name | "Repels," "keeps bugs away," "mosquito-free" |
| Settings: "backyard, camping, patio, poolside, or garden," or "outside or outdoors" | Names like "bug off," "fly away" or "mosquito finito" |
| Mood words: "lighthearted, fun, and uplifting" | Pictures of mosquitoes, insects or swamps |
| Stories of summer evenings and gatherings | Any claim, anywhere you sell, that implies pest control |
Check every place the candle appears: the label, the listing title and description, product photos, hashtags and market signs. EPA treats website and advertising materials as part of a minimum risk product's claims [2], and a listing that says "keeps mosquitoes away" makes the same pesticide claim a label would. Naming your candles and your brand covers scent names more generally.
Making the candle itself
A citronella candle is still a candle: wick it, test it and label it as any other (from a candle you like to a product you can sell). Citronella oil is an essential oil, so its load comes from your wax's limit and the oil's IFRA certificate, not from a pest claim (essential oils in candles). Outdoor candles burn in wind, which changes flame height and soot; burn test outdoors as well as in, and keep the usual fire safety warnings on the label. If the candle has a metal-cored wick, the lead rule applies as for any candle (lead in wicks).
Where the state rules live
Citronella registration is one of a handful of state rules that reach candles, alongside California's Proposition 65 and Minnesota's PFAS reporting. State rules that apply to candles keeps them in one dated, sourced table.
References
- CandleScience, Citronella Candles: Labeling Guidance and Marketing Tips, undated, read October 22, 2026. https://www.candlescience.com/citronella-candles-labeling-guidance-and-marketing-tips/
- U.S. Environmental Protection Agency, Conditions for Minimum Risk Pesticides, last updated August 31, 2026. https://www.epa.gov/minimum-risk-pesticides/conditions-minimum-risk-pesticides
- 40 CFR 152.25, Exemptions for pesticides of a character not requiring FIFRA regulation, paragraph (f) and Tables 1 and 2 (eCFR), up to date as of October 19, 2026. https://www.ecfr.gov/current/title-40/chapter-I/subchapter-E/part-152/subpart-B/section-152.25
- Kohl's, Private Brands Performance Claims Test Protocol 100-Z: Candle (including freestanding, taper, tealight, votive, filled and novelty candles), revised February 2025. https://link.kohls.com/content/dam/klink/100-Z-CANDLE.pdf
- U.S. Environmental Protection Agency, State Regulation of Minimum Risk Pesticides, last updated September 23, 2026. https://www.epa.gov/minimum-risk-pesticides/state-regulation-minimum-risk-pesticides
- Julia Vacchiano, Pesticide Registrar, memo to the Maine Board of Pesticides Control, Proposed Policy Framework for 25(b) Citronella Candle Registration and Soft Claims, July 10, 2026. https://www.maine.gov/DACF/php/pesticides/documents2/bd_mtgs/Jul26/4_Proposed_Citronella_Candle_Reistration_Policy.pdf
- Maine Board of Pesticides Control, Minutes of the July 10, 2026 meeting (in the August 2026 meeting materials). https://www1.maine.gov/DACF/php/pesticides/documents2/bd_mtgs/Aug26/3_Jul26_Min_FINAL.pdf
