Mask, neutralise or kill
On this page10
Masking
Covering an odour with a stronger pleasant one. It is what most room sprays do, it makes no claim about the source, and it keeps the product a consumer product rather than anything else.
Neutralising
Chemically binding or altering odour molecules so they are no longer perceived. Still not a claim about an organism, still not a pesticide, and a more defensible marketing position than masking.
Killing
Any claim about bacteria, mould, mildew, viruses or germs. That makes the product a pesticide under FIFRA, requiring registration and an approved label before it may be sold.
The phrasing that catches people
"Eliminates odour-causing bacteria" is the standard line in this category and it is a pesticidal claim. So is "sanitises fabric". So is a mould claim on a closet freshener.
Intended use again
As everywhere in this library, the claim is read from the whole presentation: the label, the product page, the photography and the answers you give. A careful label with an uncareful website is not a careful product.
Where this leaves a small maker
Masking and neutralising are entirely available and need no registration. They are also the honest description of what a scented water or alcohol spray actually does.
Fabric refreshers are the riskiest leaf
Because the customer problem is a smell in fabric that comes from bacteria, and saying so is natural. The product can solve the problem without making the claim.
Say what it does, specifically
A scent that reads as clean linen, a neutraliser that binds cooking odours, a spray for a gym bag. Specific and honest beats a vague claim that edges toward pesticidal language because it has nothing concrete to say.
And write the copy once, for everywhere
The label, the listing, the website and the market stall sign should say the same thing. Divergence between them is how a compliant label ends up attached to a non-compliant claim.