Can I sell a natural disinfectant as a 25(b) minimum risk product?
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No. The minimum risk exemption in FIFRA section 25(b) does not cover germ claims, whatever the ingredients. EPA's conditions say a minimum risk product "may not claim to control any microorganism (such as viruses, bacteria, spores, algae, etc.) that could lead to infection or disease in humans," and give "Sterilize," "Disinfect," "Sanitize" and "Kill germs" as barred examples [1]. A thyme oil or vinegar "disinfectant" is either EPA-registered or an unregistered pesticide. What 25(b) does allow is narrower: a product made only from listed ingredients, labeled to six conditions, that makes non-public-health claims such as killing odor-causing bacteria. This page sets out those conditions as EPA states them (updated August 31, 2026) and the regulation behind them.
Where the exemption comes from
The exemption is written into 40 CFR 152.25, which covers pesticides that EPA has "determined to be of a character not requiring regulation under FIFRA, and are therefore exempt from all provisions of FIFRA when intended for use, and used, only in the manner specified" [2]. Paragraph (f) of that section, headed "Minimum risk pesticides," holds the ingredient lists and the conditions [2].
Two things follow from that wording. A qualifying product is exempt from federal registration, so it carries no EPA registration number. And the exemption holds only "when intended for use, and used, only in the manner specified" [2]. A product that misses any one condition is an unregistered pesticide.
The six conditions
EPA's conditions page groups the requirements into six. All must be met [1][2].
| EPA's condition [1] | What the regulation says [2] | What it means for a cleaning product |
|---|---|---|
| 1. Active ingredients | Actives must be those listed in table 1 of 152.25(f)(1) | Your active ingredients come from a closed list. Vinegar is not on it |
| 2. Inert ingredients | Only the inerts listed in 152.25(f)(2)(i) through (iv) | Everything else in the bottle, water and soap included, must also be on an approved list |
| 3. Ingredients listed on label | "Each product containing the substance must bear a label identifying the label display name and percentage (by weight) of each active ingredient," and must list all inerts by label display name | Full ingredient disclosure, with active percentages |
| 4. Health-related claims | "The product must not bear claims either to control or mitigate microorganisms that pose a threat to human health, including but not limited to disease transmitting bacteria or viruses" | No germ, sanitizing or disinfecting claims |
| 5. Company name and contact information | The producer's name, or the company it was produced for qualified by wording such as "Packed for," "Distributed by" or "Sold by"; contact information "including the street address plus ZIP code and the telephone phone number" (wording as in the regulation); "displayed prominently" | Your name, full street address and phone number on the label |
| 6. Label statements | "The product must not include any false and misleading labeling statements, including those listed in 40 CFR 156.10(a)(5)(i) through (viii)" | No misleading statements, including the eight examples in 156.10(a)(5)(i) to (viii): composition, effectiveness, other value, comparisons, implied federal endorsement, names that suggest only some actives, true statements used to mislead, and disclaimers [8] |
Condition 1: the active ingredient list
The regulation's table 1 lists these active ingredients, by label display name [2]:
Castor oil; cedarwood oil; chitosan; cinnamon; cinnamon oil; citric acid; citronella; citronella oil; cloves; clove oil; corn gluten meal; corn oil; cornmint; cornmint oil; cottonseed oil; dried blood; eugenol; garlic; garlic oil; geraniol; geranium oil; lauryl sulfate; lemongrass oil; linseed oil; malic acid; peppermint; peppermint oil; 2-phenylethyl propionate; potassium sorbate; putrescent whole egg solids; rosemary; rosemary oil; sesame; sesame oil; sodium chloride; sodium lauryl sulfate; soybean oil; spearmint; spearmint oil; thyme; thyme oil; white pepper; zinc.
Several cleaning ingredients are there: citric acid, sodium lauryl sulfate, thyme oil, clove oil, peppermint oil, rosemary oil and lemongrass oil. Being on the list does not make any of them a disinfectant. It only means a product built from them may claim the limited things condition 4 allows. Vinegar does not appear in table 1; it appears among the inert ingredients [2]. A vinegar product cannot use vinegar as its 25(b) active ingredient.
The regulation adds that "All listed active ingredients may be used in non-food use products," and that food can carry pesticide residues only for ingredients with tolerances or tolerance exemptions in 40 CFR part 180 [2]. That is the food-contact rule below.
Condition 4: what you may and may not claim about microorganisms
This is the condition that matters most for cleaners. EPA's page says "The label cannot bear claims to control or reduce microorganisms, such as bacteria or viruses, that pose a threat to human health" [1].
Barred
| Claim | EPA's reason [1] |
|---|---|
| "Sterilize," "Disinfect," "Sanitize," "Kill germs" | Listed examples of prohibited microorganism claims |
| "prevent infection," "stop the spread of germs and disease," "germ-free," "kill influenza" | Listed examples of prohibited claims |
| "mold remediation," "mold control" | EPA says they imply "sterilization and disinfection" |
| Use at hospitals, nursing homes, medical or health care facilities | EPA says such use "would typically be considered to imply control or mitigation of microorganisms that may pose a threat to human health" |
Allowed, with conditions
EPA says "Some types of claims regarding microorganisms can meet the conditions of the minimum risk exemption," where the organism "would not normally lead to infection or disease in humans" [1]:
| Claim EPA allows [1] | Condition |
|---|---|
| "kill odor-causing bacteria," "neutralize and remove odors" | "A claim to clean non-food-contact surfaces or to kill odor-causing bacteria on non-food-contact surfaces is acceptable" |
| The same claims on food contact surfaces "such as countertops and sinks" | Only if each ingredient has "the appropriate tolerance or tolerance exemption" |
| Control of bacteria that cause "spoilage, deterioration, or fouling of materials" | Protects materials and makes no health claim |
| Control of algae growth in sites such as "fish tanks or ornamental ponds" | Named non-health sites |
| "clean or remove mold stain" | Stain only, never mold control |
Odor-causing bacteria is the one claim that separates a 25(b) product from a plain cleaner. A product that is not a qualifying 25(b) product cannot make it, because EPA treats controlling "bacteria or other pests that cause odors" as a pesticidal claim [3]. A plain cleaner can still say "removes odors" or "deodorizes" [3]; see what to say instead.
Condition 6: words that are false or misleading
EPA's page gives examples of label statements that break condition 6 [1]:
- Composition claims. "Chemical-free": EPA says the term "may be an attempt to convey that the product does not pose risk," but "is not based on facts and may be considered false or misleading."
- Effectiveness claims. "Kills all insects" and "Kills many insects" may "imply a misleading range of effectiveness."
- Government endorsement. "Recommended by EPA as safe and exempt." EPA says this kind of statement "leads the consumer to believe that the federal government has made such a determination," and that "Because EPA does not review exempted products, this type of statement is misleading."
- Safety symbols and terms. A caduceus or medical seal of approval, and terms EPA says imply safety, including "clinically proven," "scientifically proven" and "certified germ killer."
"Non-toxic" is not one of the examples on EPA's conditions page, but do not rely on that. EPA's 2024 settlement with U.S. Jaclean called "non-toxic and safe" "false or misleading language under FIFRA" [4], Oregon lists "non-toxic," "chemical-free" and "pesticide-free" as claims that are not acceptable for 25(b) products [5], and Connecticut says "Non-toxic claims are not acceptable" [6]. Oregon also requires any safety claim on a 25(b) label to be qualified with "when used as directed" [5]. The reason the federal text is less direct: condition 6 points to 156.10(a)(5)(i) through (viii), and the safety examples sit in the next two paragraphs, (ix) and (x), which name "Claims as to the safety of the pesticide or its ingredients, including statements such as 'safe,' 'nonpoisonous,' 'noninjurious,' 'harmless' or 'nontoxic to humans and pets'" and "Contains all natural ingredients" as misbranding for registered products [8]. Condition 6 still bars any false or misleading statement, which is the ground EPA used against Jaclean [4].
EPA does not review these products
Because the products are exempt, EPA does not look at them before sale. Its own page says "EPA does not review exempted products" [1]. That cuts both ways: no federal fee or wait, and no one to catch a mistake before an inspector or a state reviewer does. EPA has taken enforcement action where a product called itself minimum risk and claimed germ control. In a 2025 consent agreement, EPA found that a natural products company's antimicrobial product did not qualify, because its label and website claimed control of bacteria and viruses, and the company paid a $45,000 penalty [7]. More cases are on what happens if I make a germ claim without registration?.
States register 25(b) products
EPA notes that "states may require registration under state laws" [1]. Oregon and Connecticut are two that do. Oregon says "A 25(b) must be registered with ODA before it may be sold, offered for sale, or distributed in Oregon" and that the registration "must be renewed annually" [5]; Connecticut "requires registration of minimum risk pesticides under Connecticut state law" and asks for the label, an SDS and efficacy data if claims are made [6]. Requirements, fees and renewal cycles for every state are on pesticide and 25(b) registration by state.
A label check before you sell
- Every active ingredient is in table 1 of 40 CFR 152.25(f)(1), and every inert is on the permitted inert lists [2].
- Each active is listed by label display name with its percentage by weight, and every inert by label display name [2].
- No claim, direction, image or setting implies control of a microorganism that threatens human health, and nothing says sanitize, disinfect, sterilize, kill germs, mold control or mold remediation [1].
- Any odor-bacteria claim is limited to non-food-contact surfaces, or every ingredient has the right tolerance or exemption for food contact [1].
- Your company name, street address with ZIP code and telephone number appear prominently, with "Packed for," "Distributed by" or "Sold by" if you are not the producer [2].
- No "chemical-free," "non-toxic," EPA endorsement, "clinically proven" or medical symbol [1][4].
- Each state you sell into has registered the product if it requires registration [1][5][6].
If you need a germ claim
If the product has to say sanitizes or disinfects, 25(b) is the wrong route. The realistic options for a small brand are selling a registered product under your own label, covered on selling a registered product under your own brand, or registering a copy of an existing registered product, covered on what does it cost to register a disinfectant?.
References
- U.S. EPA, Conditions for Minimum Risk Pesticides, last updated August 31, 2026. https://www.epa.gov/node/64449
- Code of Federal Regulations, 40 CFR 152.25, Exemptions for pesticides of a character not requiring FIFRA regulation, via Cornell Legal Information Institute, read October 22, 2026. https://www.law.cornell.edu/cfr/text/40/152.25
- U.S. EPA, Determining If a Cleaning Product Is a Pesticide Under FIFRA, last updated July 6, 2026. https://www.epa.gov/pesticide-registration/determining-if-cleaning-product-pesticide-under-fifra
- U.S. EPA Region 9, EPA Settles with U.S. Jaclean Inc. over Sale of Unregistered Disinfectants, Purported Health Products, news release, October 6, 2024. https://epa.gov/newsreleases/epa-settles-us-jaclean-inc-over-sale-unregistered-disinfectants-purported-health
- Oregon Department of Agriculture, Registration of 25(b) Pesticides, undated, read October 22, 2026. https://www.oregon.gov/oda/Documents/Publications/PesticidesPARC/RegistrationOf25bPesticides.pdf
- Connecticut Department of Energy and Environmental Protection, 25(b) Pesticide Requirements, updated November 10, 2020. https://portal.ct.gov/-/media/deep/pesticides/25b-pesticide-requirements.pdf
- U.S. EPA Region 4, Consent Agreement and Final Order, In the Matter of CJH, Inc. d/b/a Ginesis Natural Products, docket FIFRA-04-2024-3020(b), 2025. https://yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings/91F00D41F671567285258C89006DB1ED/$File/CJH%20Inc%20dba%20Ginesis%20Natural%20Products%20CAFO%205-13-25%20FIFRA-04-2024-3020(b).pdf
- Code of Federal Regulations, 40 CFR 156.10, Labeling requirements, paragraph (a)(5), via Cornell Legal Information Institute (last amended 73 FR 75596, December 12, 2008), read October 22, 2026. https://www.law.cornell.edu/cfr/text/40/156.10
