Do I have to register a pesticide or 25(b) product in my state, and what does it cost?
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Yes for any EPA-registered pesticide, which includes every disinfectant and sanitizer: each state registers pesticide products sold within it, on top of EPA's registration. In ISSA's 2019 survey the per-product state fee ran from $90 a year in Wyoming to $1,150 a year in California, with some states on two- or three-year cycles [1]. For minimum risk products under FIFRA 25(b), EPA's exemption is federal only, and EPA says "states may require registration under state laws" [2]. California (for certain products), Connecticut and Oregon confirm in their own documents that they do [3][4][5]. For most other states no official statement on 25(b) products has been confirmed, and the table marks them that way.
Two layers: EPA, then the states
A registered disinfectant has an EPA registration number. That number lets it be sold under federal law, but each state then requires its own product registration and annual or multi-year renewal before the product may be sold there. ISSA's 2019 survey of state requirements has a fee, agency and renewal date for all 50 states and the District of Columbia [1]. If you sell a registered product under your own brand as a supplemental distributor, the state registrations still have to be in place for your brand; see selling a registered product under your own brand.
A 25(b) product has no EPA number and no EPA review. The Association of American Pesticide Control Officials (AAPCO), whose members are the state regulators, puts the state side plainly: these products "are subject to registration by individual states," "States are not required to permit the sale of an exempted product simply because it is exempted," and "Each state may have different label and/or data requirements" [6]. AAPCO's May 2026 efficacy guidance tells makers to "contact the individual state regulatory agency responsible for pesticide registration" and says "Data must be included that supports all pesticidal label claims" [6].
No 25(b) product may claim to kill germs, in any state. EPA's label condition bars claims "to control or reduce microorganisms, such as bacteria or viruses, that pose a threat to human health" [2]. What 25(b) does allow is on minimum risk (25(b)) products.
What the confirmed states require for 25(b) products
| State | Requirement | Source and date |
|---|---|---|
| California | "Certain* 25(b) Minimum Risk Pesticides require registration"; example given: topical products with more than 1 percent citronella or citronella oil. A DPR flowchart decides the rest. Application needs data for every claim and a printed label for each version | DPR checklist, updated May 4, 2026 [3] |
| Connecticut | "Connecticut requires registration of minimum risk pesticides under Connecticut state law." Submit the application, label, SDS for each product and efficacy data if claims are made. Non-toxic claims not acceptable; "safe" only with "when used as directed" | DEEP, updated November 10, 2020 [4] |
| Oregon | Must be registered with the Department of Agriculture before sale (ORS 634.016), renewed annually. Submit the marketplace label and fee; no data currently required. Public health claims, "chemical-free," "pesticide-free" and "non-toxic" not acceptable | ODA, undated, read October 22, 2026 [5] |
Three more states appear in an industry comment letter: the Household and Commercial Products Association wrote to EPA on November 8, 2021 that Indiana, Maine and New Mexico, which EPA used for an inventory estimate, "have registration requirements beyond labeling" [7]. That letter is secondhand, so those states are marked as reported, not confirmed, below. The survey also gives Pennsylvania as requiring 25(b) registration, Wisconsin as requiring it with no fee, and Delaware as exempting 25(b) products from fees [1].
The fifty-state table
Read the columns this way. Agency, fee and cycle come from ISSA's 2019 survey [1]. They are a dated lead, seven years old in 2026, and must be confirmed with the agency; ISSA itself says fees and deadlines change and some entries are inconsistent [1]. 25(b) products gives the best source found: "Required" only where the state's own document says so; "Reported" where the source is the survey or the 2021 comment letter; "Not confirmed" where no source has been found. Every row was checked on October 22, 2026.
| State | Agency (2019) | Fee per product (2019) | Cycle (2019) | 25(b) products |
|---|---|---|---|---|
| Alabama | Dept. of Agriculture and Industries | $600 | Two years | Not confirmed |
| Alaska | Dept. of Environmental Conservation | $120 paper, $125 online | Annual | Not confirmed |
| Arizona | Dept. of Agriculture | $100 from July 1, 2019 | Annual or two years | Not confirmed |
| Arkansas | State Plant Board | $250 plus $50 disposal fee | Annual | Not confirmed |
| California | Dept. of Pesticide Regulation | $1,150 | Annual | Required for certain products [3] |
| Colorado | Dept. of Agriculture | $165 | Annual | Not confirmed |
| Connecticut | Dept. of Energy and Environmental Protection | Survey entry inconsistent ($188 and $940 both appear) | Survey entry inconsistent | Required [4] |
| Delaware | Dept. of Agriculture | $140 | Two years, July 1 | Reported exempt from fees [1] |
| District of Columbia | Dept. of the Environment | $250 | Annual | Not confirmed |
| Florida | Dept. of Agriculture and Consumer Services | $350 | Annual, Jan 31 | Not confirmed |
| Georgia | Dept. of Agriculture | $200 | Annual | Not confirmed |
| Hawaii | Dept. of Agriculture | $330 | Three years | Not confirmed |
| Idaho | State Dept. of Agriculture | $160, $165 online | Annual | Not confirmed |
| Illinois | Dept. of Agriculture | $600 per product or $800 per company | Two years | Not confirmed |
| Indiana | Office of Indiana State Chemist | $170 | Annual | Reported [7] |
| Iowa | Dept. of Agriculture and Land Stewardship | $250 minimum to $3,000, based on sales | Annual | Not confirmed |
| Kansas | Dept. of Agriculture | $150 antimicrobial | Annual | Not confirmed |
| Kentucky | Dept. of Agriculture | $250 | Annual | Not confirmed |
| Louisiana | Dept. of Agriculture and Forestry | $400 | Annual | Not confirmed |
| Maine | Board of Pesticides Control | $160 | Annual | Reported [7] |
| Maryland | Dept. of Agriculture | $110 | Annual | Not confirmed |
| Massachusetts | Dept. of Agricultural Resources | $300 | Annual, usually June 30 | Not confirmed |
| Michigan | Dept. of Agriculture | $370 ($100 plus $270 groundwater fee) | Annual, June 30 | Not confirmed |
| Minnesota | Dept. of Agriculture | $350 plus surcharges and sales-based fees | Annual | Not confirmed |
| Mississippi | Dept. of Agriculture and Commerce | $200 | Annual | Not confirmed |
| Missouri | Dept. of Agriculture | $150 | Annual | Not confirmed |
| Montana | Dept. of Agriculture | $233 | Annual | Not confirmed |
| Nebraska | Dept. of Agriculture | $160 per antimicrobial product | Annual | Not confirmed |
| Nevada | Dept. of Agriculture | $125 | Annual | Not confirmed |
| New Hampshire | Dept. of Agriculture, Markets and Food | $160 | Annual | Not confirmed |
| New Jersey | Dept. of Environmental Protection | $300 | Annual | Not confirmed |
| New Mexico | Dept. of Agriculture | $100 | Annual | Reported [7] |
| New York | Dept. of Environmental Conservation | $600 (sales up to $3.5 million) or $620, plus processing fees | Two years | Not confirmed |
| North Carolina | Dept. of Agriculture | $150 plus trust fund assessment | Annual | Not confirmed |
| North Dakota | Dept. of Agriculture | $350 | Two years | Not confirmed |
| Ohio | Dept. of Agriculture | $150 | Annual, June 30 | Not confirmed |
| Oklahoma | Dept. of Agriculture, Food and Forestry | $210 | Staggered | Not confirmed |
| Oregon | Dept. of Agriculture | $320 | Annual | Required, annual [5] |
| Pennsylvania | Dept. of Agriculture | $250 | Annual | Reported required [1] |
| Rhode Island | Dept. of Environmental Management | $200 | Annual, Nov 30 | Not confirmed |
| South Carolina | Dept. of Pesticide Regulation | $175 plus $3 online | Annual, Aug 31 | Not confirmed |
| South Dakota | Dept. of Agriculture | $120 | Annual, June 30 | Not confirmed |
| Tennessee | Dept. of Agriculture | $200 | Annual, June 30 | Not confirmed |
| Texas | Dept. of Agriculture | $600 | Two years | Not confirmed |
| Utah | Dept. of Agriculture and Food | $195 | Annual, June 30 | Not confirmed |
| Vermont | Agency of Agriculture | $175 | Annual, Nov 30 | Not confirmed |
| Virginia | Dept. of Agriculture and Consumer Services | $160, rising to $255 | Annual | Not confirmed |
| Washington | Dept. of Agriculture | $390 | Two years | Not confirmed |
| West Virginia | Dept. of Agriculture | $150 | Annual | Not confirmed |
| Wisconsin | Dept. of Agriculture | $500 | Annual | Reported required, no fee [1] |
| Wyoming | Dept. of Agriculture | $90 | Annual | Not confirmed |
Where no date is shown, the survey gives December 31 or no date. Late fees in the survey range from small flat amounts to doubling the fee [1].
Budgeting for state registration
Take the states you will sell into, look up each current fee with the agency, divide multi-year fees by the years they cover, and add them. Do this per product: a scent or size that the state treats as a separate product may need its own registration. The federal side (EPA's PRIA fees and timelines for a disinfectant) is on what does it cost to register a disinfectant?, and the start-up budget on what it costs to start.
Before your first shipment into a state
- Decide whether the product is a pesticide at all. A cleaner with no germ, odor-bacteria, mold or pest claim is not, and needs none of this; see when a cleaner becomes a pesticide.
- For a registered product, register it in each state before the first sale there, under the name on your label.
- For a 25(b) product, read the state's own requirements. Expect to submit the label and, in some states, data for each claim [3][4][6].
- Check the state's claim rules. Connecticut and Oregon both reject "non-toxic," and both require "when used as directed" on any safety claim [4][5].
- Diary the renewal dates. Most states in the 2019 survey renewed on December 31, but Delaware used July 1, Florida January 31, Massachusetts usually June 30, Michigan, Ohio, South Dakota, Tennessee and Utah June 30, South Carolina August 31, and Rhode Island and Vermont November 30 [1].
This page reports the sources as read on October 22, 2026, and is not legal advice. Confirm fees, cycles and 25(b) requirements with each state's pesticide regulatory agency.
What makes a product minimum risk
Whether a state registers a 25(b) product only matters once the product truly qualifies. The six conditions, the permitted ingredients and the claims allowed are on minimum risk (25(b)) products.
References
- ISSA, *2019 State Pesticide Registration Survey*, 2019, read October 22, 2026. https://korea.issa.com/wp-content/uploads/2019-Pesticide-Registration-Surveyv2.pdf
- U.S. EPA, *Conditions for Minimum Risk Pesticides*, last updated August 31, 2026. https://www.epa.gov/node/64449
- California Department of Pesticide Regulation, *Checklist for Certain 25(b) Minimum Risk Pesticide Registration*, updated May 4, 2026. https://www.cdpr.ca.gov/wp-content/uploads/2026/05/25b-minimum-risk-checklist.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
- Oregon Department of Agriculture, *Registration of 25(b) Pesticides*, undated, read October 22, 2026. https://www.oregon.gov/oda/Documents/Publications/PesticidesPARC/RegistrationOf25bPesticides.pdf
- AAPCO FIFRA 25(b) Workgroup, *FIFRA Minimum Risk Pesticides: 25(b) Product Efficacy Data Guidance*, publication date May 1, 2026. https://aapco.org/wp-content/uploads/2026/08/25b-Efficacy-Guidance-w-Publication-Date_5.1.2026.pdf
- Household and Commercial Products Association (Steven Bennett), comments to EPA on the information collection for minimum risk pesticide labeling under FIFRA 25(b), November 8, 2021. https://thehcpa.org/wp-content/uploads/2021/11/HCPA-Comments-25b-ICR-Comments1.pdf
