Device or pesticide

What survives the exemption

On this page11

Labeling survives Which is the one people assume went away Establishment registration survives Which catches small makers Books and records survive Import and export survive And child resistant packaging survives With inspection and enforcement Read the list as four duties, not one exemption What a container supplier can help with References

Exempt from registration is not exempt from the label. Two of the surviving duties are packaging duties.

Labeling survives

A device remains subject to FIFRA section 2(q)(1) and 40 CFR part 156. The misbranding provisions and the labeling rules apply in full.

Which is the one people assume went away

It did not. The registration review went away; the requirement that the label be truthful, complete and not misleading did not.

Establishment registration survives

"FIFRA sec. 7 and part 167 of this chapter, with respect to establishment registration and reporting." The place where the device is produced has to be registered even though the device does not.

Which catches small makers

A one-person operation assembling filters is producing devices at an establishment. That is a registration and a reporting obligation with nothing to do with the product itself.

Books and records survive

"FIFRA sec. 8 and part 169 of this chapter, with respect to books and records." Which means production and distribution records, kept.

Import and export survive

"FIFRA sec. 17, with respect to import and export of devices." A device brought in from overseas is inside that section.

And child resistant packaging survives

FIFRA sec. 25(c)(3) is on the list. Which is a packaging requirement sitting inside the device provisions, and it is the second reason this property is in a container catalog.

With inspection and enforcement

FIFRA sections 9, 12, 13 and 14. The enforcement machinery applies to devices, so the exemption is from one requirement rather than from the regime.

Read the list as four duties, not one exemption

Label it properly, register the establishment, keep the records, and package it to the child resistant requirement where it applies. None of those is a section 3 registration and all of them are real.

What a container supplier can help with

Two of the four: the label surface and the closure. 18 child resistant closures on this shelf, which is a small set and the relevant one.

References

40 CFR 152.500. A device is "any instrument or contrivance (other than a firearm) intended for trapping, destroying, repelling, or mitigating any pest", excluding equipment used for the application of a pesticide when sold separately. Devices are not required to be registered under FIFRA section 3, but remain subject to FIFRA sec. 2(q)(1) and 40 CFR part 156 for labeling; "FIFRA sec. 7 and part 167 of this chapter, with respect to establishment registration and reporting"; "FIFRA sec. 8 and part 169 of this chapter, with respect to books and records"; "FIFRA sec. 17, with respect to import and export of devices"; and to FIFRA sec. 9 inspection, sec. 12, 13 and 14 enforcement, sec. 25(c)(3) child resistant packaging and sec. 25(c)(4). law.cornell.edu

The Davis Pack Supply catalog, measured 18 October 2026. The camping and backpacking shelf is 979 rows: 453 containers and 526 closures. 15 mL to 500 mL with a median of 177; 8 containers at 15 mL or under, 27 at 30 or under, 86 at 60 or under, 189 at 120 or under, 394 at a pint or under. 201 PET, 126 HDPE, 76 PP, 50 glass. 221 bottles, 218 jars, 12 tubs and pails, 1 jug, 1 tube. 134 white, 114 clear, 66 natural, 52 amber. Closures: 369 continuous thread, 26 dome lids, 26 spouted, 19 flip top, 19 lug and twist, 18 child resistant, 11 liners and sealing discs, 9 phenolic, 7 spice caps, 7 buttress, 6 round tubs, and no disc tops, lotion pumps or fine mist sprayers.

Written from 40 CFR 152.500 and from the catalog as it stood on 18 October 2026. No log-reduction performance figures appear anywhere in this property, because the commonly cited numbers come from an EPA guide standard rather than a codified rule. Forest and park food storage orders are issued locally and are not summarized. Nothing here is a fuel bottle or a bear-resistant container.