What goes wrong

The claim was wrong

On this page11

A chemical treatment described as a device Registration assumed to be the only duty The establishment was never registered Log reduction numbers printed from memory A microbiological claim with no basis at all Biodegradable asserted for a camp soap A packaging bottle sold for fuel A jar described as bear resistant Leakproof claimed rather than tested The fix in every case References

A substance sold as a device is an unregistered pesticide.

A chemical treatment described as a device

A device is an instrument or contrivance. A chemical that destroys the organism is a pesticide, and selling it without registration is not a labeling error.

Registration assumed to be the only duty

Which gets the device case backwards. Labeling, establishment registration, books and records and child resistant packaging all survive the registration exemption.

The establishment was never registered

A small maker assembling filters is producing devices at an establishment, and section 7 reaches the place rather than the product.

Log reduction numbers printed from memory

The commonly cited figures come from an EPA guide standard rather than a codified rule. Printing them as though they were a legal threshold lends them authority they do not have.

A microbiological claim with no basis at all

Which is the version that gets enforcement attention. If the claim is about organisms, it is a FIFRA claim.

Biodegradable asserted for a camp soap

A measurable property with test methods behind it, not a word that comes free with a green label. Either there is a result or there is not.

A packaging bottle sold for fuel

Which is the one claim this catalog could make and should not. A fuel bottle is a pressure-rated object and nothing on this shelf is one.

A jar described as bear resistant

Certified bear-resistant containers are tested objects, and food storage orders are issued locally. Nothing here is one and nothing here should suggest it is.

Leakproof claimed rather than tested

The archetype says leakproof under pressure change is the whole requirement. That is a test result, and a claim made without running it is the same error in miniature.

The fix in every case

Say what you can show. For this craft that means a liner specification, a pressure test you actually ran, and silence on everything else.

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 archetype behind this shelf is store-liquid-decant: 15 to 120 mL, narrow mouth, flip top or disc top or lotion pump or fine mist, PET and HDPE, cold fill, thin, aqueous, poured, with "travel decant, leakproof under pressure change is the whole requirement" as its stated reason. All seven leaves sit on it, including fuel decant and fire starter, which are neither aqueous nor cold.

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.