Staying a cleaner on purpose
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For almost every small maker this is the right answer, and it should be a decision rather than an omission.
A legitimate and usually correct choice
A cleaning product that removes soil is a complete, honest, useful product. It is not a weaker version of a disinfectant.
Physical removal of soil is how cleaning actually works, it happens at the speed people clean, and it needs no registration, no efficacy data and no EPA number.
Deciding this in writing, before the label is designed, is what keeps the rest consistent.
What you still have to do
Staying out of FIFRA does not mean staying out of regulation. A cleaning product still faces:
Cautionary labeling under the Federal Hazardous Substances Act if it contains a hazardous substance, which most effective cleaners do.
Child-resistant packaging where the formula crosses a threshold in 16 CFR 1700.14.
Ingredient disclosure for designated products sold into California, on the website and on the label.
Truthful advertising, including the Green Guides for environmental claims.
So the choice removes one regime and leaves three.
What has to go
Disinfects, sanitizes, sterilizes. Kills germs, bacteria, viruses, and any percentage.
Antibacterial, antimicrobial, germicidal.
Kills mold and mildew, as opposed to removing the stains.
Any claim to protect a person from illness.
Any imagery or context that says the same thing without words.
And the category listing, which is where a compliant label most often gets undone.
Keeping it that way
Write the permitted language once and use it everywhere: label, website, listings, sell sheets, market signage, and the sentence whoever is staffing a stall says out loud.
Review it when anything changes: a new listing, a seasonal campaign, a new person writing your posts.
The failure is almost never a decision to make a pesticidal claim. It is a product that was a cleaner when it was designed and is being sold as something else a year later.