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Cleaner or pesticide

Staying a cleaner on purpose

Updated

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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.

References

US Environmental Protection Agency. Determining If a Cleaning Product Is a Pesticide Under FIFRA. A cleaner that claims to clean and degrease is not a pesticide; the same product claiming to kill germs is. The claim triggers it, not the chemistry. epa.gov
Federal Hazardous Substances Act and 16 CFR Part 1500, which require cautionary labeling on household products containing hazardous substances: the signal word, the hazard, precautionary measures, first aid and the instruction to keep out of reach of children. ecfr.gov
Poison Prevention Packaging Act, 16 CFR 1700.14, Substances requiring special packaging. Thresholds relevant to household cleaners include sodium and/or potassium hydroxide at 2 percent or more in liquid (10 percent dry), methyl alcohol at 4 percent, sulfuric acid at 10 percent, turpentine at 10 percent, and nonemulsion liquid furniture polish with 10 percent or more petroleum distillates below 100 SUS. ecfr.gov
California Cleaning Product Right to Know Act of 2017 (SB 258). Designated products — air care, automotive, general cleaning, and polish or floor maintenance products — must disclose ingredient information on the product website from January 1, 2020 and on the label from January 1, 2021. leginfo.ca.gov
Written from the federal regulation and agency guidance named on each page, not from a laboratory or a legal practice. Whether a particular product and a particular label make a cleaner or a pesticide is a determination about your product, and this is not that determination.