Two entirely different lists, and which one applies was decided the moment you wrote the label.
It depends on one answer
Cleaner or pesticide. There is no partial answer and no small-business version of the harder one.
As a cleaner
No product registration and no license. Nobody approves a cleaning product before it is sold.
What applies instead is continuous:
Labeling: consumer commodity requirements, plus cautionary labeling under the Federal Hazardous
Substances Act where the product contains a hazardous substance.
Child-resistant packaging where a formula crosses a threshold in 16 CFR 1700.14.
Ingredient disclosure online and on the label for designated products sold into California.
A safety data sheet if you supply for workplace use.
Truthful advertising, including the Green Guides.
Plus the ordinary business registration and sales tax.
As a pesticide
EPA product registration, with efficacy, chemistry and toxicology data.
An EPA establishment number for the facility.
An EPA-approved label carrying the registration number.
State pesticide registration in most states, each with a fee and an annual renewal.
None of that has a small-business exemption, and the cost lands before the first sale.
Doing it in the right order
Decide the regime. Write the label to it. Check the formula against the packaging thresholds. Build the
disclosure page. Then sell.
The failure is registering a business, writing "kills 99.9% of germs" on the bottle, and discovering the
order was wrong.
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.govUS Environmental Protection Agency.
Pesticide Registration Manual, Chapter 4: Additional Considerations for Antimicrobial Products. What an antimicrobial pesticide is, and what registration requires.
epa.govFederal 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.govPoison 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.govCalifornia 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.govOSHA Hazard Communication Standard, 29 CFR 1910.1200, which requires a safety data sheet and GHS labeling for hazardous chemicals supplied for workplace use.
osha.gov 