Buy a full case and the price per unit drops automaticallyRequest a sample
AccountCart0
All ContainersBottlesJarsCaps & ClosuresPumps & SprayersTubs & PailsJugsDroppersTinsTubesAccessories
Industries
Personal CareShop all 934 items →
AromatherapyBathBath →Body careBody care →Color cosmeticsColor cosmetics →DeodorantDeodorant →FragranceFragrance →GroomingHair careLip careLip care →NailNail →Oral careOral care →Skin and faceSkin and face →Soap and washSoapmaking →Sun and protectionSun and protection →
Learn:BathBody careColor cosmeticsDeodorantFragranceLip careNailOral careSkin and faceSoapmakingSun and protectionEverything we have written →
Learn
Beekeeping100Hot sauce making90Jam and preserves96Pickles and ferments64Sauces and condiments36Syrups36Oils and vinegars34Nut butters and spreads33Dairy and alternatives33Coffee and tea36Confection31Resin and casting27Supplement liquids23Laboratory17Dispensing13Photography and darkroom14Industrial chemical14Prepared and deli15Body care14Color cosmetics13Bath14Pet health15Toiletry decanting14Oral care14Capsules and tablets14Nail14Fragrance15Deodorant17Fossils16Janitorial16Baking and dry goods16Seed storage17Specimens16Paint and ink18Automotive fluids18Wax melts17Diffusers17Detailing15Sun and protection18Dish and hand16Soapmaking91Candle making93Beverages92Cleaning products92Lip care89Minerals and rocks93Powders91Skin and face91Spices and seasoning91Findings and components16
All 1,895 pages we have written →
Janitorial
All Containers›Shop by use case›Janitorial›Repackaging a pesticide›A sanitizer is a pesticideShop all janitorial →
Repackaging a pesticide

A sanitizer is a pesticide

By Dwight Davis, Founder

Updated

On this page9
The word on the bottle decides which statute you are under, and in this category the word is often added by marketing.

The definition

EPA describes antimicrobial pesticides as substances used to destroy or suppress the growth of harmful microorganisms on inanimate objects and surfaces. Sanitize, disinfect, sterilize, kills germs, antibacterial: each of those is such a claim.

What registration brings with it

An EPA registration number on the label preceded by "EPA Registration No." or "EPA Reg. No.", a producing establishment number preceded by "EPA Est.", an ingredient statement, hazard and precautionary statements, directions for use and a use classification.

Registration is a serious undertaking

With efficacy and safety data behind it. For most businesses the realistic path is to distribute somebody else’s registered product rather than to register one, and that is exactly the path the repackaging rules govern.

A cleaner is not a pesticide

Removes soil, cuts grease, lifts films, leaves no residue. All true, all sellable, and none of them a claim about microorganisms. The honest version of a janitorial cleaner competes perfectly well.

The line is crossed in the description, not the drum

The same concentrate sold as a degreaser and as a sanitizer is two different regulatory objects. Nothing changes in the container, and everything changes in what you are obliged to do.

Check everything published, not only the label

Listings, spec sheets, the website, a sales email. The label gets reviewed and the rest does not, which is where unregistered claims actually live, and the same lesson appears in three other properties here under three other statutes.

And a dispensing system does not change the answer

Equipment is equipment. The moment a reservoir holds a registered product, the container and labeling rules attach to what is in it, including the labeling requirement at the discharge control valve.

The registration number is the quick test

A registered product's label carries "EPA Registration No." followed by a number. If you are handling something that makes a microbiological claim and there is no such number anywhere on it, that is the whole answer and it took ten seconds to find.

References

United States Environmental Protection Agency, What are Antimicrobial Pesticides?, for products making claims about microorganisms on surfaces. epa.gov
40 CFR 156.10, Labeling requirements. Paragraph (a)(4) requires the label on or securely attached to the immediate container, defines securely attached as reasonably expected to remain affixed through the foreseeable conditions and period of use, and for bulk containers in the user’s custody requires a copy of the labeling in the immediate vicinity of the discharge control valve. Paragraph (a)(2)(ii) sets 6-point or larger type on a clear contrasting background; (e) and (f) cover "EPA Registration No." and "EPA Est.". law.cornell.edu
Written from federal regulation, not from a plant floor. FIFRA is administered by EPA and the states have their own pesticide programs on top of it. Nothing here is a registration, a contract or a finding that a container complies; those are the registrant’s, the lawyer’s and the container manufacturer’s to give.