Is this for you at all
Updated
On this page8
What this covers
Bulk sanitizer, janitorial concentrate and dispensing systems. Three leaves, and the regulation divides them rather than the filling process does, which is why this property is organized around the rule instead of around the jug.
A sanitizer is a pesticide
EPA defines antimicrobial pesticides as substances used to destroy or suppress the growth of harmful microorganisms on inanimate objects and surfaces. A product that sanitizes or disinfects a surface is one, and it is registered under FIFRA.
And repackaging a registered product has five conditions
No change to the formulation, an EPA-registered refilling establishment, a written contract with the registrant, a container meeting the refillable container standards, and the registrant’s label unchanged except for net contents and your establishment number.
Missing any of them is a violation
Repackaging a pesticide product for distribution or sale without either obtaining a registration or meeting all of those conditions is a violation of section 12 of the Act, and both you and the registrant may be liable for it.
The container condition is the one we fail
A portable refillable pesticide container has to be designed, constructed and marked to a list of 49 CFR requirements. Nothing in our catalog carries that marking, so no container we sell is a refillable pesticide container within the rule.
Which leaves a real and honest use for this shelf
Janitorial concentrate that makes no antimicrobial claim, and reservoirs for dispensing equipment. Those are ordinary cleaning chemistry, and the 24 HDPE jugs here suit them well.
The claim is the cheapest thing to get wrong
A general purpose cleaner is not a pesticide. The same liquid described as sanitizing is. One word in a product description moves the whole regulatory position, and that is the subject of the concentrate section.