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Not the label and not the claim. The repackaging itself is what EPA regulates here.

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.

References

40 CFR 165.70, Refillers who are not registrants. Paragraph (b) sets the five conditions under which a registrant may let you repackage their product into refillable containers, including an EPA-registered refilling establishment and a written contract; paragraph (c) makes repackaging without them a violation of section 12 of the Act for which both you and the registrant may be liable. law.cornell.edu
40 CFR 165.45, Refillable container standards. Paragraph (a)(1) requires a non-DOT-hazardous pesticide in a portable refillable container to be designed, constructed and marked to comply with an enumerated list of 49 CFR requirements for a Packing Group III material, including parts 178 and 180; paragraph (b) requires full 49 CFR parts 171-180 packaging where the product is a DOT hazardous material. law.cornell.edu
United States Environmental Protection Agency, What are Antimicrobial Pesticides?, for products making claims about microorganisms on surfaces. epa.gov
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.