Cleaners, and where the claim moves
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What a cleaner is
A product that removes wax, debris or soil, making no claim about pests, microorganisms or the treatment of a condition. It is not a pesticide and not a drug, and it is the bulk of what can honestly be packaged from these shelves.
The antimicrobial claim moves it
EPA describes antimicrobial pesticides as substances used to destroy or suppress the growth of harmful microorganisms. An ear solution claiming to kill bacteria or yeast has made such a claim, and registration follows.
The therapeutic claim moves it further
Treating otitis, healing a wound, relieving an infection: those are claims about treating a condition in an animal, which is the new animal drug description. The same bottle, two sentences, two statutes.
Wound spray is the most tempting
Because the use case invites it. Cleans the wound and helps it heal are two different claims, and the second is the one that needs an approval behind it.
The honest claims are plenty
Removes wax and debris, flushes the ear canal, cleans around a wound, leaves no residue, pH balanced for canine skin where that is supportable. All specific, all verifiable, and none of them a pest, microbial or treatment claim.
Owners will ask you the question directly
Which is the real pressure in this category. Answering what the product does rather than what the owner hopes it does is the discipline, and it has to reach whoever answers the phone and the emails.
Write the claim rules down
One page of what may and may not be said, with the reason beside each. The label gets reviewed and the customer-service reply does not, which is the same finding six other properties here reach.