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The line

What the marking tells you

Updated

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The quickest test takes ten seconds: look for the number.

The pesticide marking

A registered pesticide label carries the registration number preceded by "EPA Registration No." or "EPA Reg. No.", and the producing establishment number preceded by "EPA Est." Both are required label content under the EPA labeling rules.

Plus the rest of the required content

An ingredient statement, hazard and precautionary statements, directions for use and a use classification, all clearly legible and conspicuous enough to be read and understood by the ordinary individual under customary conditions of purchase and use.

The animal drug position

An approved animal drug is sold under an approval in effect for that use, with labeling that conforms to the approved application. There is no single short phrase to look for in the way there is for EPA, so the question is whether an approval exists and covers this use.

And the third outcome

A product making a pest or disease claim with no EPA registration number and no animal drug approval is unregistered or unapproved. That is not a lighter category, it is the absence of the thing the claim required.

Which makes it a useful supplier test too

If you are buying a bulk product to repackage, the absence of a registration number on a product with a flea claim tells you something about the supplier before any other conversation happens.

Repackaging a registered pesticide has its own rules

A written contract with the registrant, an EPA-registered refilling establishment, a compliant container and the registrant’s label unchanged. The Janitorial property sets those out in full, and they apply here identically.

So check the marking before the packaging

It decides whether you are packaging a product or repackaging a registered one, and those are completely different projects with different obligations.

References

40 CFR 156.10, the EPA pesticide labeling requirements, which require the product registration number preceded by "EPA Registration No." or "EPA Reg. No." and the producing establishment number preceded by "EPA Est.", along with an ingredient statement, hazard and precautionary statements, directions for use and a use classification. law.cornell.edu
7 U.S.C. 136(u), the FIFRA definition of pesticide, which covers substances intended for preventing, destroying, repelling or mitigating any pest and then excludes any article that is a new animal drug within the meaning of the Federal Food, Drug, and Cosmetic Act, or that has been determined not to be one by regulation, or that is an animal feed bearing or containing a new animal drug. law.cornell.edu
21 U.S.C. 360b(a)(1), which deems a new animal drug unsafe with respect to any particular use unless there is in effect an approval, a conditional approval, an index listing for a minor species or an authorization, and "such drug, its labeling, and such use conform" to it. law.cornell.edu
Written from federal statute, not from a veterinary bench. Which regime a specific product falls under is a determination about that product, and state feed and drug programs run alongside the federal ones. Nothing here is a registration, an approval, or advice on a particular formulation.