A repellent is a pesticide

Why a repellent counts

A product intended to repel a pest is a pesticide under the federal scheme, whether it kills anything or not. Repelling is a pesticidal purpose, which catches people who assume the word applies only to things that kill.

Registration, and what the number means

EPA describes a registration number as meaning the company provided the agency with technical information on the safety of the product and its effectiveness against mosquitoes or ticks. It is on the label, and it is checkable against the agency’s own database.

One registration, several names

EPA notes that a single registered product may be sold under multiple product names, which is why the registration number rather than the brand is the thing to look up. That is also a route for a small brand: selling a product registered by somebody else.

It is a different kind of undertaking

Registration involves data on safety and efficacy, and it is a substantial process rather than a filing. For most small makers the realistic routes are the minimum risk exemption or selling somebody else’s registered formulation.

The label is a pesticide label

Which has its own content and its own conventions, quite unlike a Drug Facts panel or a cosmetic ingredient list. A maker moving from cosmetics into repellents is learning an entirely new labeling vocabulary.

State registration may apply too

Several states require their own registration for pesticide products sold there, on top of the federal one. That is a per-state question and it is worth asking early if you intend to sell nationally.

The agency difference is cultural as well as legal

Pesticide regulation speaks in actives, percentages and registration numbers rather than in panels and claims substantiation. A cosmetic maker entering it finds the documents unfamiliar in form as much as in content, which is worth budgeting time for.

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