State Regulatory Support:
Pesticides - Devices & Exempt Pesticides

Pesticide Devices

Pesticide devices are any instrument that uses physical or mechanical means for trapping, repelling, destroying or mitigating any pest, and does not contain any pesticidal substance or mixture of substances.

EPA does not require pesticide devices to be registered, but they are subject to some FIFRA provisions:

▲ Labeling requirements to prevent misbranding;

▲ Establishment registration, reporting and inspection;

▲ Violation, enforcement and penalties; and

▲ Import and export requirements.

However, even if a pest control device is not subject to

FIFRA registration

requirements, it may still be subject to

state registration

 or other regulatory requirements. Each state has its own statutes and regulations concerning pesticide and pest control device registration.

TSG’s state regulatory experts are highly knowledgeable of each state’s pesticide device regulations, helping companies comply with the unique device requirements found in every state.

Minimum Risk 25(b)

Minimum risk pesticides are pesticide products that meet certain criteria exempting them from federal registration under section 25(b) of FIFRA. They are a special class of pesticides that are not subject to federal registration requirements because their ingredients, both active and inert, are established as safe for the intended use. However, while EPA does not review or register pesticides that meet the 25(b) criteria, most states require registration. TSG’s state regulatory experts routinely work with minimum risk 25(b) pesticides, and are highly familiar with the regulations pertaining to them.

State map showing TSG expertise for pesticide devices and 25(b) productsOur consultants provide comprehensive registration services for 25(b) minimum risk pesticides, including label development and marketing claims compliance, registration application coordination and submission, and product maintenance. Once a product is registered, TSG’s product maintenance services include monitoring product status, preparing and submitting all documents required to renew registration, providing copies of all documentation for a company’s records, informing a company of upcoming regulatory changes that will affect its product, as well as assisting with label amendments or product defense issues as needed.
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