Determining If a Cleaning Product Is a Pesticide Under FIFRA -AMAZON PLEASE READ!
Seller support does not understand what qualifies as an EPA regulated pesticide, so I am posting this mostly for their information to train their departments better, but also for sellers to be armed with facts when dealing with the misidentification of pesticides when it comes to cleaning products.
Per the EPA:
Examples of Claims That the Agency Considers to be Pesticidal
Cleaning products with claims such as those described below are considered by the Agency to be intended for a pesticidal purpose because the claims imply or express that the product mitigates a pest, directly or indirectly, either by itself or by removing the pest’s food, food source or its habitat. These examples represent claims or types of claims for a cleaning product that would trigger a requirement to register the product under FIFRA.
- Cleans away, washes away or removes any pest covered by 40 CFR §152.5.
- Cleans away, washes away or removes biofilm or scum (unqualified).
- Cleans away, washes away or removes allergens (unqualified).
- Cleans away or removes allergens associated with a pest (e.g., dust mite allergens, cockroach allergens).
- Removes pests by suffocating or drowning.
- Cleans or removes pest habitats or breeding sites.
- Cleans, precipitates or removes contaminants, nutrients or matter that provide food or habitat for pests.
- Cleans, reduces or removes scum or sludge where pests breed, feed or live.
- Out-competes or displaces a pest for nutrition or habitat.
- Cleans or removes the habitat where biofilm, germs, allergens or microorganisms can hide, thrive or grow.
- Prevents, blocks, removes, neutralizes or controls bacteria or other pests that cause odors.
- Sanitizes, disinfects or sterilizes.
- Images of pests or pest habitats (e.g., nest, hive or web) that imply cleaning or removal of pest habitats, or of nutrition or sources of nutrition for pests.
- A banner, logo, design, header or any claim on a label or labeling, or through other means such as web sites, advertising, etc. that specifically links the cleaning product to pest control, Integrated Pest Management (IPM), pests or a specific kind of pest.
Examples of Claims That the Agency Considers are NOT Pesticidal
Cleaning products with claims such as those described below are generally considered by the Agency to not be intended for a pesticidal purpose. These cleaning products claim to remove dirt or other debris without any linkage to mitigating a pest, its food, food source, or its habitat. Many of these examples are similar to the examples in the previous section with the explicit linkage to a pest removed.
When not used in connection with other pesticidal claims or in a context where they imply pesticidal purposes, these examples represent claims, or types of claims, for a cleaning product that would not trigger a requirement to register the product under FIFRA.
- Cleans or removes stains.
- Cleans or removes stains from algae, mold, mildew or other non-public health organisms.
- Cleans or removes dirt, soil, dust, debris, inanimate scum, inanimate nutrients, inanimate organic particulates, or inanimate contaminants.
- Cleans a site (e.g., ponds, aquariums, etc.).
- Prevents, blocks, neutralizes, reduces, eliminates, encapsulates or removes odors; deodorizes.
- Cleans, reduces or removes sludge.
- Cleans or removes inanimate scum such as “soap scum.”
- Cleans, washes or prepares the surface for application of a registered disinfectant intended to kill biofilm.
- Combines suspended inanimate particulates for easy removal by a filtration system.
- Cleans away or removes inanimate dust-mite matter, non-living matter, or allergens from non-living sources (e.g., pet dander allergens, cockroach matter allergens, dust mite matter allergens) [These examples differ from the examples in the section on claims we consider to be pesticidal in that these indicate that the allergens come from non-living matter such as “pet dander,” “cockroach matter” and “dust mite matter.”]
SOURCE: (I unfortunately cannot link to the EPA site per forum limitations), however to see the source you would add "/pesticide-registration/determining-if-cleaning-product-pesticide-under-fifra" without quotes after the EPA's url.
Determining If a Cleaning Product Is a Pesticide Under FIFRA -AMAZON PLEASE READ!
Seller support does not understand what qualifies as an EPA regulated pesticide, so I am posting this mostly for their information to train their departments better, but also for sellers to be armed with facts when dealing with the misidentification of pesticides when it comes to cleaning products.
Per the EPA:
Examples of Claims That the Agency Considers to be Pesticidal
Cleaning products with claims such as those described below are considered by the Agency to be intended for a pesticidal purpose because the claims imply or express that the product mitigates a pest, directly or indirectly, either by itself or by removing the pest’s food, food source or its habitat. These examples represent claims or types of claims for a cleaning product that would trigger a requirement to register the product under FIFRA.
- Cleans away, washes away or removes any pest covered by 40 CFR §152.5.
- Cleans away, washes away or removes biofilm or scum (unqualified).
- Cleans away, washes away or removes allergens (unqualified).
- Cleans away or removes allergens associated with a pest (e.g., dust mite allergens, cockroach allergens).
- Removes pests by suffocating or drowning.
- Cleans or removes pest habitats or breeding sites.
- Cleans, precipitates or removes contaminants, nutrients or matter that provide food or habitat for pests.
- Cleans, reduces or removes scum or sludge where pests breed, feed or live.
- Out-competes or displaces a pest for nutrition or habitat.
- Cleans or removes the habitat where biofilm, germs, allergens or microorganisms can hide, thrive or grow.
- Prevents, blocks, removes, neutralizes or controls bacteria or other pests that cause odors.
- Sanitizes, disinfects or sterilizes.
- Images of pests or pest habitats (e.g., nest, hive or web) that imply cleaning or removal of pest habitats, or of nutrition or sources of nutrition for pests.
- A banner, logo, design, header or any claim on a label or labeling, or through other means such as web sites, advertising, etc. that specifically links the cleaning product to pest control, Integrated Pest Management (IPM), pests or a specific kind of pest.
Examples of Claims That the Agency Considers are NOT Pesticidal
Cleaning products with claims such as those described below are generally considered by the Agency to not be intended for a pesticidal purpose. These cleaning products claim to remove dirt or other debris without any linkage to mitigating a pest, its food, food source, or its habitat. Many of these examples are similar to the examples in the previous section with the explicit linkage to a pest removed.
When not used in connection with other pesticidal claims or in a context where they imply pesticidal purposes, these examples represent claims, or types of claims, for a cleaning product that would not trigger a requirement to register the product under FIFRA.
- Cleans or removes stains.
- Cleans or removes stains from algae, mold, mildew or other non-public health organisms.
- Cleans or removes dirt, soil, dust, debris, inanimate scum, inanimate nutrients, inanimate organic particulates, or inanimate contaminants.
- Cleans a site (e.g., ponds, aquariums, etc.).
- Prevents, blocks, neutralizes, reduces, eliminates, encapsulates or removes odors; deodorizes.
- Cleans, reduces or removes sludge.
- Cleans or removes inanimate scum such as “soap scum.”
- Cleans, washes or prepares the surface for application of a registered disinfectant intended to kill biofilm.
- Combines suspended inanimate particulates for easy removal by a filtration system.
- Cleans away or removes inanimate dust-mite matter, non-living matter, or allergens from non-living sources (e.g., pet dander allergens, cockroach matter allergens, dust mite matter allergens) [These examples differ from the examples in the section on claims we consider to be pesticidal in that these indicate that the allergens come from non-living matter such as “pet dander,” “cockroach matter” and “dust mite matter.”]
SOURCE: (I unfortunately cannot link to the EPA site per forum limitations), however to see the source you would add "/pesticide-registration/determining-if-cleaning-product-pesticide-under-fifra" without quotes after the EPA's url.
13 replies
Seller_rI7BZIczK8iAC
OK, you want to train seller support. Well, well.
That will not be enough. In fact you should change the Artificial Intelligence programs. Actually it's the AI that decides if a listing is a pesticide or not - and not seller support. And it decides this according to the keywords in your listing. If you say "antibacterial", "antimicrobial", "mold" and many, many more words the AI says: "Yes, this product fights pest and bacteries, so it's a pesticide".
So, the AI doesn't care what that FIFRA says, the important is what YOU say in your listing.
Seller_HP0CuTSNvJvu9
Well no kidding, but seller support is responsible for reinstating the listings after the bot flags it incorrectly. This of course is the equivalent of moving mountains to happen. Nuance IS important. I'm not going to lie about my to game the system, or as I have too often in the past - downsell them to encounter less resistance. It's WORSE than you think Bridgette, because even the word "Fresh" in the context of scent will trigger the bots.
Seller_HP0CuTSNvJvu9
100% sure, the word "Fresh" when combined with certain other words is a trigger; even when those words aren't triggers themselves. I've tested it myself.
Seller_4zBzdtgCyS9EI
OK, from what I have seen, speaking of myself, in this forum the last few years...they ARE following that guideline, even though in the strictest of terms....
Seller_HP0CuTSNvJvu9
They are following the "Examples of Claims That the Agency Considers to be Pesticidal" part pretty strictly, but they are completely ignoring the "Examples of Claims That the Agency Considers are NOT Pesticidal" part,
Cooper_Amazon
Good Evening @Seller_HP0CuTSNvJvu9,
I just wanted to stop by here and let you know that the information you have shared is very thorough and it's feedback I'd be happy share with the Pesticides team.
Besides the feedback in you post, was there a question or case you needed additional support on which may have prompted the creation of this discussion? I want to make sure I am able to assist as best I can.
Looking forward to hearing back from you soon. Have a great weekend.
Sincerely, Cooper_Amazon
Seller_HP0CuTSNvJvu9
Thanks Cooper. After MANY back and forths in the cases my issues were finally resolved. It just shouldn't have taken so much to finally get there.