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Because all active ingredients must be listed, the absence of an active ingredient in the ingredient statement would indicate it is not in the product. These claims are therefore disallowable under FIFRA sections 2(q)(1)(A) and 12(a)(1)(E).Ĭonsumers can readily determine if a pesticide product contains an active ingredient (e.g., DEET) by reviewing the active ingredients listed on the front panel of the label in accordance with 40 CFR 156.10(g). Misleading comparative claims about the safety of the product versus other products also constitute misbranding under 40 CFR 156.10(a)(5)(iv) and (vii). Safety claims are considered false or misleading statements that constitute misbranding under 40 CFR 156.10(a)(5)(ix) and (x). This could give users the impression that products without a certain active ingredient are safe or safer than products with the active ingredient, which may be false or misleading. EPA is concerned that users might understand these types of statements to be safety claims. Advertising Claims Can a manufacturer advertise that their product does not contain a certain active ingredient (e.g., “DEET free”)? LC21-1208 10/14/21Ĭlaims such as “free of ” or “contains no ” may constitute misbranding and may need to be removed. Supplemental labeling (NOT distributor products)ġ.Name and address of producer/registrant.Exception to use in a manner not permitted (FIFRA Sec 2ee).

California residential appliance installer license prep class for apple instal free