Compliance Shortcuts for Exporting Pet Protective Products to the US

Pet protection products containing insecticides (such as those effective against lice, fleas, and mosquitoes) or built-in chips or capsules that release chemicals and have the effect of preventing/repelling lice, fleas, and mosquitoes are usually regarded as pesticides by the U.S. Environmental Protection Agency and must be registered as EPA insecticide products.

Registration of conventional insecticide products: high cost and long cycle

The cost of EPA federal registration alone is quite high, typically starting at several hundred thousand RMB. The registration process is lengthy, usually taking 1-2 years or even longer. Overall, it requires a significant investment of time and money.。

Exemption pathway: lowest risk pesticides

However, not all pet flea and tick repellent products require full EPA federal registration.

If your product meets certain criteria, it may be compliant as a minimum risk pesticide under the EPA, thus exempting it from federal registration and requiring only state registration.

—Minimum risk pesticides are those pesticides exempt from federal registration with the U.S. Environmental Protection Agency (EPA) under Section 25(b) of the Federal Insecticides, Fungicides, and Rodenticides Act (FIFRA).

Core requirements for lowest risk pesticides

Products must strictly use ingredients listed below:

Active Substances: Only the 45 substances listed in the EPA's List of Exempted Active Ingredients for Lowest Risk Pesticides (2024 Revision) are permitted (such as specific concentrations of citronella oil, peppermint oil, and other plant extracts).

Adjuvant Ingredients: Only the 288 substances listed in the EPA's List of Exempted Adjuvant Ingredients for Lowest Risk Pesticides (2024 Revision) are permitted.

State registration requirements and compliance difficulty

After exemption from federal registration, state registration is required based on the requirements of the states where the product is intended to be sold. Requirements vary significantly from state to state, and the main categories of compliance difficulty fall into the following categories:

Businesses can prioritize registering in states with a compliance difficulty rating of ⭐ or ⭐⭐, as these registrations tend to be less costly and faster. If planning nationwide sales, registration in all 51 states is required. Once the target market is identified, the list of target states can be provided to professional service agencies, such as EntGroup. EntGroup can then design a compliance solution based on this list, maximizing material reuse and significantly reducing compliance costs for businesses.

Key requirements for lowest risk pesticide labeling

Label content must strictly comply with regulations. Core requirements include:

1. Complete Ingredient Listing: All ingredients must be listed completely and clearly on the label as required.

2. Limited Use Claims: Claims or implications that the product can control or reduce organisms that pose a threat to human health (such as bacteria or viruses), or control insects/rodents carrying specific diseases are prohibited.

3. Complete Company Information: Necessary information such as the company name and address must be clearly stated as required.

4. Accurate and Truthful Content: All label information must be truthful and accurate, and must not contain any false or misleading content.

5. Supporting Efficacy Data: Regulatory requirements for low-risk pesticide labeling claims vary across US states. Some states explicitly require that claims on the label be supported by true and reliable efficacy data.

Minimum risk pesticide compliance process

Pet protection products using specific plant-derived active ingredients and adjuvants can significantly reduce compliance costs and timelines by following the minimum risk pesticide pathway. Conventional insecticides, on the other hand, fall under a high-regulatory-risk category, with a complex, lengthy, and costly EPA federal registration process; companies need to plan ahead.

For information on EPA compliance requirements for other pet protection and antibacterial products, please contact us via info@enter-co.com.

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