25(b) efficacy: literature vs a new insect study

Some states ask for proof that a 25(b) product does what the label says. That is not an EPA Section 3 data package, but it is also not a blog post. EPA and AAPCO updated 25(b) efficacy expectations (guidance effective 2026). States still decide what they will file.

What a literature package is

A written rationale that maps each labeled pest to an allowed oil or constituent and to published papers that actually discuss that pest or that chemistry. It cites real PDFs. It states what the paper does not prove. It does not invent percent kill from a software “virtual insect.”

When literature is usually enough

• Household or plant pests already covered by a long paper trail on that oil (mites, fungus gnats, aphids, whiteflies on many cinnamon, clove, rosemary, or similar 25(b) actives)
• States that historically accepted a bound literature set plus the CFS

When a state may still want a study

• A long pest list with no paper for several names
• Public-health pests (mosquitoes, ticks, biting flies) or personal-repellent claims
• A new use site (skin vs foliage vs indoor crack-and-crevice)
• A reviewer who applies the 2026 guidance strictly

A full insect-by-insect bioassay is a different cost tier than a literature draft. We do not promise every state will take literature only.

Typical project cost

Literature rationale is quoted in the $1,900–$5,900 range depending on pest count and how complete the papers are. A single-pest live study, if required, is a separate quote.

Request an efficacy quote Public-health pests

Not EPA or state approval. A literature package is a filing aid, not a guarantee of registration.