25(b) minimum-risk pesticide registration
FIFRA section 25(b) products are exempt from federal EPA registration if they meet EPA’s conditions — allowed actives, allowed inerts, label statements, and no public-health claims. Most states still require their own product registration. A few only notify or exempt. Policy varies; we track it per state.
Federal conditions (still on the label)
- Active ingredients only from EPA’s 25(b) active list
- Inerts only from EPA’s 25(b) inert list
- Label conditions (identity, percentages, company contact, no false EPA-registration implication)
- No claims to control microbes / public-health pests in the sense EPA forbids for this exemption
Failing those conditions does not “become a Section 3 with extra paperwork.” It can mean the product is an unregistered pesticide.
What states commonly want
- Label as sold
- Confidential formula statement (CFS) listing actives and inerts to 100%
- Efficacy support in states that ask — literature rationale vs. full insect-by-insect studies depends on the state and the 2026 EPA 25(b) efficacy guidance
- Company license / applicator or dealer credentials where that program is separate
Typical costs
| Item | Typical range |
|---|---|
| 25(b) registration / verification (our work) | $200–$250 / label / state |
| New state account setup | $200–$400 / state |
| CFS draft / package (project) | Quoted |
| Literature efficacy rationale (project) | Quoted; full bioassays are a different cost tier |
| State product fee | Paid to the state; $0 in some programs, several hundred in others |
Common 25(b) errors
- Inert not on the EPA 25(b) inert list (or listed only by a trade name)
- Active + inert percentages that do not total 100%
- “EPA registered” or an EPA reg. number on a 25(b) label
- Disease, virus, or disinfectant-style claims
- Target pests named with no support the state will accept
- CFS that does not match the label ingredient statement
- Assuming “25(b) means no state filing”
Official lists and associations
EPA minimum-risk pages and active/inert lists, state pesticide programs, AAPCO, and specialty groups such as RISE. More links: registration resources.
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Not EPA or state approval. Efficacy and CFS drafts are for human review before filing.