1. Erica Millette Workgroup Chairperson
AAPCO 25(b) workgroup
Erica Millette Workgroup Chairperson

2. background First reached out to states in April 2017 for participants.
First conference call was in June 2017.
Currently we have a conference call with all state participants monthly.
There are 34 participants in the workgroup.
Representing 25 states
Have EPA representation
Held a call with industry representatives the end of February.

3. State survey
Needed to find out which states register 25(b) products and what they require for registration.
In August 2017, a survey was sent out to all states for this information.
We had 100% participation of all 50 states and DC!
41 States require registration
Some states require the label on file but do not actually register the products.
5 States require data
More states said they could request data but it was not required.
11 States require the CSF
12 States require the SDS
Some states had specific label requirements while others did not.

4. The problem
Find common ground when you have potentially 51 different state laws and opinions regarding these products.

5. Label guidance
Products must comply with all six conditions outlined by EPA.
Signal Work and Keep Out of Reach of Children statement are to be located prominently on the front panel of the label.
Active and Inert Ingredients are to be listed in column form and total 100%.
Inert Ingredients are to be listed on the label in order of highest percentage first.
NO images of children are acceptable on labels unless the product is intended for use on children or is a swimming pool product.
All claims on the manufacturer’s website must comply with the six conditions outlined by EPA.
Labels are to include specific use site locations.

6. Label Guidance (Cont.) Non-toxic claims are not acceptable.
The terms “Organic” or “Certified Organic” in reference to the 25(b) product are unacceptable.
“Natural” claims are not allowed if the product includes synthetic chemicals and those derived synthetically.
Claims such as “Safe” or “Safe around children and pets” are acceptable only when accompanied by the qualifier “...when used as directed”.
Data may be required to substantiate any claim that appears on the label or labeling.

7. Label Guidance (Cont.)
This is guidance and does not guarantee your product will be accepted in all states that require registration.
Some states may have additional requirements for registration.
We are hoping to avoid a company needing multiple labels for one product due to different requirements in each state.
This information is subject to change at any time.

8. Future Projects Create data guidance for 25(b) products.
Set up an online forum for states and industry.
Create label and data guidance for topical insect repellent 25(b)s.

9. Erica Millette AAPCO 25(b) Workgroup Chairperson (575) 646-4697