FIFRA 25(b) Minimum Risk Pesticide Label Requirements Checklist

Your product qualifies for the EPA 25(b) minimum risk pesticide exemption — but the exemption only applies if your label meets every requirement. A missing element can disqualify your product from the exemption entirely, which means you would need full EPA registration. This checklist covers every label requirement so you can verify your label before listing on Amazon or any other marketplace.

Last updated April 2026

The short answer

Even though 25(b) products are exempt from EPA registration, they are not exempt from labeling requirements. The label must include the product name, the name and address of the producer, a complete ingredient statement listing all active and inert ingredients by name and percentage, directions for use, and specific cautionary statements. Missing any of these elements can void the exemption.

The complete label checklist

1. Product name (brand name) The common or trade name of the product, displayed prominently on the front panel.

2. Name and address of the producer, registrant, or person for whom produced Must include the company name and full mailing address (street, city, state, ZIP). A P.O. box alone may not satisfy this requirement in some states. This is the name and address of whoever is responsible for the product — the manufacturer, the formulator, or the brand owner.

3. Complete ingredient statement — active ingredients List every active ingredient by its common chemical name. Each must appear on the EPA 25(b) approved active ingredient list at 40 CFR 152.25(f)(1). Show the percentage by weight for each active ingredient.

4. Complete ingredient statement — inert ingredients List every inert ingredient by name. Each must appear on the EPA-approved inert ingredient list for 25(b) products. Show the percentage by weight for each inert ingredient, or show the total percentage of all inert ingredients combined. EPA’s guidance recommends listing each inert by name; some states require it.

5. Total percentage must equal 100% The active ingredient percentages plus the inert ingredient percentages must add up to 100%. This is a common error on 25(b) labels.

6. Directions for use Clear, complete instructions telling the user how to apply the product, how much to use, where to apply it, and how often. The directions must be adequate to protect the user and the environment.

7. Net contents statement The amount of product in the container, expressed in weight or volume as appropriate (e.g., “Net Wt. 12 oz” or “Net Contents: 16 fl oz”).

8. Caution statements At minimum: “Keep out of reach of children.” Additional precautionary statements as appropriate for the product (e.g., “Avoid contact with eyes”). Even though 25(b) products are considered minimum risk, basic safety statements are required.

9. No false or misleading statements The label cannot contain claims that are false, misleading, or unsubstantiated. This applies to both efficacy claims and safety claims. You cannot claim EPA registration or EPA approval for a 25(b) product — because it is exempt, not registered.

10. No claims against excluded pests The label cannot claim efficacy against pests that carry diseases to humans (e.g., ticks that transmit Lyme disease, mosquitoes that carry West Nile virus). Public health pest claims disqualify the product from the 25(b) exemption.

11. No claims requiring EPA registration number Do not include a fake or placeholder EPA registration number. Do not state “EPA Registered” or “EPA Approved.” You may state “Exempt from EPA registration under FIFRA Section 25(b)” if desired, but this is optional and some sellers prefer to omit it.

Common label mistakes

Listing “other ingredients” without naming them. Unlike conventional pesticide labels that may list “Other Ingredients: 95%,” 25(b) labels should name all inert ingredients. Some states explicitly require this.
Using a fragrance oil name instead of the chemical name. “Summer Garden Blend” is not an acceptable ingredient name. Use “Geraniol,” “Citronella oil,” etc.
Forgetting “Keep out of reach of children.” This statement is required even for minimum risk products.
Percentages that do not total 100%. Double-check your math. Rounding errors are common.
Missing the company address. A website URL is not a substitute for a physical mailing address.

Run the full self-check

Not sure whether your product actually qualifies for the 25(b) exemption? Start with the self-check tool to verify your eligibility before reviewing label requirements.

Start the Free FIFRA Self-Check 5 questions, ~3 minutes, no signup required Get the Compliance Template Bundle — $29 Appeal letters, rewrite checklist, EPA filing guide

Relevant source text

“A minimum risk pesticide that otherwise meets the requirements for exemption [under 25(b)] must bear a label identifying the name and percentage of each active ingredient by weight, the name of each inert ingredient by weight, the name and address of the producer, a directions-for-use statement adequate to protect health and the environment, and [required cautionary statements].” — 40 CFR §152.25(f)(3), Labeling Requirements for Exempt Products. Full text at eCFR

“Although products qualifying for this exemption are not subject to the registration requirements of FIFRA, they remain subject to other requirements of the Act, including the prohibition against making false or misleading claims (FIFRA section 12(a)(1)(E)) and the requirement that products not be misbranded.” — EPA, Minimum Risk Pesticides Exempted from FIFRA Registration. EPA.gov

Not legal advice. This page applies publicly available statutes and regulations to common Amazon seller scenarios. It does not substitute for a licensed attorney or compliance professional. Before acting, confirm with the relevant regulator or a licensed professional. The site author is not responsible for decisions made based on this content.

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