Insect Repellent 25(b) Minimum Risk Exemption for Amazon Sellers

You sell a natural insect repellent — citronella spray, lemongrass candle, cedarwood oil blend, peppermint bug deterrent — and Amazon flagged your listing under the pesticide policy. The product genuinely is a pesticide (it claims to repel insects), but it may qualify for the EPA’s 25(b) minimum risk exemption, which means no federal registration is needed. Here is how to determine if you qualify and what Amazon requires.

The short answer

FIFRA Section 25(b), codified at 40 CFR 152.25(f), exempts certain “minimum risk pesticides” from federal registration. To qualify, your product must meet all of the following conditions: every active ingredient must be on EPA’s approved list, every inert ingredient must be on the approved inert list, the product cannot make claims against certain high-risk pests, and the label must meet specific formatting requirements. If you meet all conditions, you do not need an EPA registration number — but you still need to comply with state registration requirements and FIFRA labeling rules.

How this applies to your situation

The 25(b) exemption was created for products that EPA considers low enough risk to not warrant the full registration process. Most natural insect repellents fall into this category — if they are formulated correctly.

Approved active ingredients for insect repellents include:

• Cedar oil (cedarwood oil)
• Cinnamon and cinnamon oil
• Citronella and citronella oil
• Clove and clove oil
• Corn oil
• Garlic and garlic oil
• Geraniol
• Lemongrass oil
• Mint and mint oil (peppermint, spearmint)
• Rosemary and rosemary oil
• Soybean oil
• Thyme and thyme oil

This is not the complete list. EPA maintains the full list of approved 25(b) active ingredients in 40 CFR 152.25(f)(1). If your active ingredient is not on the list, the exemption does not apply and your product needs full EPA registration.

Conditions that disqualify you from the exemption:

• Any active ingredient not on the approved list (DEET, picaridin, permethrin, and IR3535 are not 25(b) eligible — they require full registration)
• Any inert ingredient not on EPA’s approved inert list (List 4A/4B, now part of the Safer Chemical Ingredients List for 25(b) purposes)
• Claims against insects or pests that carry diseases to humans (you cannot claim a 25(b) product repels ticks that transmit Lyme disease, or mosquitoes that carry malaria or Zika — these are public health pest claims)
• Missing or non-compliant labeling (see our 25(b) label requirements checklist)

What Amazon specifically requires

Amazon’s pesticide policy requires that any pesticide product listed on the platform either have a valid EPA registration number or qualify for a recognized exemption. For 25(b) products, Amazon may ask you to provide:

• Documentation showing the product qualifies under 25(b) — typically a letter from a regulatory consultant or attorney, or your own compliance documentation identifying each active and inert ingredient against the approved lists
• A copy of the product label showing all required 25(b) label elements
• State registration documentation, if the product is sold in states that require separate registration of 25(b) products

The Compliance Template Bundle includes a 25(b) exemption documentation template you can customize for your product.

Watch out for state requirements

The 25(b) exemption is a federal exemption. Many states have their own pesticide registration requirements, and not all of them recognize the federal 25(b) exemption. As of 2026, states that require separate registration for 25(b) products (or have additional restrictions) include but are not limited to: California, Indiana, New York, and Washington. If you sell nationally on Amazon, you should check the registration requirements for every state where your product ships.

What to do next

1. Run the free self-check to confirm your product qualifies for the 25(b) exemption. Start the self-check.
2. Verify every ingredient. Check each active ingredient against the 40 CFR 152.25(f)(1) list and each inert ingredient against EPA’s approved inert list.
3. Review your label against the 25(b) label requirements checklist.
4. Check state requirements for every state where your product is sold or shipped.
5. Prepare your documentation for Amazon, including ingredient verification and label compliance. Keep this ready for any compliance review or appeal.

Run the full self-check

Relevant source text

“A minimum risk pesticide is exempt from the requirements of FIFRA if it meets all of the following conditions: (i) Each of the active ingredients in the pesticide product is listed [in 40 CFR 152.25(f)(1)]. (ii) The pesticide product contains only inert ingredients [listed in 40 CFR 152.25(f)(2) or on the applicable EPA list]. (iii) All of the claims made for the product, as distributed or sold, are [consistent with the conditions of exemption].” — 40 CFR §152.25(f), Minimum Risk Pesticides. Full text at eCFR

“Products claiming to repel or kill ticks (or other arthropods) that may carry disease are not eligible for the FIFRA section 25(b) exemption, as they are making public health claims.” — EPA, Minimum Risk Pesticides Exempted from FIFRA Registration. EPA.gov