Some of you may notice that I am in the process of changing
the labeling of my Bug Off Lotion Bars to Woodland Wonder (there are just a few
dozen of the old labels still around, so this should be done very soon). I am a
soap and cosmetics maker, not a pesticide producer and I believe in following
laws and requirements to my best ability. This is both a federal EPA and a
state issue, so here is the short story.
·
Minimum risk pesticides are a special class of
pesticides that are not subject to federal registration requirements because
their ingredients, both active and inert, are demonstrably safe for the intended use.
- · The product must contain only approved active ingredients. The active ingredient of a product is the ingredient that kills, destroys, mitigates, or repels pests named on the product label. The Orange Oil and Catnip Oil I use in my formula are not on this list of approved ingredients.
- · The product must contain only those inert ingredients that have been classified by EPA as Inert Ingredients of Minimal Concern. The cocoa butter and almond oil I use in my formula are not on this list of approved ingredients.
- · Even if I changed my formula and was compliant to the above federal ingredient requirements, there are still further rules to follow, including more complex labeling laws, and state registration requirements. If I were to remain making my lotion bar as is and claiming insect repelling properties, I would need to register as a pesticide producer in the state of PA.
Because my product is not compliant, I have removed all claims
of repelling pests of any kind. However, I know many of you still like the
scent and have personal anecdotal evidence of its effectiveness on your own.
Therefore, I have renamed it Woodland Wonder and it is being sold as a “normal”
lotion bar. The formula has not changed in any way, just the labeling.
If you are looking at other handcrafted (or even mass
produced items) that claim to repel insects, you should also look for the
following information on the label:
- · The active ingredient(s) must be listed by name and percentage by weight.
- · The label cannot include any false or misleading statements, and claims that minimum risk pesticides protect human or public health are prohibited.
- · Minimum risk pesticide labels may not bear claims to control rodent, insect or microbial pests in a way that links the pests with any specific disease.
- · The product is made in the state, it should be registered in the state of PA. You can look them up by company here: http://npirspublic.ceris.purdue.edu/state/state_menu.aspx?state=PA
- · If you are interested in seeing the lists of approved active and inert ingredients you can find them here http://www.epa.gov/oppbppd1/biopesticides/regtools/25b_list.htm
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