Section 25(b) Chemicals
Chemical products containing active and inert ingredients considered minimum risk are registered under Section 25(b) of FIFRA (Federal Insecticide, Fungicide Rodenticide Act). They are NOT required to have an EPA registration number and are exempt from EPA regulations on efficacy and toxicity. The exemption from Federal registration is allowed only if the manufacturer uses approved active and inert ingredients, and follows EPA labeling guidelines. There are 31 approved active ingredients with pesticide claims on the Section 25(b) list and nearly all of them are natural products (Table 1). A pesticide is defined by FIFRA as "(1) any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest, (2) any substance or mixture of substances intended for use as a plant regulator, defoliant, or desiccant, and (3) any nitrogen stabilizer."
Products exempted from registering with EPA under Section 25(b) are also exempted from full state registration by the Nebraska Department of Agriculture (NDA). NDA requires that Section 25(b) labels be submitted, reviewed and approved by them prior to sale within the State.
Some characteristics of Section 25(b) labels are:
- No approval or review by EPA done.
- Manufacturer is responsible for label content.
- Ingredients are limited to those approved by the EPA.
- No EPA Reg. # issued to identify label.
- No EPA Establishment # is required.
- No signal word is required notifying danger.
- No personal protective equipment (PPE) is required.
- False or leading statements as defined are not allowed.
To growers, a key important point about Section 25(b) products is that the sellers do NOT have to prove efficacy for their claims to either the EPA or the states. An example is a product with the Section 25(b) active ingredients sodium lauryl sulfate @ 0.109%, soybean oil @ 0.0004% and corn oil @ 0.002% plus various "inert ingredients" (99.8%). Sodium lauryl sulfate is a foaming agent refined from coconut oil and found in shampoos. This product is sold as an insecticide, however, demonstrations have shown that this product does not kill insects much. It still can be sold for this use since EPA and state registrations are not concerned with efficacy.
Note that there are products resembling Section 25(b) products in the marketplace that have not received federal and state approval. So a buyer should be aware and wary of unsupported label claims. These products may contain unapproved ingredients. Since they do not contain signal words or requirements for PPE, they could be pose potential health risks. They also may be ineffective, as already noted, and be a waste of money.
(source: Schulze, L. 2003. The Label v.15,i.11.)
Table 1. Active Ingredients under Section 25(b) FIFRA
- Castor Oil
- Cedar Oil
- Cinnamon and Cinnamon Oil
- Citric Acid
- Citronella and Citronella Oil
- Cloves and Clove Oil
- Corn Gluten Meal
- Corn Oil
- Cottonseed Oil
- Dried Blood
- Garlic and Garlic Oil
- Geranium Oil
- Lauryl Sulfate
- Lemon grass Oil
- Linseed Oil
- Malic Acid
- Mint and Mint Oil
- Peppermint and Peppermint Oil
- 2-phenylethyl propionate
- Potassium Sorbate
- Putrescent Whole Egg Solids
- Rosemary and Rosemary Oil
- Sesame (includes ground Sesame plant stalks) and Sesame Oil
- Sodium Chloride (common salt)
- Sodium Lauryl Sulfate
- Soybean Oil
- Thyme and Thyme Oil
- White Pepper
- Zinc Metal Strips