US EPA Pesticide Device Registration

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) defines a "pesticide device" an instrument or contrivance that work using physical or mechanical means and do not contain any active pesticide ingredients, but claim to kill, inactivate, or inhibit the growth of bacteria, viruses, or fungi; reduce or eliminate microorganisms or allergens in the air or water; repel pests such as birds, subterranean animals, and rodents; or kill or trap insects/pests.

• Examples: UV lights, insect traps, black light traps, ultrasonic devices, ozone generator device, air ionizer/electrolyzer, pool and spa electrolysis units, humidifiers, water treatment units and air treatment units

Pesticide devices are regulated by the US EPA and do not need to go through complex and expensive pesticide registration process. Only establishment registration with EPA is required. Some states also require pesticide device registration. It is usally easy and cheap to register a pesticide device and obtain an establishment number in the US.

If a company is unsure whether its product is a pesticide device, the company can submit a pesticide device identification application to EPA and pay the corresponding fee to clarify whether the product meets EPA's definition of pesticide devices.

Pesticide Device Compliance Requirements in the US

Pesticide devices sold to the United States must comply with the following regulatory requirements of the U.S. EPA:

(1) Meet the definition of device in FIFRA 40 CFR 152.500

(2) Pesticide device manufacturers must register their factory sites with the EPA and submit an annual report before March 1 of each year.

(3) Comply with EPA labeling requirements for pesticide devices:

• The use of any statements, formats, or diagrams that are likely to mislead or deceive is strictly prohibited 40 CFR 156.10(a)(5);

• The packaging must meet the requirements of FIFRA section 25(c)(3):

• It is strictly prohibited to imitate or misuse the names of other products

• Mark EPA brand name and place of origin

• Any valid information must be indicated

• Contains detailed instructions for use

• Contains warnings

(4) When the device is packaged in child-resistant packaging, it must meet the specific requirements of the CRP, see 40 CFR 157.20

(5) The importer submits the designated port import application form to EPA

US Pesticide Device State Registration

Some US states (i.e., California, Colorado, Indianna) also require state registration for pesticide devices sold within their state. Each state charges an administrative fee of US$40-330, and the approval process can take anywhere from seven days to six months.

Pesticide Device Registration FAQs

1. How long is the validity period of the US EPA pesticide device registration?

A: There is no specific expiration date for U.S. EPA establishment registration. As long as the annual report is submitted on time each year and the authorized agency in the United States is legal and valid, the EPA registration will remain valid.

2. Can overseas manufacturers apply for U.S. EPA registration on their own?

A: U.S. EPA registration must be applied for by local U.S. residents or companies. All companies outside the U.S. must entrust a U.S. agency to apply.

3. Is there a pesticide device registration certificate issued by US EPA?

A: The U.S. EPA does not issue formal certificates for pesticide device. However, once a company completes EPA registration and obtains a company registration number and establishment number, the EPA will issue a notice.

Our Services

CIRS Group USA Inc can be your agent to help you navigate the complex pesticide regulatory barriers in the USA and bring your pesticide products to the US market cost-efficiently and compliantly.  

• US FIFRA regulatory consultation;

• U.S. EPA company and establishment registration;

• U.S. EPA agent and annual report;

• U.S. EPA Pesticide Federal Registration;

• U.S. state registration of pesticide products and pesticide devices;

• Review of pesticide device labels;

For more information on how we can assist with your pesticide device registration and compliance needs in USA, contact us today via Email: service@cirs-group.com.