With the return of summer there is an increase of outdoor activites which prompts the use of products such as insect repellent. Although it is not impossible for your small business to offer insect repellants, there are many guidelines and regulations that need to be reviewed before you begin to distribute your product.
Summer increases the likelihood of outdoor activities, which in turn increases your risk of exposure to insects. Many small cosmetics companies see this as an opportunity to market “natural’ insect repellent products as an extension of their existing line. However, commercial insect repellents are, by definition, pesticides. Because of the intended use of these class of products, they are understandably highly regulated. Before an insect repellent can be marketed, most must be registered by the Environmental Protection Agency (EPA). EPA registration of insect repellent active ingredients ensures that the materials used have been reviewed and approved for human safety as well as for effectiveness. Products registered by the EPA will display an EPA Registration Number on the product label. The Centers for Disease Control and Prevention (CDC) solely recommends the use of products containing active ingredients that have been registered by the EPA. [1]
There are some insect repellent products for sale in the United States that do not currently require EPA registration. The active ingredients in these non-registered products were evaluated for safety in the 1990’s and include many “natural” components like essential oils and botanicals. It was determined at that time that these specific active ingredients posed minimal risk to human health. Based on this minimal risk determination, the EPA determined that products made from these ingredients should be exempt from registration. Products made from these ingredients have not been evaluated for effectiveness, only for safety of the active ingredients. The EPA is considering whether repellent products should be removed from the exemption altogether because effectiveness is critical to disease prevention which is the underlying intent of a repellent. Examples of some ingredients used in non-registered insect repellents are citronella oil, cedar oil, geranium oil, peppermint oil and soybean oil. [2]
Minimum risk pesticides are a special class of pesticides that are not subject to federal registration requirements because their ingredients are demonstrated as safe for the intended use. To satisfy the conditions required for federal minimum risk status, all five of the following conditions must be met:
1. The product must contain only active ingredients that are listed on the EPA website.
2. The product must contain only inert ingredients that have been classified by EPA as List 4A “Inert Ingredients of Minimal Concern.”
3. All of the ingredients (both active and inert) must be listed on the label. The active ingredient(s) must be listed by name and percentage by weight. Each inert ingredient must be listed by name.
4. The label cannot include any false or misleading statements, and claims that minimum risk pesticides protect human or public health are prohibited.
5. In general, public health claims 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.
If you advertise (in print, online, by word of mouth or by any other means) that your product "kills", "repels", "protects against" or imply that the intended use of your non-registered product is to perform these functions, you are making a claim that ultimately should be validated through independent testing.
Manufacturing pesticide products in a non-agricultural facility falls under Occupational Health & Safety Administration (OSHA) jurisdiction. Working with pesticides, even natural ingredients that act as pesticides, requires appropriate personal protection equipment for all workers who may come into contact with these materials. Failure to comply can result in OSHA intervention and fines.
In short, it is possible to offer a natural repellent product as a small or micro-business. However, to remain in compliance with both local and federal regulations, you should be sure to follow all published guidelines as well as contact your local Extension office to determine any additional guidelines specific to your geographical location as well as the geographical locations in which you intend to distribute your finished repellent product. [3]
