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Home > By DEPARTMENTS > Green Operations > California Environmental Compliance

Product Donations Must Meet EPA Labeling Guidelines

Domestic distribution of pesticides that have not been registered with the EPA, such as export-only pesticides, is a violation of federal pesticide law.

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Mislabeled Products, Even When Donated, Must Follow EPA Labeling Regulations

In 2007 the U.S. EPA fined The Clorox Company $95,000 for allegedly distributing an unregistered and mislabeled Chinese version of Clorox Disinfectant Bleach, in violation of federal pesticide law.

The company’s Los Angeles production facility donated the illegal disinfectants to Los Angeles charities in 2005 and 2006. The products were intended for Asian export, so the labels lacked adequate English-language directions for use, hazard and precautionary statements, and the required statement "Not Registered for Use in the United States of America."

"Unregistered pesticides meant solely for export must not be donated, sold, or otherwise distributed in the United States," said Katherine Taylor, associate director of the Communities and Ecosystems Division for the Pacific Southwest region. "Clorox did not give EPA the opportunity to review these labels to ensure the protection of human health and the environment. Recipients of charity deserve the same level of protection from pesticidal risk as all other users."

The EPA annually reviews production reports submitted by industry, and found discrepancies in The Clorox Company reports for 2005 and 2006. The agency conducted a detailed investigation that uncovered 38 Federal Insecticide, Fungicide, and Rodenticide Act violations.

Before selling or distributing any pesticide in the United States, companies must register the pesticide with the EPA. The domestic sale or distribution of pesticides that have not been registered with the EPA, such as export-only pesticides, is a violation of federal pesticide law.

The law also requires unregistered, export-only pesticides to be clearly marked with required labeling to prevent the products from inadvertently entering the U.S. market. The requirements protect public health and the environment by ensuring safe and appropriate distribution, handling, and application of pesticides.

For more information on pesticide regulation and enforcement, please visit:

Edited by Carolyn Allen, owner/editor of California Green Solutions
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