Mods please help FIFRA Exemption
Dear Mods, please help as we have a 25b Exempt FIFRA pesticide product and the product was flagged and removed a while ago. We went ahead and got a Certification letter from EPA where they have clearly mentioned the product is "Exempt" from Registration and that it qualifies for a 25b Minimum risk exempt from Registration, Inspite of showing all the proofs the folks keep asking the same thing again and again in a endless loop. After a few tries they agreed with the proof and asked us to upload images of the product. Once we did this they again went back to the same question to show proof. Please check as everything is there with Case ID 16929238161. Kindly help resolve this issue as probably the team handling may not know this process.
Mods please help FIFRA Exemption
Dear Mods, please help as we have a 25b Exempt FIFRA pesticide product and the product was flagged and removed a while ago. We went ahead and got a Certification letter from EPA where they have clearly mentioned the product is "Exempt" from Registration and that it qualifies for a 25b Minimum risk exempt from Registration, Inspite of showing all the proofs the folks keep asking the same thing again and again in a endless loop. After a few tries they agreed with the proof and asked us to upload images of the product. Once we did this they again went back to the same question to show proof. Please check as everything is there with Case ID 16929238161. Kindly help resolve this issue as probably the team handling may not know this process.
9 replies
Seller_i6S8knzW6zU6Z
Hi @Seller_ZPg31FQi5vaDc,
I'm sorry to hear about the frustrating loop you're experiencing with your FIFRA 25b exempt product. It sounds like you've been thorough in providing the necessary documentation.
Have you checked the 'Compliance ID Attribute – Pesticide Marking' help page (https://sellercentral.amazon.com/help/hub/reference/GLX9EJX844SNJX7J)? This page outlines the steps for marking a product as exempt, which might help ensure everything is set up correctly on your end.
Since you've already provided the EPA exemption letter and uploaded product images, it might be worth revisiting the compliance settings in your product listing to ensure they align with the guidance on that page. Sometimes, even small details can make a difference in how the system processes your exemption status.
Best regards, Michael
Emet_Amazon
Hello @Seller_ZPg31FQi5vaDc,
Thank you for posting your concerns with your listing.
Looking over both the case and the ASIN: B09GW35SSY I do see the referenced policy you mentioned. This product was identified as a pesticide, although you are providing proof that this "product" complies with the FIFRA and showing proof of exemption. The issue may actually be in the products description. Per our pesticide policy, we state:
In the US, pesticides and pesticide devices must comply with FIFRA and applicable state and local laws, including registration and labeling requirements. Pesticides and pesticide devices include the following:
- Any product intended for preventing, destroying, repelling, or mitigating any pest
- Any product that makes antimicrobial, antifungal, antibacterial, anti-mold, or pesticide claims
When I look at the ASIN I see the use of "antibotic" and "antibiotic" in your keywords. The use of this phrasing implies your product is not exempt from FIFRA. If your product is not related to to an antibiotic, or have the proper EPA registration, you will need to remove this. I additionally see the use of "hydrocortisone" in the keywords but no mention of this in your product images under ingredients, this will raise a number of other concerns.
Bases on these observations, you will need to update your product listing to meet our pesticide policy and reflect the exempt nature of the product.
The forums community and I are here to support you. Please let us know how we can help you from this point forward.
Emet.
Emet_Amazon
Hello @Seller_ZPg31FQi5vaDc,
Thank you for following up on this.
Thank you so much for your response and we really appreciate it and that's one of the reason Amazon is such a nice platform as we always get so much help.
We had removed all those keywords and we checked again and there is no mention of the keyword "antibiotic" or "hydrocortisone". Maybe the system is not updating but we tried to edit and save again. The product is live for sale on Amazon Canada and you will notice none of these keywords on that site. can you please review and help us.
Reviewing the situation further and working with the appropriate teams. I have been informed that at this time claims to treat mites are under EPA regulations. Although the phrasing was updated to remove the "antibiotic" and "hydrocortisone" reference, the concern they are advising on as that this is an ear mite treatment which requires EPA registration for the claims of being as pesticide. This will be the only path forward at this time to show proof of compliance.
If you are not the manufacturer of the product, you can typically reach out to them for compliance details. If they are not willing to provide or do not possess these documents, you can have the product independently tested to confirm it's compliance. I would not recommend attempting to create a new ASIN for this product as it may be seen as an attempt to circumvent the current policy.
The forums community and I are here to support you. Please let us know how we can help you from this point forward.
Emet.
