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Discussion in 'The Green Guardian' started by Norm Al, Feb 25, 2006.
mark do any of your products carry the 25b exemption on their labels?
Each and every product we manufacture that claims any pesticide activity is and conforms to the FIFRA ACT SEC (25)b exemption requirements.
im not sure how a fertiliser has gotten a 25b exemption but i will take your word on it!
All pesticide ingredients are on the active list while the fertilizer components are on the inert list.
mark i just checked out the distributor info page about your products, the PDF's listed their, only make the 40% to 95% claims of being organic,,,,there were also no 25b exempt wordings on your label! the paragraph that has to be on the label is the only identifier to the public that it is truly 25b exempt!
if the fert part qualifys as an inert your products would truly then be 100% organic.
are you a salesman repeating what you are told or are these your products?
I will answer in order and also post some questions.
The distributor info page. What web site? If this is Canada different rules apply and the products are also made for local climate conditions.
Our labels, where did you get them from? We do have the proper data provided on each.
The EPA FIFRA ACT SEC (25)b does not identify inerts as organic.
Some of our products are all organic others will contain Urea. Each are clearly identified.
I am the creator of the products.
mark since your websites are down i was looking at the distributor you posted,,,,,it looks to be your canadian distributor.
the labels are the labels they list as product info.
is where i get the info about inerts,,,,,,ALL of the products have to come from their list to qualify as a 25b exempt product, whether inert or active.
we can simplify this,,,,,are your products being marketed in florida as 25b exempt products,,,,with your labels aproved by the state of florida and on file with the state of florida as 25b exempt? or are your labels being sold in any states as 25b exempt aproved labels?
QUESTION: How can I tell if my product qualifies for the minimum risk pesticide exemption?
ANSWER: To qualify as a minimum risk pesticide under 40 CFR 152.25(g) (and be exempt from pesticide registration), a product must meet certain conditions. These conditions fall into the following two categories.
-- active ingredients: may contain only those active ingredients that are listed in 40 CFR 152.25(g)(1) and shown in Appendix A.
-- other (inert) ingredients: may contain only List 4A inerts, including commonly consumed foods. (See Appendix B).
All ingredients in an exempted product must be listed on its label:
-- Active ingredients must be listed by name and percentage (by weight).
-- All other ingredients must be listed by name (see above for inerts).
No false or misleading statements under 40 CFR 156.10 (a)(5)(i)-(viii) may appear on an exempted products label.
Actually, most states do not register 25b products. They simply follow the federal EPA registration exemption and likewise do not register them.
mark almost all states register the label and charge a fee for the product to be registered as a product to be sold within that state!
companys can contact florida state registration and get a copy of a products label if it is registered to be sold within the state.
what the state does is insure that your label meets the epa standards for 25b exemption,,,,if the label does not meet the standards then they would make you change it so as to make it a sellable product within the state.