PI233

When Cleaning Products Are Pesticides1

Frederick Fishel2

It might never occur to many people that cleaning products, such as bleach and disinfectants, can be considered
pesticides. Custodial staff and homemakers who routinely
use cleaning products within the indoor environment may
or may not actually be handling pesticidesit depends. This
document describes the U.S. Environmental Protection
Agencys (EPA) interpretation of cleaning product label
language that constitutes which products are marketed as
pesticides and must be registered as such. The document
includes examples of cleaning product claims that are
considered pesticidal, that are considered not pesticidal,
and that may or may not be pesticidal depending on the
context in which they are presented.

Introduction and Overview

The Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA) defines a pesticide as any substance or mixture
of substances intended for preventing, destroying, repelling,
or mitigating any pest. Some substances might appear
at first to be classified by FIFRA as pesticides, but this
is not necessarily the case. Unless otherwise exempted
from registration, pesticide products intended for a
pesticidal purpose, including some cleaning agents, must be
registered.
A product is considered intended for a pesticidal purpose
if, among other things, the person who distributes or sells it
claims, states, or implies that the product prevents, destroys, repels, or mitigates a pest.Therefore, once a product

label or other statement made in connection with the sale

or distribution of the product includes any claim of pest
mitigation, the product becomes subject to the registration
provisions of FIFRA.
A product doesnt necessarily have to act directly on a pest
in order for it to mitigate the pest and be considered a pesticide. For example, claims that a product affects the habitat
or food source of a pest are considered mitigation claims
against that pest. Such claims are in contrast with statements about a products use that merely claim to remove
dirt or other debris without its association to mitigating a
pest, its food source, or its habitat. Thus mitigation claims
against a pest, its habitat, or its food source subject the
product to the requirements of FIFRA.
Certain products may have effects that mitigate pests
without being intended for a pesticidal purpose. One such
group of these products includes deodorizers, bleaches,
and cleaning agents that are not pesticides because they are
not intended to prevent, destroy, repel, or mitigate a pest.
However, FIFRA provides, and EPA considers, that these
types of products are not pesticides only if no pesticidal
claim is made on their labeling or in connection with their
sale and distribution. In other words, where a claim or
implication is made in connection with the sale or distribution of a cleaning product that its use will mitigate a pest,
either by itself or in combination with any other substance,
the product is considered a pesticide and therefore requires
registration and regulation as such.

1. This document is PI233, one of a series of the Agronomy Department, UF/IFAS Extension. Original publication date January 2011. Reviewed June 2014.
Visit the EDIS website at http://edis.ifas.ufl.edu.
2. Frederick Fishel, associate professor, Department of Agronomy, and director, Pesticide Information Office, UF/IFAS Extension, Gainesville, FL 32611.
Use pesticides safely. Read and follow directions on the manufacturers label.
The Institute of Food and Agricultural Sciences (IFAS) is an Equal Opportunity Institution authorized to provide research, educational information and other services only to
individuals and institutions that function with non-discrimination with respect to race, creed, color, religion, age, disability, sex, sexual orientation, marital status, national
origin, political opinions or affiliations. For more information on obtaining other UF/IFAS Extension publications, contact your countys UF/IFAS Extension office.
U.S. Department of Agriculture, UF/IFAS Extension Service, University of Florida, IFAS, Florida A & M University Cooperative Extension Program, and Boards of County
Commissioners Cooperating. Nick T. Place, dean for UF/IFAS Extension.

In this document, the term cleaning product means a

substance or mixture of substances, such as chemical or
biological substances, intended to clean away or remove
material from a surface, water, or air, and that makes no
pesticidal claims.

Cleaning Products Considered

Pesticides by the EPA
Cleaning products are considered pesticides if their claims
imply or express that the product mitigates a pest, directly
or indirectly, either by itself or by removing the pests food,
food source or its habitat.The following are example claims,
or types of claims, for cleaning products that the EPA
deems to have pesticidal intent:
Cleans away, washes away, or removes any pest covered
by FIFRA.

Cleaning Products Not Considered

Pesticides by the EPA
These cleaning products claim to remove dirt or other
debris without any linkage to mitigating a pest, its food,
food source, or its habitat.Many of these examples are
similar to the examples in the previous section with the
explicit linkage to a pest removed.
When not used in connection with other pesticidal claims
or in a context where they imply pesticidal purposes, these
examples represent claims, or types of claims, for a cleaning
product that would not trigger a requirement to register the
product under FIFRA. EPA generally considers cleaning
products with the claims such as those described below as
not intended for a pesticidal purpose.
Cleans or removes stains.

Cleans away, washes away, or removes biofilm or scum

(unqualified).

Cleans or removes stains from algae, mold, mildew, or

other non-public health organisms.

Cleans away, washes away, or removes allergens

(unqualified).

Cleans or removes dirt, soil, dust, or debris.

Cleans away or removes allergens associated with a pest;

for example, dust mite allergens and cockroach allergens.
Removes pests by suffocating or drowning.
Cleans or removes pest habitats or breeding sites.

Nonliving scum, nutrients, organic particulates, or

contaminants.
Cleans a site, such as ponds and aquariums.
Prevents, blocks, neutralizes, reduces, eliminates, encapsulates, or removes odors; deodorizes.

Cleans, precipitates, or removes contaminants, nutrients

or matter that provide food or habitat for pests.

Cleans, reduces, or removes sludge.

Cleans, reduces, or removes scum or sludge where pests

breed, feed or live.

Cleans, washes, or prepares the surface for application of

a registered disinfectant intended to kill biofilm.

Out-competes or displaces a pest for nutrition or habitat.

Combines suspended inanimate particulates for easy

removal by a filtration system.

Cleans or removes the habitat where biofilm, germs,

allergens, or microorganisms can hide, thrive, or grow.
Prevents, blocks, removes, neutralizes, or controls
bacteria or other pests that cause odors.
Sanitizes, disinfects, or sterilizes.
Images of pests or pest habitats on product labels, labeling, or other advertising media, such as nests, hives, or
webs, that imply cleaning or removal of pest habitats, or
of nutrition or sources of nutrition for pests.
A banner, logo, design, header, or any claim on a label
or labeling, or through other means such as websites,
advertising, etc., that specifically links the cleaning
product to pest control, Integrated Pest Management
(IPM), pests or a specific kind of pest.

When Cleaning Products Are Pesticides

Cleans or removes inanimate scum such as soap scum.

Cleans away or removes nonliving dust mite matter,

nonliving matter, or allergens from nonliving sources.
Examples would include pet dander allergens, cockroach
matter allergens, and dust mite matter allergens. These
examples differ from the examples in the previous section
in that these indicate that the allergens come from
nonliving matter.

Additional Information
Fishel, F.M. 2006. Federal regulations affecting use of
pesticides. UF/IFAS EDIS Document PI-131. http://edis.
ifas.ufl.edu/pi168 (accessed January 2011).
Fishel, F.M. 2006. What is and isnt a pesticide. UF/IFAS
EDIS Document PI-96. http://edis.ifas.ufl.edu/pi133
(accessed January 2011).