Minimum Risk Pesticides - Inert Ingredient and Active Ingredient Eligibility under 40 CFR 152.25(f)

If a minimum risk pesticide contains as an active ingredient a chemical that is also eligible under 40 CFR 152.25(f) as an inert ingredient, will the product still be eligible as a minimum risk product?

Ingredients that are included on both the Minimum Risk Active Ingredient list and the Minimum Risk Inert Ingredients list may be used either as an active ingredient or an inert ingredient. However, the active ingredient and inert ingredient lists are not interchangeable. Unless the ingredient appears on both lists, it can only be used based on the list it appears on.

• You may not use an inert ingredient as an active ingredient unless the ingredient is included on both the active ingredient list and the inert ingredient list.
• Similarly, you may not use one of the active ingredients as an inert unless it appears on both lists.  

 Examples:

• Citric acid, malic acid, corn oil, cottonseed oil, sodium chloride, and other chemical substances are examples of minimum risk pesticide ingredients that can be found on both the minimum risk active ingredient list and inert ingredient list.
• Vinegar (maximum of 8% acetic acid in solution), a commonly consumed food commodity, can be used as an inert ingredient in minimum risk products. As an inert ingredient, vinegar provides manufacturers a means of controlling (buffering) pH in minimum risk pesticide products.
  • We selected the maximum of 8% because that is the concentration of some vinegars sold in grocery stores.
  • When the concentration of the acetic acid is greater than 8%, the chemical substance is generally not referred to as vinegar and is not eligible for use as a minimum risk ingredient.
    • At these higher percentages, the acetic acid can cause severe burns and eye damage.
    • Also, acetic acid is a potent herbicide.
  • Because of this potential safety concern, vinegar is not listed as a minimum risk active ingredient and may not be used as an active ingredient in unregistered, minimum risk pesticides.
    • The same is true of any minimum risk inert ingredient that coincidentally has some sort of pesticidal property. If it is not on the minimum risk active ingredient list, it may not be used as an active ingredient in minimum risk pesticides.

For those chemicals that can be used as either an inert or active ingredient, the ingredient must be properly designated on the label according to its role in the product. See EPA letter on differentiation of active and inert ingredients.