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EPA Alleged 21 Unregistered-Pesticide Sales by Ecoxall

EPA Enforcement
U.S. EPA Region 5 Β· Docket FIFRA-05-2026-0020 Β· Consent Agreement and Final Order
Pesticide regulation

TL;DR

  • The U.S. Environmental Protection Agency alleged that Michigan company Ecoxall, LLC made 21 sales or distributions involving three unregistered pesticide products.
  • The alleged conduct involved four occasions for boric acid, two for oxalic acid and 15 for 75% vinegar.
  • EPA relied on Amazon storefront material, product labels, shipping records and affidavits collected during a January 2025 inspection.
  • Ecoxall agreed to a $5,000 civil penalty, waived a hearing and appeal, and certified that it was complying with federal pesticide law.
  • The settlement contains no admission of the factual allegations and no adjudicated finding that customers, property or the environment were harmed.

The case turns on how the products were promoted: under federal law, pest-control claims can make an otherwise multipurpose chemical a pesticide that must be registered before sale or distribution.

Transparency notice: This article relies on an EPA Consent Agreement and Final Order. The agency labeled the underlying account β€œFactual Allegations and Alleged Violations.” Ecoxall neither admitted nor denied those factual allegations, and the parties settled before a complaint was filed or any factual or legal issue was adjudicated. The penalty and final order are binding; the allegations were not proven at a contested hearing.

The Facts

An Amazon storefront placed a Michigan chemical seller inside the federal pesticide system. EPA alleged that Ecoxall, which has also done business under the name Pure Chemistry, promoted boric acid, oxalic acid and concentrated vinegar for uses that included controlling ants, treating mildew and spraying weeds.

The Federal Insecticide, Fungicide, and Rodenticide Act, usually called FIFRA, doesn’t classify a product solely by its chemical name. A substance is also treated as a pesticide when its seller claims or implies that it can prevent, destroy, repel or mitigate a pest. Once marketed that way, it must be registered under FIFRA before it can be distributed or sold.

EPA alleged that none of the three pesticide products was registered. Its order divides the conduct into 21 alleged violations.

21 Alleged sales or distributions across the three products
3 Products EPA alleged were unregistered pesticides
$5,000 Civil penalty Ecoxall agreed to pay

What Ecoxall Allegedly Sold

The strongest product-specific language appears on the 75% vinegar labels collected by inspectors. According to the order, the labels gave dilution ratios for β€œLight Mildew/Grime” and β€œHeavy Mildew.” They also said the bottle could make horticultural-strength vinegar above 20% and instructed users to β€œCompletely spray weeds during full sunlight.”

For oxalic acid, EPA quoted the Amazon claim: β€œWood Bleach | Rust Removal | Bee Keeping | Pool Cleaner.” The filing treated the beekeeping claim as part of the basis for classifying the product as a pesticide. For boric acid, the order reproduces storefront imagery showing ants near spray equipment as the alleged claim rather than providing searchable wording.

Product Marketing or label evidence described by EPA Alleged occasions
Boric acid Amazon material reproduced in the filing as ant-control imagery; inspectors also collected shipping records, bin labels and an affidavit. 4
Oxalic acid Amazon listing included β€œBee Keeping” among several promoted uses; inspectors collected shipping records, bin labels and an affidavit. 2
75% vinegar Bin labels supplied mixing directions for mildew and directions to spray weeds. 15

All counts and product classifications in this table reflect EPA’s allegations. The order contains two drafting inconsistencies: one sentence in the oxalic-acid section refers to β€œBoric Acid,” and the boric-acid date range ends on January 14 in the formal counts but January 15 elsewhere in the factual allegations.

How the Marketing Triggered Pesticide Law

The case isn’t based on a claim that every sale of vinegar, boric acid or oxalic acid is automatically a pesticide sale. The legal trigger described in the order is intended use. If the seller’s labeling or advertising says or implies that a substance should be used against a pest, FIFRA treats it as a pesticide.

β€œDistribute or sell” is also broader than a completed retail purchase. Under the statute quoted in the order, the phrase includes offering a product for sale, holding it for sale or shipment, shipping it and delivering it. That matters because the filing describes 21 occasions, but it doesn’t establish that those occasions represent 21 different customers or even 21 conventional checkout transactions.

The documented enforcement issue is narrow but concrete: EPA alleged that products were promoted for pest-related uses without the registration federal law required for those uses.

What Inspectors Collected

The investigation moved from the online storefront to Ecoxall’s business records. EPA and the Michigan Department of Agriculture and Rural Development, the state agency whose inspectors were authorized to conduct FIFRA inspections, reviewed the Amazon material. State inspectors then conducted an inspection and collected records tied to the products.

September 10, 2024

An EPA inspector accessed Ecoxall’s Amazon storefront. The order attributes boric-acid and oxalic-acid promotional claims to the storefront on or about that date.

January 5–13, 2025

EPA alleged 15 sales or distributions of 75% vinegar during this period.

January 14, 2025

A Michigan agriculture inspector accessed the Amazon storefront and documented product claims.

January 15, 2025

State inspectors conducted an inspection of Ecoxall and collected shipping records, bin labels and affidavits for the products identified in the order.

Who Was Affectedβ€”and What the Record Doesn’t Show

The order establishes the scale of the alleged regulatory conduct only as 21 sales or distributions. It doesn’t identify customers, provide the amount of product involved, state the value of the sales or say whether the occasions involved unique purchasers.

Nor does the document report illness, physical injury, property damage, crop damage, environmental contamination or financial loss to a customer. It contains no finding that any product was ineffective or unsafe. The absence of registration is the violation EPA alleged; it isn’t, by itself, evidence in this record that a particular person was harmed.

The practical consequence documented here is therefore limited: products allegedly promoted through a major online marketplace for pest-related uses were outside the registration required by FIFRA. Claims about health or environmental consequences would go beyond the supplied evidence.

The Settlement

EPA and Ecoxall used a Consent Agreement and Final Order, or CAFO, to begin and conclude the administrative case at the same time. That allowed them to settle without filing a separate complaint or holding a hearing.

Ecoxall consented to the $5,000 penalty and agreed to pay it within 30 days after the order became effective. EPA said it selected the amount after considering the size of the business, the effect on Ecoxall’s ability to remain in business, the gravity of the alleged violations and the agency’s enforcement policy. FIFRA permitted a penalty of up to $24,885 for each covered offense, but EPA did not assess that per-offense maximum.

The company waived its right to contest the allegations, request a hearing or appeal the order. It also certified that it was complying with FIFRA. Those concessions made the order final, but they didn’t convert the factual allegations into admitted facts.

What the Final Order Actually Decided

The final order concluded EPA’s administrative proceeding and imposed the agreed civil penalty. It resolved Ecoxall’s liability for federal civil penalties only for the violations alleged in this case.

It did not contain an adjudicated finding that Ecoxall committed the 21 alleged violations. It also did not determine that anyone was injured. The settlement expressly preserves the government’s ability to pursue appropriate injunctive relief, equitable remedies or criminal sanctions for violations of law, but the document doesn’t say that any such proceeding is underway.

What Remains Unresolved

The order closes the penalty proceeding without answering several factual questions that would be necessary to measure consumer or environmental consequences. It doesn’t identify the purchasers, quantify how much product entered commerce or describe how the products were ultimately used.

  • Penalty payment: The order requires payment within 30 days of its effective date, but the supplied record doesn’t establish whether payment has been completed.
  • Ongoing compliance: Ecoxall certified that it was complying with FIFRA. The source contains no later inspection, product-registration record or follow-up report testing that certification.
  • Regulatory scope: The settlement resolves only the federal civil-penalty liability alleged in this docket. It doesn’t document any separate enforcement action.

The source document for this investigation is attached below.

There was also a product recall from Exocall in 2023: https://www.cpsc.gov/Recalls/2023/Ecoxall-Recalls-Sodium-Hydroxide-Caustic-Soda-Beads-and-Potassium-Hydroxide-Flakes-Due-to-Failure-to-Meet-Child-Resistant-Packaging-Requirements-Sold-Exclusively-on-Amazon-com

Aleeia
Aleeia

I'm Aleeia, the creator of this website.

I have 6+ years of experience as an independent researcher covering corporate misconduct, sourced from legal documents, regulatory filings, and professional legal databases.

My background includes a Supply Chain Management degree from Michigan State University's Eli Broad College of Business, and years working inside the industries I now cover.

Every post on this site was either written or personally reviewed and edited by me before publication.

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