The Missing “N” Behind Bedoukian’s $2,700 EPA Settlement

One letter separated the label from the registered establishment

The difference was an “N.” EPA alleged that Bedoukian Research imported a horse-fly trap whose label showed 92752-CH-1, rather than the establishment number 92752-CHN-1 for the EPA-registered facility where the device was produced.

The product was the H Trap Professional Horse Fly Control System. According to the order, its label called it a “Horse Fly Control System,” said it was “for catching tabanids,” and claimed to offer “effective and easy control of horse flies (tabanids).” Those pest-control claims mattered because FIFRA defines a regulated device to include an instrument intended to trap, destroy, repel, or mitigate a pest.

“effective and easy control of horse flies (tabanids)”

Product-label language quoted in the EPA order

FIFRA makes it unlawful to distribute or sell a misbranded device. The order states that a device may be misbranded when its label does not carry the establishment number of the final EPA-registered establishment where it was produced. EPA applied that rule to the number on this label.

The word “sale” does not necessarily mean the order documents a retail purchase by a consumer. The statutory definition quoted in the agreement is broader. It includes holding for shipment, shipping, delivering, and receiving and then delivering or offering to deliver. The single count also does not establish that only one physical trap was involved. The order does not disclose the quantity in the shipment.

What Bedoukian accepted, and what it did not admit

The settlement became a final order when it was filed with EPA’s Regional Hearing Clerk on September 2, 2026. It requires Bedoukian to pay $2,700 within 30 days and prevents the company from claiming the payment or related interest as an income-tax deduction.

The distinction is explicit. Bedoukian “neither admits nor denies” the factual allegations, even as it accepts the penalty and gives up the right to challenge them. The order therefore documents a binding settlement, not a litigated factual finding after a trial.

EPA also stated that if Bedoukian declined the expedited agreement, the agency could pursue more formal enforcement and seek up to $24,885 per violation, adjusted for inflation. That larger figure was a stated potential maximum, not the penalty imposed.

1. May 27, 2026

   EPA alleged that Bedoukian imported the H Trap in a specified entry at the Los Angeles and Long Beach seaport.

2. August 27, 2026

   The respondent’s representative, EPA enforcement official, and regional judicial officer signed the agreement or final order.

3. September 2, 2026

   The order was filed at 4:23 p.m. and became effective upon filing.

The public order stops short of the corrective details

Paragraph 19 says Bedoukian certified under penalty of perjury that it had supplied a detailed explanation of how compliance was achieved. That explanation was supposed to identify the date, location, action taken, quantity of product brought into compliance, and supporting information such as product images. If correction was not possible, the company was to report steps intended to prevent another violation.

The seven-page order does not reproduce that submission. As a result, the supplied record does not show whether the products were relabeled, withheld, returned, or handled another way. It also does not reveal how many units were involved or what caused the establishment number to be printed incorrectly.

This is a labeling case, not a documented injury case

The order does not allege that the H Trap malfunctioned, contained a hazardous substance, injured a person, or damaged the environment. It focuses on whether a pest-control device carried the establishment identifier required by federal law.

That limitation matters. Calling the product “misbranded” is a legal characterization tied here to the establishment number. It should not be read as an EPA finding that every product claim was false or that the trap itself was unsafe.

At the same time, the one-character difference was not treated as optional paperwork. EPA alleged a federal violation, obtained a final order, and required both a penalty and a certified compliance explanation. The settlement resolves Bedoukian’s federal civil-penalty liability only for the violation and facts alleged in this matter.

The record tells a narrow but complete enforcement story: one imported entry, one disputed label identifier, one settled count. It establishes how EPA treated the discrepancy. It does not establish the shipment’s scale, the cause of the error, or harm to consumers or the environment.