The Operation: Unregistered, Unauthorized, and Straight to Market

The Facts Buchheit Agri, Inc., headquartered in Perryville, Missouri, is a pesticide producer, dealer, and distributor with approximately 100 employees. On October 21, 2024, an inspector from the Missouri Department of Agriculture walked into the Buchheit Agri facility at 33 PCR 540 in Perryville and found a product called NUTRA Pak Cattle Mineral (Fly Control) sitting there, being held for distribution and sale.

The Misconduct That product contained Diflubenzuron Cattle Supplement, a regulated pesticide ingredient registered under EPA Registration Number 89459-2, owned by Central Garden & Pet Company. Buchheit Agri did not own the rights to that pesticide. The company had no written contract with Central Garden & Pet Company to repackage it, distribute it, or sell it under any circumstances. None. Zero. The agreement that federal law requires simply did not exist.

The facility itself was not registered with the EPA to produce pesticides, which is a separate and additional legal violation. Federal law requires any establishment that produces a pesticidal product to register with the EPA. Buchheit Agri never did that. Under federal law, “producing” a pesticide includes repackaging it into a new container, and that is exactly what Buchheit Agri did when it put Diflubenzuron into its NUTRA Pak branded packaging and put it on the shelf.

Three Violations, One Facility, No Accountability Worth the Name

The EPA charged Buchheit Agri with three distinct violations of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Each violation is its own separate offense. Each offense carries a maximum civil penalty of $23,494 (roughly the annual federal minimum wage take-home pay for a full-time worker). The EPA settled all three counts for a combined $12,610 (about what a family of four spends on groceries in four months).

• 1 Production of a Pesticide at an Unregistered Facility. Buchheit Agri manufactured NUTRA Pak Cattle Mineral (Fly Control) at a facility that carried zero EPA registration for pesticide production. The company admitted this to inspectors.
• 2 Sale of an Unregistered and Illegally Repackaged Pesticide. Without a registration, without a written contract with the pesticide’s owner, and without the correct label, Buchheit Agri distributed and sold the repackaged Diflubenzuron product. Every single distribution and sale constitutes a separate violation under FIFRA.
• 3 Misbranding. The NUTRA Pak label was stripped of critical federally mandated information: complete directions for use, use restrictions, human hazard warnings, domestic animal hazard warnings, environmental hazard warnings, and directions for storage and disposal. All missing. All illegal.

The Fine vs. The Law: A Math Problem That Should Enrage You

Federal law sets a maximum penalty of $23,494 per offense for FIFRA violations. Buchheit Agri committed three separate offenses. That means the maximum possible penalty was $70,482 (about what the average American worker earns in two full years of labor). The EPA settled for $12,610. That is 17.9 cents on every dollar of maximum accountability.

Three violations. Three instances where the law set a ceiling of $23,494 per offense. The EPA collected $12,610 total (about what someone working minimum wage earns in five months of full-time work). That is not justice. That is a business expense.

The Non-Financial Ledger: What the Settlement Cannot Repay

The Misconduct Start with this fact: the label that farmers and agricultural workers received on NUTRA Pak Cattle Mineral (Fly Control) was missing hazard and precautionary statements for human hazards. That means the people handling this product, mixing it into feed, breathing it in during dispensing, or getting it on their skin while working a farm, had no federally mandated warning telling them it was a pesticide-containing product requiring protective measures. The label that existed was not the real label. It was a stripped-down, rebranded package that concealed the nature of what was inside.

Diflubenzuron is an insect growth regulator classified as a pesticide under federal law. It is used in fly control because it disrupts insect development. The EPA requires specific, detailed handling instructions, storage directives, and environmental precaution language on any product containing it, because the risks of mishandling are real. Every one of those required warnings was absent from the NUTRA Pak product. The document filed by the EPA explicitly states the label was missing “hazard and precautionary statements for human, domestic, and environmental hazards.” That is not a typo. That is what inspectors found.

The label was also missing directions for storage and disposal. Storage and disposal instructions for pesticides exist because improper disposal contaminates soil and water, and improper storage near heat, food, or incompatible chemicals can create dangerous situations. A farmer who bought NUTRA Pak Cattle Mineral had no idea how to safely get rid of empty containers, where to store the product safely on their property, or what to do in the event of a spill or exposure. Buchheit Agri sold them a product stripped of the basic safety infrastructure that federal law designed specifically to protect them.

There is also the question of livestock and the environment. The NUTRA Pak label was missing directions for environmental hazards. Diflubenzuron, when it enters water systems through runoff or improper disposal, can harm aquatic invertebrates, insects, and other non-target organisms. The legal label exists precisely to prevent that contamination. Buchheit Agri removed those warnings from its repackaged product. Every farm operator who bought and used NUTRA Pak without the environmental precautionary language was one accidental spill or one improper container disposal away from a contamination event they had no knowledge to prevent.

None of this touches the question of trust. Farmers who purchased NUTRA Pak Cattle Mineral did so from a company that markets itself as an agricultural supplier. They did not purchase an unregistered pesticide assembled in an unlicensed facility with fabricated branding. They did not consent to receiving a product stripped of safety information. They trusted a supply chain, and that supply chain ran an illegal operation behind their backs.

The company had 100 employees at this facility. Someone packaged this product. Someone put the label on the container. Someone shelved it or loaded it for distribution. The EPA settlement resolves Buchheit Agri’s civil liability for federal penalties. It does not answer who at the company knew the facility was unregistered. It does not reveal how long this operation ran before the Missouri Department of Agriculture showed up on October 21, 2024. The document only describes what inspectors found that day. The full ledger of how many units moved, how many farms received this product, and how many people handled a mislabeled pesticide without knowing it, remains unwritten and unpublished.

Legal Receipts: What the Government Actually Said

These are direct statements from the EPA’s Consent Agreement and Final Order. Nothing paraphrased. Nothing softened.

“The NUTRA PAK label was incomplete and missing elements required under Section 2(q) of FIFRA, 7 U.S.C. § 136(q) and 40 C.F.R. Part 156, including but not limited to: complete directions for use; use restrictions; hazard and precautionary statements for human, domestic, and environmental hazards; and directions for storage and disposal.” EPA Consent Agreement and Final Order, Paragraph 67 — Count 3, Misbranding

“At the time of the inspection, Respondent did not have a written contract with Central Garden & Pet Company to repackage, distribute, or sell the pesticide identified in Paragraph 32.” EPA Consent Agreement and Final Order, Paragraph 35 — General Factual Allegations

“Respondent’s distribution and sale of repackaged Diflubenzuron Cattle Supplement without obtaining a registration nor meeting all of the conditions in 40 C.F.R. § 165.70(b) constitutes separate distributions of an unregistered pesticide, each of which is a separate violation of Section 12(a)(1)(A) of FIFRA.” EPA Consent Agreement and Final Order, Paragraph 58 — Count 2, Sale of Unregistered and/or Illegally Packaged Pesticide

“The Respondent admitted that the product is NUTRA Pak Cattle Mineral (Fly Control), was in fact, produced at the Facility.” EPA Consent Agreement and Final Order, Paragraph 47 — Count 1, Production of a Pesticide at an Unregistered Facility

“Respondent’s production of NUTRA Pak Cattle Mineral (Fly Control) without obtaining an establishment registration constitutes the production of a pesticide in an unregistered establishment, which is a violation of 12(a)(1)(A) of FIFRA.” EPA Consent Agreement and Final Order, Paragraph 49 — Count 1, Production of a Pesticide at an Unregistered Facility

Societal Impact Mapping

Environmental Degradation: The Label They Removed Was All That Stood Between This Chemical and Your Watershed

The Misconduct The NUTRA Pak label was missing “hazard and precautionary statements for environmental hazards.” Federal pesticide labeling law mandates those statements for exactly one reason: because pesticides like Diflubenzuron can contaminate ecosystems when used, stored, or disposed of improperly. Diflubenzuron works by preventing insects from developing their exoskeletons. It does not distinguish between the flies you want to kill and the aquatic insects, crustaceans, and beneficial organisms in nearby streams, ponds, or drainage ditches.

Agricultural facilities generate runoff. Containers get rinsed. Empty bags blow away. All of this is managed by the safe-use and disposal instructions that Buchheit Agri removed from its product label. Every farm that received NUTRA Pak without the environmental precaution language operated without the information the federal government determined was necessary to protect surrounding land and water. The inspection happened on October 21, 2024. The document does not specify how long Buchheit Agri operated this way before the inspection. That gap in the public record is its own kind of environmental risk.

Public Health: No Warnings for the Workers Mixing It into Feed

The Misconduct The EPA’s document confirms the NUTRA Pak label was missing hazard and precautionary statements for human hazards. Farm workers who handle pesticide-containing products are entitled to know what they are handling. FIFRA labeling requirements for human hazard statements exist because exposure to pesticide-grade compounds through skin contact, inhalation, or eye exposure can cause harm, and the appropriate first aid and protective equipment recommendations depend on knowing what the product contains.

A farm employee mixing NUTRA Pak Cattle Mineral into a feed supplement had no federally mandated warning telling them gloves were required, that the product should be kept away from eyes, or what to do if it splashed onto skin. The legitimate Diflubenzuron Cattle Supplement label, owned by Central Garden & Pet Company and dated May 1, 2019, carried all of that information. Buchheit Agri’s repackaged version did not. The company stripped that information off and sold the product anyway. The human beings on the receiving end of that decision worked without protection they had a legal right to receive.

Economic Inequality: A $12,610 Fine Is Cheaper Than Doing It Right

The Misconduct Registering a pesticide establishment with the EPA has an associated cost and compliance process. Entering into a legitimate written repackaging contract with a pesticide registrant like Central Garden & Pet Company takes time and money. Properly labeling a product with all federally required hazard statements, directions, and registration numbers is a compliance burden. Buchheit Agri, a company with 100 employees, skipped all of it and sold the product anyway.

The penalty for all of that was $12,610 (roughly the cost of a second-hand pickup truck or about four months of rent for a family in rural Missouri). Legitimate competitors in the agricultural supply market who go through proper EPA registration and labeling compliance carry costs that Buchheit Agri did not pay. That is not a level playing field. Every agricultural supplier who followed the law competed against a company that was cutting corners on federal pesticide safety requirements and paying a fine smaller than most regulatory violations receive. The settlement lets Buchheit Agri walk away from all of this for less than the average American earns in six months of full-time minimum wage work.

The “Cost of a Life” Metric

What Now? Here Is What You Can Actually Do

The Resistance The regulatory bodies with ongoing jurisdiction over this company and this industry are named below. They have public complaint processes. Use them.

• EPA Region 7 Enforcement: The EPA’s Enforcement and Compliance Assurance Division in Lenexa, Kansas filed and resolved this case. Future violations go back to them. The reservation of rights in this settlement means EPA can pursue additional enforcement if Buchheit Agri steps out of line again.
• Missouri Department of Agriculture: State inspectors caught this. State agricultural departments have their own inspection and enforcement authority. Missouri residents can file concerns about agricultural pesticide violations directly with the state department.
• EPA’s Pesticide Complaint Line: If you purchased NUTRA Pak Cattle Mineral (Fly Control) from Buchheit Agri and your label was missing safety information, report it. The EPA takes pesticide misbranding complaints and can use them to build further enforcement records.
• OSHA (Occupational Safety and Health Administration): Workers at this facility or on farms that received this mislabeled product had rights to hazard information under federal occupational safety law. OSHA handles worker complaints about exposure to unlabeled or mislabeled hazardous substances.
• EPA’s FIFRA Watchlist: Keep tabs on Buchheit Agri, Inc. The settlement explicitly reserves EPA’s right to pursue enforcement for any other violations of FIFRA. One inspection is not the end of the road.

Beyond the Regulators: Build the Infrastructure That Doesn’t Depend on Them

Regulatory agencies caught this one, but the settlement shows the limits of what those agencies deliver. The fine is smaller than the harm. The answer is local: know your agricultural suppliers, support regional farmers’ coalitions that share information about supply chain safety violations, and back mutual aid networks that connect farmworkers to legal resources when they are exposed to unlabeled pesticides on the job. The people who handle these chemicals every day deserve to know what is in every product they touch. That knowledge should not depend on whether a company feels like following the law.