A company that manufactures pesticides went silent with federal regulators for three straight years, and the United States government’s response was a fine of $1,300 (roughly what a minimum-wage worker earns in one week before taxes).

Three Years, Three Strikes, Zero Accountability

Earth Laboratories, Inc. operates a registered pesticide-producing facility at 1011 East Diamond Avenue, Evansville, Indiana, carrying EPA Establishment Number 84198-IN-1. Under federal law, specifically Section 7(c) of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), every registered pesticide producer must file an annual report telling the EPA exactly what pesticides they are making, what they made last year, and what they sold or distributed. The deadline is every year by March 1. No exceptions.

Earth Laboratories failed that obligation three separate times. First, the company submitted its 2021 annual report with an invalid EPA Registration Number for its product called PEROXY HDOX. A registration number that does not exist in federal records is a report that cannot be verified. The EPA had no way to confirm what Earth Laboratories actually produced that year.

Then the company went further. The 2022 annual report was due by March 1, 2023. Earth Laboratories did not file it until April 9, 2025. That is more than two years late. The 2023 annual report was due by March 1, 2024. Earth Laboratories filed that one on the exact same day in April 2025. The company packaged two years of delinquent compliance into a single catch-up filing, three years after the first deadline passed.

The Timeline: Watch the Gaps

• February 2022 Earth Laboratories submits its 2021 annual report with an invalid EPA Registration Number for PEROXY HDOX. The report is incomplete and unverifiable.
• March 1, 2023 Deadline for the 2022 annual pesticide production report. Earth Laboratories files nothing.
• March 1, 2024 Deadline for the 2023 annual pesticide production report. Earth Laboratories files nothing.
• April 9, 2025 Earth Laboratories files both the 2022 and 2023 annual reports on the same day, more than two years and one year late, respectively.
• September 30, 2025 Company President Jennifer M. Richardt signs the EPA settlement agreement.
• October 1, 2025 EPA Acting Division Director Carolyn Persoon executes the Final Order. The $1,300 (roughly one week of pre-tax pay for a minimum-wage worker) penalty is assessed.

The Non-Financial Ledger

What a $1,300 Fine Actually Says About Who This System Protects

Federal pesticide reporting requirements exist for a reason that has nothing to do with bureaucracy and everything to do with public safety. When a company that produces pesticides tells the EPA what it is making, how much it made, and what it sold, regulators can track chemical exposure risks, detect unreported hazards, and connect production volumes to public health data. When a company stops reporting, that chain of accountability breaks.

Earth Laboratories produced and distributed pesticide products during 2022 and 2023 while the EPA had no verified, current information about what those products were or how much the company was shipping into the market. The 2021 report listed an invalid registration number for PEROXY HDOX, meaning the EPA could not cross-check the product against its own official database for that filing year. For three consecutive reporting cycles, federal oversight of this company’s chemical output was either incomplete or entirely absent.

The fine the EPA assessed for this three-year blackout: $1,300 (less than the average American pays for a single month of rent in most mid-sized cities). Divided across three separate, distinct violations, that comes to roughly $433 per violation. The cost of a single mistake to a company registered to manufacture pesticides in the United States is four hundred and thirty-three dollars. That number tells you everything about whose interests enforcement is designed to protect.

The settlement language adds its own layer of insulation. Earth Laboratories signed the agreement while explicitly “neither admitting nor denying the factual allegations contained herein.” The company consented to the penalty without ever being required to stand in front of a judge, a community, or the public and acknowledge that it broke federal law three times. The legal mechanism that was designed to resolve the case also guaranteed the company a clean exit from any public reckoning.

The settlement also carries a provision that the civil penalty “is not deductible for federal tax purposes.” That restriction exists precisely because the law recognizes that a deductible fine is not really a fine at all; it is a subsidized business expense. But at $1,300 (less than most Americans spend on utilities in a single winter), non-deductibility is cold comfort. The financial consequence of three federal violations remains laughably low regardless of how it is categorized on a tax return.

What does a company learn from a $1,300 settlement after three years of non-compliance? The math sends a clear message: the cost of compliance may well exceed the cost of getting caught. Filing accurate pesticide production reports requires time, staff, and attention. Ignoring them for three years and then filing two reports at once costs a company $1,300 and a signature. The structural incentive created by this enforcement action points in exactly the wrong direction.

Legal Receipts: What the Document Actually Says

Straight From the Settlement Agreement

“Section 7(c) of FIFRA, 7 U.S.C. § 136e(c), requires any producer operating a registered pesticide-producing establishment to inform EPA of the types and amounts of pesticides (and, if applicable, active ingredients used in producing pesticides): which it is producing; which it has produced during the past year; and which it has sold or distributed during the past year.” EPA Expedited Settlement Agreement and Final Order, Paragraph 2

“On or about February 2022, Respondent submitted an incomplete pesticide-production report for the 2021 calendar year by including an invalid EPA Registration Number for the product PEROXY HDOX, EPA Registration Number 84198-1.” EPA Expedited Settlement Agreement and Final Order, Paragraph 6

“Respondent’s annual report for the calendar year 2022 was late, as it was submitted on or about April 9, 2025. Respondent’s annual report for the calendar year 2023 was late, as it was submitted on or about April 9, 2025.” EPA Expedited Settlement Agreement and Final Order, Paragraphs 7 and 8

“Respondent’s three failures to comply with Section 7(c) of FIFRA and 40 C.F.R. § 167.85 constitute three violations of Section 12(a)(2)(L) of FIFRA, 7 U.S.C. § 136j(a)(2)(L).” EPA Expedited Settlement Agreement and Final Order, Paragraph 9

“In signing this Agreement, Respondent: (a) admits that Respondent is subject to the requirements in Paragraphs 2 through 5 above; (b) admits that EPA has jurisdiction over Respondent and Respondent’s conduct as alleged herein; (c) neither admits nor denies the factual allegations contained herein; (d) consents to the assessment of this penalty; and (e) waives any right to contest the allegations contained herein, and its right to appeal the proposed Final Order attached hereto.” EPA Expedited Settlement Agreement and Final Order, Paragraph 12

The Numbers, Side by Side

Societal Impact Mapping

Public Health: When Pesticide Oversight Goes Dark

FIFRA’s annual reporting requirement is one of the primary mechanisms the federal government uses to track what pesticides are being produced and sold in the United States. Without accurate, timely production reports from registered manufacturers, the EPA cannot maintain a current picture of chemical exposure risk across communities. Earth Laboratories produced and distributed pesticides during 2022 and 2023 while regulators had no verified data on record for those years.

The product flagged in the 2021 incomplete report, PEROXY HDOX, carried an invalid EPA Registration Number. Without a valid registration number, that product cannot be cross-referenced against the EPA’s official registry of approved formulations, label requirements, or safety profiles. Anyone downstream from that product, including distributors, applicators, or end users, had no regulatory guarantee that the EPA had verified its registration.

Pesticide exposure is not an abstract concern. Chemical producers in residential and agricultural regions carry outsized responsibility to regulators and the communities around them. Three years of unverified or absent production reporting from a facility in Evansville, Indiana represents exactly the kind of gap in the federal safety net that public health officials warn about. The settlement does not require Earth Laboratories to conduct remediation, issue public notice, or undergo additional auditing. It requires a $1,300 (less than the average American pays for a single month of health insurance premiums) check.

Economic Inequality: The Two-Tiered Fine System

The penalty structure revealed in this case illustrates a pattern that runs throughout environmental enforcement in the United States. A private individual who violates federal chemical regulations faces possible criminal referral, reputational destruction, and civil liability that can exceed their net worth. A registered corporate producer faces a negotiated settlement with no admission of guilt and a fine calibrated so low that it functions as a cost of doing business rather than a deterrent.

The settlement explicitly states that each party bears its own costs and fees, and that the civil penalty resolves only liability for the specific violations alleged. The EPA reserves rights to pursue future violations but issued no enhanced monitoring requirement, no third-party audit mandate, and no corrective action plan beyond the company’s own certification that it is currently complying. The accountability gap between what was alleged and what was actually required lands entirely on the public, not the company.

What Now?

The People Involved

• Jennifer M. Richardt — President, Earth Laboratories, Inc. Signed the settlement agreement on behalf of the company.
• Carolyn Persoon — Acting Division Director, Enforcement and Compliance Assurance Division, EPA Region 5. Approved the settlement on behalf of the EPA.
• Earth Laboratories, Inc. — Registered pesticide producer, 1011 East Diamond Avenue, Evansville, Indiana 47711. EPA Establishment Number 84198-IN-1.

Watchlist: Who Regulates This

• U.S. EPA Region 5 — The regional office responsible for enforcement in Indiana and five other states. Contact them directly with concerns about pesticide producers in your region.
• EPA Pesticides and Toxics Compliance Section — The unit that processed this case. They can be pushed on enforcement adequacy through public comment and congressional pressure.
• EPA Office of Inspector General — Has oversight authority over enforcement decisions and can audit whether penalty amounts reflect actual deterrence policy.
• Indiana Department of Environmental Management (IDEM) — State-level regulator for facilities in Indiana. State agencies can act independently of federal settlement resolutions.
• U.S. Congress — FIFRA’s penalty ceiling and enforcement funding are both subject to legislative action. Your representative controls the budget that determines whether the EPA has the staff to pursue more than a $1,300 settlement.

The Organizing Angle

Settlements like this one do not happen in a vacuum. They happen because enforcement agencies are under-resourced, under-staffed, and structurally discouraged from pursuing costly litigation against companies that can afford to lawyer up. The answer is local: connect with environmental justice organizations in Indiana, support groups that monitor industrial facilities in your zip code, and push your state legislators to fund IDEM adequately so state enforcement can pick up where federal enforcement leaves soft. Community air and water monitoring projects exist in many regions and give residents direct data independent of what companies self-report. Find them. Fund them. Trust the data over the press releases.