Environmental enforcement EPA Region 9
EPA alleged that an imported horse-fly trap carried the wrong establishment number. A final consent order imposed one civil penalty, while leaving the quantity of products and the precise corrective action outside the public record.
What the order says
- EPA alleged that Bedoukian Research imported the H Trap Professional Horse Fly Control System through the Los Angeles and Long Beach seaport on May 27, 2026.
- The label displayed establishment number
92752-CH-1. EPA said the correct number was92752-CHN-1. - Because the product claimed to catch and control horse flies, EPA treated it as a pest-control device regulated under the Federal Insecticide, Fungicide, and Rodenticide Act.
- The final order assessed a $2,700 civil penalty for one alleged unlawful distribution or sale of a misbranded device.
- Bedoukian consented to the penalty and waived its right to contest the case, but neither admitted nor denied the factual allegations.
- The order does not identify the number of traps involved, describe a performance defect, or allege injury to people or the environment.
The enforcement action turns on a one-letter labeling discrepancy, but the public document does not explain how the error occurred.
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 documentary chain
Evidence status: EPA allegations resolved through a consent order, not factual admissions by Bedoukian.
- Label displayed
92752-CH-1- EPA says required
92752-CHN-1- Agency classification
- A device under FIFRA because the product was marketed to catch and control horse flies.
- Alleged violation
- One unlawful distribution or sale of a misbranded device under FIFRA section 12(a)(1)(F).
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.
Bedoukian agreed to
- Accept EPA’s jurisdiction over the company and the alleged conduct.
- Consent to the civil penalty.
- Waive the right to contest the allegations or appeal the final order.
- Waive defenses that could have moved the matter into federal court.
The agreement does not say
- That Bedoukian admitted the factual allegations.
- That the trap failed to catch horse flies.
- That a consumer was injured or financially harmed.
- That environmental damage occurred.
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.
EPA alleged that Bedoukian imported the H Trap in a specified entry at the Los Angeles and Long Beach seaport.
The respondent’s representative, EPA enforcement official, and regional judicial officer signed the agreement or final order.
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.
What remains unknown from this record
- The number of H Trap units in the import entry.
- The origin of the discrepancy between
CHandCHN. - The exact action used to bring the product into compliance.
- Whether any units reached end users before the issue was addressed.
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.
Explore by category
Antitrust
Monopolies and anti-competition tactics used to crush rivals.
View Cases →Product Safety Violations
When companies sell dangerous goods, consumers pay the price.
View Cases →Environmental Violations
Pollution, ecological collapse, and unchecked greed.
View Cases →Labor Exploitation
Wage theft, worker abuse, and unsafe conditions.
View Cases →Data Breaches & Privacy
Misuse and mishandling of personal information.
View Cases →Financial Fraud & Corruption
Lies, scams, and executive impunity that distort markets.
View Cases →Intellectual Property
IP theft that punishes originality and rewards copying.
View Cases →Misleading Marketing
False claims that waste money and bury critical safety info.
View Cases →


