What Etimine Did, Step by Step

The EPA’s findings lay out a straightforward industrial operation: import a chemical, repackage it, ship it. The problem is that every step of that operation violated federal pesticide law.

• Etidot-67 (EPA Reg. No. 90788-1) is a registered pesticide. Its registration number means it has been reviewed and approved under specific conditions, including mandatory labeling requirements that exist to protect anyone who handles, stores, or disposes of it.
• On July 8, 2023, Etimine imported a shipment of Etidot-67 from the Republic of Turkey through Entry # 669-XXXX600-5. Federal regulations at 19 C.F.R. § 12.112(a) required Etimine to file a Notice of Arrival with the EPA administrator before that shipment reached U.S. soil. Etimine did not file it on time.
• The Notice of Arrival exists for one reason: it gives the EPA a window to review active ingredients, quantities, and ports of entry before a pesticide lands in the country. Skipping it eliminates that review entirely. The pesticide enters, and the government finds out after the fact.
• Etimine received the shipment in large supersac containers at its EPA-registered producing establishment at 700 New Castle Avenue, Wilmington, Delaware 19801. At that facility, company workers repackaged the product into smaller containers for distribution.
• The labels on those imported containers were missing: the EPA registration number, the EPA establishment number for the last place of production, a complete ingredients statement identifying each active ingredient by name and percentage by weight, a Full First Aid statement, precautionary statements covering hazards to humans and domestic animals, and directions for use including storage and disposal procedures.
• After repackaging, Etimine shipped the product to customers. Under Section 12(a)(1)(E) of FIFRA, distributing a misbranded pesticide is itself an unlawful act, separate from any failure in the importing step.

The Non-Financial Ledger

Pesticide labels are not paperwork. They are instructions for not getting hurt.

When you handle a concentrated pesticide, the label is the only thing standing between you and a serious exposure incident. It tells you whether you need gloves. It tells you whether the fumes are dangerous in a closed space. It tells you what to do if someone swallows it, inhales it, or gets it in their eyes. It tells you how to store it so it does not react with other chemicals in a warehouse. It tells you how to dispose of the containers so the residue does not contaminate soil or groundwater.

The supersac containers that arrived from Turkey and landed at Etimine’s Delaware facility were missing all of that. No First Aid statement. No hazard warnings for humans or domestic animals. No environmental hazard section. No storage or disposal instructions. No list of active ingredients by percentage, which means a worker could not even look up the chemical to find independent safety guidance.

Etimine’s own representative told the EPA inspector what happened next: the material was repackaged and shipped to customers. Those customers, and their workers, received a pesticide with the same incomplete labels. They had no way of knowing what was missing because a missing label does not announce itself. It just is not there.

Boron-based compounds, which is the product category Etidot-67 belongs to based on the “Eti” naming convention associated with Turkish boron producer Eti Maden and Etimine’s role as its U.S. distributor, can cause irritation to the eyes, skin, and respiratory tract. The point is not that Etidot-67 is uniquely lethal. The point is that the people who received it were given no information to make that assessment themselves.

The penalty for this is $12,600. A single emergency room visit for an occupational chemical exposure costs more than that in the United States. The company that distributed an unlabeled pesticide to an unknown number of customers pays less than the cost of treating one person harmed by what they distributed.

There is no figure in this enforcement action for the workers who handled the product. There is no count of how many customers received it. There is no list of facilities where the repackaged pesticide ended up. The Consent Agreement resolves the legal claim. It does not resolve what happened to anyone who handled this material without knowing what it was.

Legal Receipts: Straight from the Document

These are verbatim quotes from EPA Docket No. FIFRA-03-2025-0063. Etimine signed this document on April 15, 2025.

“EPA alleges that, on July 8, 2023, Respondent imported the pesticide Etidot-67 from the Republic of Türkiye into the United States, via Entry # 669-XXXX600-5, for distribution or sale to individuals, associations, partnerships, corporations, or other organized groups of persons.” — Consent Agreement, Paragraph 30, EPA Docket No. FIFRA-03-2025-0063

• This establishes the core unlawful act: a pesticide crossed into the U.S. for commercial distribution without the legally required pre-arrival notice to the EPA.
• The entry number (669-XXXX600-5) is a U.S. Customs filing. The product cleared the border as commercial merchandise before the EPA had reviewed it.

“The importer reports vital information to EPA such as the major active ingredients, quantity, port of entry, and points of contact, which allows EPA to make informed decisions, before pesticides arrive in the United States, as to whether such importation will pose unreasonable adverse effects on public health and the environment.” — Consent Agreement, Paragraph 28, EPA Docket No. FIFRA-03-2025-0063

• The EPA is explaining, in its own language, exactly what was lost when Etimine skipped the Notice of Arrival: the opportunity to evaluate public health risk before the shipment arrived.
• This was not a technicality. This was the entire review mechanism, bypassed.

“EPA alleges that the label affixed to the pesticide Etidot-67, which was allegedly imported by Respondent on July 8, 2023 . . . was missing the following information required by Sections 2(q)(1) and (2) of FIFRA: EPA Pesticide Registration Number; EPA producing establishment number of the last place of production; Complete ingredients statement which contains the name and percentage by weight of each active ingredient; Full First Aid statement; Full precautionary statements (hazard to humans and domestic animals, user safety recommendations, environmental hazards); and Directions for use, including storage and disposal.” — Consent Agreement, Paragraph 38(a)–(f), EPA Docket No. FIFRA-03-2025-0063

• This is not a list of minor oversights. Six separate categories of mandatory label information were absent. Each category corresponds to a specific protection for a specific class of person: workers, handlers, emergency responders, and the public.
• The “Complete ingredients statement” requirement exists so that a poison control center or emergency room physician can identify what a patient was exposed to. Its absence is directly dangerous in an acute exposure scenario.
• The “Directions for use, including storage and disposal” requirement exists to prevent secondary exposures, chemical reactions in storage, and environmental contamination from improper disposal. None of those risks were addressed on the product as distributed.

“Respondent neither admits nor denies the specific factual allegations set forth in this Consent Agreement. This CAFO shall not be used as evidence in any other proceeding, except any proceeding to which the EPA is a party.” — Consent Agreement, Paragraph 6, EPA Docket No. FIFRA-03-2025-0063

• This is standard settlement language, but its implications are real: Etimine pays $12,600 and the legal record of wrongdoing cannot be used against it in civil litigation by any harmed party who did not know about the label deficiencies.
• Anyone harmed by this product who tries to sue Etimine cannot point to this settlement as proof of liability. The company bought legal closure without admitting anything.

“Respondent consents to the assessment of the civil penalty stated herein, to the issuance of any specified compliance order herein, and to any conditions specified herein.” — Consent Agreement, Paragraph 9, EPA Docket No. FIFRA-03-2025-0063

• Combined with the waivers in Paragraphs 8 and 11, Etimine also waived its right to a jury trial and its right to challenge the lawfulness of the Final Order. It accepted the penalty and closed the case administratively.
• There was no court proceeding. No judge reviewed the facts independently. An administrative process resolved a violation that put an unlabeled pesticide into commercial distribution.

What the System Promised vs. What Happened

FIFRA creates a specific sequence of checks designed to ensure pesticides reaching U.S. workers and consumers are reviewed, labeled, and safe to handle. Here is how that sequence was supposed to work, and what Etimine’s conduct produced instead.

Societal Impact Mapping

Public Health

The mandatory labeling requirements Etimine violated are not bureaucratic formality. They are the practical safety infrastructure that protects workers, emergency responders, and communities along the supply chain.

• The absence of a Full First Aid statement means that if a worker inhaled, ingested, or had skin or eye contact with Etidot-67, they or a coworker would have had no immediate guidance on what to do. Time matters in a chemical exposure incident, and the label is often the only resource available in the first minutes.
• Without a complete ingredients statement listing each active ingredient by name and percentage by weight, any hospital or poison control center contacted during an exposure incident could not accurately identify what the patient was exposed to. This directly impairs medical treatment.
• The missing precautionary statements covering hazards to humans and domestic animals left customers and their employees without information on whether the product required respiratory protection, protective clothing, or ventilation. Those decisions were made blind.
• The unlabeled product was distributed to “individuals, associations, partnerships, corporations, or other organized groups of persons,” per Paragraph 30 of the Consent Agreement. The total number of end recipients is not disclosed in the enforcement document. The scope of exposure risk is unknown.

Economic Inequality

The $12,600 penalty in this case structures a cost calculus that benefits larger companies at the expense of workers who lack the resources to protect themselves independently.

• A $12,600 fine is a negligible operational cost for a company with a registered EPA producing establishment, legal representation from Nixon Peabody LLP, and a multi-year import operation. Nixon Peabody’s hourly rates alone likely exceeded this fine during the October and December 2024 conference calls with the EPA.
• Workers who handled the mislabeled product had no independent means to verify what they were handling. The label is the only accessible information source for most workers. Without it, the cost of any resulting health impact, including medical bills, lost wages, and long-term monitoring, falls on the worker, not the distributor.
• The Consent Agreement explicitly states that penalties and interest are not deductible for federal tax purposes (Paragraph 48), but the underlying legal fees defending the case almost certainly are, making the real net cost of this enforcement action lower than the headline number.
• Small businesses that received and used this product in their own operations may face secondary liability or compliance costs if their own inspections reveal they were storing or using a pesticide with deficient labeling, a problem entirely created by Etimine’s conduct and entirely not their fault.
• The enforcement timeline itself reflects resource inequality: the violation occurred in July 2023, the inspection in August 2023, the Show Cause letter in August 2024. Over a year elapsed before the EPA formally notified Etimine of its intent to pursue a penalty. An unrepresented individual facing the same scrutiny would not have had a year of breathing room.

The “Cost of a Life” Metric

What Was Missing from the Label

A lawful pesticide label is not a single piece of text. It is a structured disclosure framework. Here is the breakdown of what Etimine’s imported Etidot-67 labels were missing, and what each component is designed to protect.

What Now? Who to Watch and What to Do

Etimine USA is still operating. The consent agreement certifies current compliance, but the EPA explicitly reserved its right to pursue further action. Here is who holds accountability and where pressure can go.

Key Actors Named in the Docket

• Goksen Elkas, Vice President and Technical Director, Etimine USA, Inc. Named directly in the Certificate of Service as a recipient of the final order. This is the executive with direct responsibility for technical and compliance operations at Etimine.
• Karen Melvin, Director, Enforcement and Compliance Assurance Division, U.S. EPA Region 3. Signed the Consent Agreement on the government’s side. Her division is the watchdog.
• Holly Raguza, Compliance Officer, U.S. EPA Region 3. Named as a case recipient. She is the monitoring contact for ongoing compliance.
• Joseph J. Lisa, Regional Judicial and Presiding Officer, U.S. EPA Region 3. Signed the Final Order. His office is the administrative court of record for this case.

Regulatory Watchlist

• U.S. EPA Region 3 (Philadelphia): Primary jurisdiction over this case. The EPA can pursue further action for any imminent endangerment under the reserved rights in Paragraph 55. File complaints via EPA’s online enforcement reporting portal.
• U.S. Customs and Border Protection (CBP): CBP’s Automated Broker Interface processes pesticide import entries. The Notice of Arrival can also be filed electronically through CBP-authorized systems. CBP’s Trade Compliance division has independent authority to flag pesticide shipments for EPA review.
• OSHA (Occupational Safety and Health Administration): If workers at Etimine’s Delaware facility or at customer sites handled the mislabeled product, OSHA’s Hazard Communication Standard (HCS, 29 C.F.R. § 1910.1200) independently requires proper labeling and Safety Data Sheets. Workers can file OSHA complaints anonymously.
• State Environmental Agencies (Delaware and New Jersey): Etimine operates in both states. Delaware’s Department of Natural Resources and Environmental Control (DNREC) and New Jersey’s Department of Environmental Protection (NJDEP) have independent authority to enforce state pesticide laws and follow up on any environmental disposal concerns from the unlabeled product.
• EPA’s FIFRA Enforcement Office (Nationally): This case falls under FIFRA’s civil penalty framework. The EPA’s Office of Enforcement and Compliance Assurance (OECA) maintains a public database of enforcement actions. Track Etimine’s compliance record there.

What You Can Do

• If you work in an industry that receives Etidot-67 or any other boron-based pesticide, request the Safety Data Sheet (SDS) from your employer for every chemical product on-site. Under OSHA’s HCS, you have a legal right to this information. If an SDS is unavailable or incomplete, that is an OSHA reportable issue.
• Contact EPA Region 3’s Enforcement and Compliance Assurance Division if you received Etidot-67 from Etimine before August 2023 and your product label was missing any of the six categories listed in this article. Document what you received, including lot numbers, container labels, and shipment dates.
• Use EPA’s EnviroFacts database to look up Etimine USA’s registered establishment (EPA Est. No. 90788-DE-001) and track its compliance history over time. Public records exist. Use them.
• Support mutual aid networks and worker health organizations in the Mid-Atlantic region, particularly those serving agricultural workers, warehouse workers, and chemical distribution employees. These workers are the most directly exposed to the consequences of mislabeled pesticides and the least likely to have legal resources to pursue individual claims. Organizations like the National Council for Occupational Safety and Health (COSH) provide worker advocacy support nationwide.
• Push your elected representatives to support increased FIFRA enforcement funding and shorter timelines between inspection findings and enforcement actions. The 13-month gap between the August 2023 inspection and the August 2024 Show Cause letter is a structural problem, not a one-time oversight.