What are EPA 25(b) Exempt Pesticides? FIFRA Minimum Risk Pesticides Explained

How FIFRA 25(b) Minimum Risk Pesticides Work

To qualify as a 25(b) minimum risk pesticide, a product must satisfy six strict conditions set by the EPA[3][4]:

Allowed Active Ingredients Only: The active ingredients (the ones intended to kill or repel pests) can only be those on EPA’s approved 25(b) list of substances (found in 40 CFR 152.25(f)(1)). This list includes various botanical oils, plant extracts, and other naturally derived compounds that the EPA deems low-risk[3]. If a pesticide’s active ingredient is not on this list, the product cannot be 25(b) exempt.

Allowed Inert Ingredients Only: All inert (inactive/carrier) ingredients in the formula must also be safe and on approved lists. Specifically, 25(b) products may only use inert ingredients that are classified by EPA as minimal risk, such as those on the 40 CFR 152.25(f)(2) list or in the FDA’s GRAS (Generally Recognized As Safe) food substances[5]. In other words, every component of the product – active or inert – has to be a low-risk substance.

All Ingredients Disclosed on Label: The product’s label must clearly list every ingredient (both active and inert). The active ingredients must be shown with their percentage by weight, and inert ingredients listed by name[6]. This full transparency is required so consumers know exactly what is in the pesticide.

No Public Health Pest Claims: The product cannot claim to control pests that threaten human health (e.g. mosquitoes that transmit diseases, bacteria or viruses harmful to people)[4]. Minimum risk pesticides are only for nuisance pests or plant pests – they must not advertise themselves for disease-vector control or public health sanitation, because that would require stricter regulation.

Company Name and Contact on Label: The label must prominently display the name of the manufacturer (or company distributing it) and their contact information[7]. This ensures accountability, even though the product isn’t EPA-registered.

No False or Misleading Claims: Like any pesticide, a 25(b) product’s labeling cannot contain false or misleading statements[8]. This includes no fake promises, no misuse of EPA logos, and no claims that contradict the product’s status (for example, it must not imply EPA endorsement). The product should not be marketed as “safe if eaten” or other such claims that could be misleading. Compliance with standard EPA labeling rules (40 CFR 156.10) is expected, minus the registration specifics.

If – and only if – all six conditions are met, the pesticide is exempt from federal registration as a minimum risk pesticide[2]. This is why you might notice that 25(b) products have no EPA registration number on their label[1]. They legally skip the normal EPA approval process, yet they must still adhere to these labeling and ingredient rules. Many states also maintain their own registration or notification programs for 25(b) products, so manufacturers often still register the products at the state level before distributing them.

What 40 CFR 152.25(f) actually says

The six conditions above are a plain-English reading of one regulation: 40 CFR 152.25(f), the section of the Code of Federal Regulations that creates the minimum risk exemption. It is worth knowing how it is subdivided, because state regulators and product labels cite the subsections directly. [35]

One point catches people out. The exemption is federal only. A product can be perfectly exempt under 40 CFR 152.25(f) and still be unlawful to distribute in a given state until that state has registered it, and the states do not agree with each other about what they want. [2]

What changed in 2026

The rules on ingredients have been stable since the December 2015 final rule, with chitosan added in November 2022. [29] What moved recently is enforcement of the claims side. The AAPCO FIFRA 25(b) Workgroup published updated efficacy data guidance with an effective date of 1 May 2026, replacing a version that had stood since January 2019. It now runs to three chapters: general study conduct, arthropod testing, and a new chapter on antimicrobial and surface fungicide testing, with products claiming to kill microbial pests expected to show at least 60% efficacy. [36]

There is an eighteen-month implementation period, and renewals falling inside it are not affected. New products submitted after 1 May 2026 are. The practical effect for a grower is small but real: a label claim on a 25(b) product is now more likely to have data behind it than it was two years ago, and a state can reject a product whose claims do not. [36]

Common Ingredients in 25(b) Exempt Pesticides

One hallmark of EPA 25(b) exempt pesticides is that they’re made from very familiar, naturally derived ingredients. The EPA’s list of permitted active ingredients (originally 31 substances, now slightly expanded) reads like a pantry of kitchen and garden items, not a chemical lab. For example, the allowed actives include many essential oils and plant extracts – peppermint oil, clove oil, thyme oil, rosemary oil, cinnamon oil, citronella, and others – which are known for their insect-repellent or antifungal properties[9][10]. Other entries on the list are common food-grade materials like corn oil, cottonseed oil, garlic extract, castor oil, sesame oil, linseed oil, and even citric acid and malic acid (the kind found in citrus fruits and apples)[9][10]. In fact, ordinary table salt (sodium chloride) is on the list as a permissible active ingredient, as are potassium sorbate (a food preservative) and sodium lauryl sulfate (a soap-like compound often found in toothpaste)[11][10]. Even some quirky items made the cut, like putrescent egg solids (used to repel wildlife) and zinc metal strips (for algae control)[12][13].

This emphasis on natural, low-toxicity ingredients means that 25(b) products are typically free from conventional synthetic pesticides. You won’t find organophosphates, carbamates, or even naturally-derived but potent chemicals like pyrethrins in these exempt formulations – those require full EPA registration. Instead, minimum risk pesticides rely on things like botanical oils, soaps, and minerals that have a long history of safe use. Many of these substances are also common in organic gardening. (In fact, several 25(b) ingredients are OMRI listed for organic farming, and some products themselves obtain OMRI certification, indicating they meet organic standards.)

It’s worth noting that the inert ingredients in 25(b) products are likewise constrained to safe choices. Often, the inerts are just water, minor solvents like ethanol or glycerin, or inert ingredients the EPA considers minimal risk (such as certain food additives, carriers, or fragrances). The old “List 4A” shorthand is still widely quoted for these, but it was superseded by the December 2015 final rule, which replaced it with the explicit table now at 40 CFR 152.25(f)(2) [35][5]. For example, a typical ready-to-use natural insecticide spray might be something like peppermint oil as the active, with water and a bit of soap as inerts – all of which are innocuous. The EPA requires that all ingredients be disclosed, so consumers can see there’s nothing scary hidden in the formula[6].

Why these ingredients?

Most of the 25(b)-eligible substances have some known pest control action but are also common in everyday life and known to be safe for human exposure. Essential oils like peppermint and clove can kill or repel soft-bodied insects by disrupting their cell membranes or breathing, yet these oils are commonly used in foods, candies, or cosmetics for us. Likewise, garlic and hot pepper extracts deter pests but are edible for humans. Citric acid can kill mildew spores or insect eggs by lowering pH, but it’s of course a normal part of our diet. By restricting minimum risk pesticides to such ingredients, the EPA means that even if these products are misused or overused, the likelihood of causing harm is extremely low.

The full 25(b) active ingredient list

People search for this list constantly and usually end up on a stale copy of it. The table below is the current Table 1 to 40 CFR 152.25(f)(1), reproduced in full, with the CAS numbers the label has to match. Forty-five entries, and nothing outside them qualifies. Where a plant and its oil are listed separately, both forms are permitted; where only the oil is listed, the ground plant material is not. [35]

A few entries surprise people. Zinc is on the list as metal strips, not as a salt. Dried blood and putrescent whole egg solids are there because they work as deer and rabbit repellents. And the label display name matters as much as the substance: if the label says something the table does not, the product is not exempt, however low-risk its contents actually are. [35]

Which inert ingredients are allowed

The inert side trips up more formulators than the active side. Inerts have their own table at 40 CFR 152.25(f)(2), and an ingredient qualifies only for the role it is listed under. Citric acid, malic acid, corn oil, cottonseed oil and sodium chloride appear on both lists, so they can be used either way. Vinegar is the instructive exception: approved as an inert at up to 8% acetic acid, and not permitted as an active ingredient at all. [37]

Benefits of Minimum Risk (25b) Pesticides

Several reasons why home gardeners or commercial farmers choose a 25(b) exempt pesticide over a regular one? There are several compelling advantages:

• Safety for Humans and Pets: Minimum risk pesticides are, by definition, low in toxicity. They are generally recognized as safe to use around people, pets, and even sensitive environments when used correctly. Many product labels tout statements like “safe around children and pets” and “can be used up to the day of harvest”[14]. Unlike harsher chemicals, these products often leave little to no toxic residue on fruits or vegetables. For example, Sierra Natural Science’s SNS 244 natural fungicide is made of thyme extract and is explicitly labeled as safe for use around kids, pets, and beneficial insects, and safe to spray on edible plants even on harvest day[14][15]. This makes minimum risk options very attractive for home gardens, community gardens, and anywhere you might be concerned about exposure to traditional pesticides.
• No Wait Times (REI or PHI): Because of their benign ingredients, 25(b) exempt products typically don’t require a waiting period after application. In conventional agriculture, after spraying a pesticide you often have a restricted-entry interval (REI) (to keep workers out of the area for a certain time) and a pre-harvest interval (PHI) (you must wait days or weeks before harvesting crops for consumption). Minimum risk pesticides usually have a 0-hour REI and 0-day PHI – essentially no restriction[16][17]. You can spray and harvest the same day, which is a huge convenience for both hobby growers and commercial operations. For instance, BioWorks EpiShield, a botanical insecticide/miticide, advertises that it has no REI or PHI, meaning greenhouse workers can re-enter immediately and crops can be harvested without delay[18][16]. This allows continuous pest management right up to harvest time.
• Eco-Friendly and Biodegradable: Most 25(b) ingredients are biodegradable natural substances. They tend not to persist long in the environment – essential oils volatilize or break down, and things like soap or mineral oil degrade quickly. They generally won’t contaminate groundwater or cause long-term ecological harm. Many are derived from renewable resources (plants, food byproducts) rather than petroleum. Because of this, minimum risk pesticides align well with organic and sustainable farming practices. In fact, a number of these products are OMRI Listed for use in organic production (for example, Flying Skull’s Nuke Em insecticide/fungicide has an OMRI-listed formula made of food-grade ingredients)[19]. Using 25(b) pesticides can help growers reduce their chemical footprint and meet organic standards or customer expectations for natural products.
• Reduced Regulatory Hassles: For professional growers, especially those in tightly regulated industries like licensed high-value horticulture or hemp, 25(b) exempt products offer an important compliance advantage. Because they are unregistered (exempt) pesticides, there’s no official EPA restriction on using them on any crop, even if that crop isn’t listed on a label (some states do maintain lists of allowed products for those crops, but these almost always include 25(b) products by default). Growers of federally restricted crops in legal states have famously limited options for pest control – most conventional pesticides are not permitted on them. But EPA-exempt minimum risk products are generally permitted, and states like California, Oregon, Colorado, etc., have dozens of 25(b) products on their approved pesticide lists for those crops[20]. These products also tend to pass residual pesticide testing easily. For example, Trifecta’s Crop Control (a popular essential-oil based pesticide) is marketed with the claim that it will “TEST CLEAN” under state pesticide residue regulations[21]. This matters enormously to commercial growers who have to submit samples for lab testing – using minimum risk products helps ensure there are no detectible chemical residues that could cause a batch of produce (or flower) to fail testing. Similarly, in food crop production, using 25(b) pesticides means no worries about exceeding tolerance limits for residues on produce, since those actives are exempt from tolerance under EPA regulations.
• Ease of Access and Use: For home gardeners, minimum risk pesticides are very easy to obtain and use. They are sold over-the-counter in garden centers and online without any restricted-use licenses. You might find them labeled as “natural insecticide spray”, “organic garden pest control”, or similar. Because they’re considered safe, they often have simpler instructions and less stringent precautions (though you should still follow the label!). Many have pleasant or tolerable odors (often minty, herbal, or citrusy rather than harsh chemical smells). And since there’s no long wait after spraying, a hobbyist can treat their indoor hydroponic garden or backyard vegetables and not worry about keeping pets or kids away for long. This convenience encourages regular use as a preventative measure – you can incorporate these products into a weekly routine as part of an integrated pest management (IPM) program. In an IPM context, 25(b) sprays can be used frequently and proactively (e.g. a mild soapy insecticide spray every few days) to keep pest populations down without stress on your plants. Many growers appreciate that they can “spray early and often” with minimal risk.
• IPM and Resistance Management: The modes of action of 25(b) pesticides are typically non-specific (e.g. smothering insects with oil or soap, repelling them with odors, or dessicating fungal spores). While this can mean they aren’t as immediately lethal as synthetic pesticides, it also means pests are less likely to develop resistance to them. In fact, some products combine multiple natural ingredients to hit pests from different angles. BioWorks EpiShield, for instance, uses a proprietary blend of peppermint and clove oil that paralyzes and suffocates insects, and it touts that using multiple botanical actives eliminates the risk of pests developing resistance[22]. Resistance management is a big benefit, especially for greenhouse growers – by rotating 25(b) products with other controls, you can avoid creating “superbugs.” These products are also generally safe to mix or alternate with biological controls (like predatory insects or microbial sprays) since they tend to be softer on non-target organisms. All of this makes minimum risk pesticides excellent tools in a modern IPM strategy focused on long-term, sustainable pest suppression rather than just scorched-earth eradication.

Of course, it’s important to acknowledge that minimum risk does not mean zero risk. Users should still follow the label directions carefully (some botanical oils can cause skin or eye irritation, for example, and you generally don’t want to inhale sprays of anything, “natural” or not). The absence of EPA registration also means these products don’t undergo the same efficacy testing as registered pesticides – so their performance can be inconsistent or subtle. In practice, many 25(b) products work best on small, soft-bodied pests (like aphids, mites, whiteflies) or as preventative treatments, rather than as knock-down chemicals for large outbreaks. They may require more frequent application and good coverage of the pests to be effective (many act as contact insecticides or repellents, with little residual effect after they dry). For tough infestations or highly destructive diseases, growers might find they still need to integrate other measures (cultural controls, biological controls, or in some cases, stronger pesticides that are approved for their crop). Nonetheless, the general track record of safety and the modest but real effectiveness of many 25(b) products have earned them a valued place in both home gardening and professional cultivation.

Use Cases: Home Gardeners vs. Commercial Growers

One of the key challenges in writing about pesticides is that the needs of a backyard tomato grower can be quite different from those of a large-scale greenhouse operator. Interestingly, FIFRA 25(b) minimum risk pesticides bridge that gap by offering benefits to both groups, though in slightly different ways.

Home and Hobby Growers: If you’re a home gardener or hobby grower, you probably prioritize safety and ease of use. You want to protect your roses, veggies, or houseplants from pests and fungi, but without turning your home into a hazmat zone. Minimum risk pesticides are ideal in this context. They allow “do-it-yourself” pest control that is gentle. For example, a natural insecticidal soap made with plant oils can knock back an aphid infestation on your peppers without leaving nasty residues that you’d ingest later. You can spray your indoor garden system (be it a soil houseplant or a small indoor hydroponic setup) and not worry about lingering chemical smells or toxicity. Many 25(b) products explicitly say things like “safe to use around kitchens, schools, and pet areas”. They’re a great option for urban gardeners or families who have to manage pests in close quarters with living spaces. Also, because these products are readily available and don’t require protective gear beyond maybe gloves, a home user is more likely to actually use them regularly. Regular, gentle treatment can prevent pests from ever becoming a big problem. In short, minimum risk pesticides empower gardeners to practice IPM at home: you can monitor your plants and as soon as you see a few aphids or a hint of powdery mildew, you can respond with a safe spray that same day. The peace of mind that you’re not introducing something hazardous to your home is a huge plus.

Commercial Growers: For commercial operations – whether it’s an organic vegetable farm, a large greenhouse, or a licensed cultivation facility – 25(b) exempt pesticides serve somewhat different (but overlapping) purposes. The safety aspect is still huge: farm workers can spray and re-enter immediately, and there’s no risk of failing residue tests, as mentioned. But additionally, minimum risk products can help businesses meet regulatory and market demands. Many grocery retailers and consumers are increasingly pushing for produce grown with reduced pesticides. Using exempt products can be part of a farm’s marketing strategy for “all-natural” or “spray-free” produce (even if they do spray, it’s with botanicals). For growers of those crops, it’s practically a necessity to use things like essential oil sprays, because most conventional pesticides are off-limits – hence a flourishing of specialized 25(b) formulations for that industry. Commercial cultivators also value that these products can be applied right up to harvest. For instance, a greenhouse tomato producer might use a thyme-oil based fungicide every week as a preventative for powdery mildew through the season, and even a day before picking tomatoes, with no ill effect on the crop. That flexibility can save a crop from disaster, compared to having to cease sprays weeks before harvest and risk a late outbreak.

Another big use in commercial settings is as part of a rotation to prevent resistance. Say you have a thrips problem in a flower greenhouse: you might not want to repeatedly use the same synthetic chemical (due to resistance buildup and legal spray limits). You could rotate in a 25(b) product like a rosemary oil spray on alternate weeks. While the oil spray alone might not be as potent as a synthetic insecticide, in combination they keep the pests off balance and reduce overall chemical usage. Also, some minimum risk products have multi-faceted uses – e.g. a product that is simultaneously an insecticide, miticide, and fungicide (several brands market 3-in-1 solutions). An example is General Hydroponics TriShield, which has soybean oil, citric acid, and sodium lauryl sulfate and is labeled to control certain insects and powdery mildew at the same time[23][24]. A commercial grower might appreciate such broad-spectrum, one-stop tools for convenience.

Finally, since commercial growers often have to keep tight schedules and cannot afford downtime, the no REI/PHI aspect bears repeating. In a large greenhouse or indoor farm, if you spray a conventional pesticide with a 12-hour REI, it means an entire section might sit idle (no workers tending plants) for half a day – that’s lost productivity. With a 25(b) spray, workers can virtually follow behind the sprayer. This is especially important for facilities like vertical farms or year-round greenhouses, where there is constant daily crop maintenance. Minimum risk pesticides let pest control integrate seamlessly into daily routine.

Examples of 25(b) Exempt Products

Modern growers have a wide range of 25(b) minimum risk pesticide products to choose from. Some popular examples (available through GrowersHouse and similar suppliers) include: Athena - IPM BioWorks EpiShield, SNS 244C Fungicide Concentrate (and its ready-to-use counterpart 244 NATURAL FUNGICIDE RTU), Trifecta Crop Control, General Hydroponics TriShield, Mammoth Control, Flying Skull Nuke Em, and GreenGro Pride Lands Defense. Each of these products uses the kinds of ingredients and principles to qualify as an EPA 25(b) exempt pesticide – from essential oil blends to food-grade plant extracts – to combat pests and pathogens with minimal risk. By using these exempt products, both home gardeners and commercial growers can strike a balance between effective pest control and the safety of their operations.

Here is what is actually on the shelf. Every 25(b) product currently listed, with its declared active ingredients and the size range for each. Prices move, so treat the figures as a starting point rather than a quote.

Read that active ingredient column against Table 1 above and every single entry is on it — corn oil, thyme oil, peppermint oil, clove oil, lemongrass oil, geranium oil, citric acid, soybean oil, sodium lauryl sulfate, rosemary oil, garlic, cinnamon, white pepper. That is not a coincidence, it is the whole mechanism. A product qualifies because of what is in it, and the label has to declare each active by name and percentage, which is why this table can exist at all. [35]

Two things the table cannot say on its own. The target column is taken from each product’s own label, not from an independent efficacy trial — a 25(b) product is exempt from registration, which means the EPA has not reviewed those claims. And the labels themselves distinguish control from suppression: EpiShield controls mites and aphids but only suppresses thrips, whiteflies and mealybugs, which is a real difference when you are building a rotation rather than reacting to an outbreak.

BioWorks EpiShield stands out as a powerhouse 25(b) exempt miticide and insecticide designed for efficiency and grower convenience. Its unique blend—15% peppermint oil, 10% clove oil, and 3% sodium lauryl sulfate—delivers up to 53% higher mortality of mites and aphids vs. traditional oils, using as much as 10× lower application rates and up to 45× less total oil delivered to plants.

As an EPA 25(b) exempt product, EpiShield requires no restricted‑entry interval (REI) or pre‑harvest interval (PHI), allowing growers to spray right up to harvest and keep operations running without a pause[25]. Its efficacy is both potent and gentle—working via paralysis, suffocation, and desiccation on contact—while minimizing phytotoxic risk thanks to lower oil content and reduced dosage needs.

This makes EpiShield a stellar fit for IPM programs: it delivers fast, reliable results without interrupting greenhouse schedules, and with multiple modes of action, it helps stall pest resistance. Ideal for spot treatments of hot spots, this product empowers commercial growers to protect yield and maintain quality with minimal disruption.

Mammoth Control is a natural, multi-purpose 25(b) exempt product that works as an insecticide, miticide, and fungicide—perfectly tailored for discerning home gardeners. Its all-natural, plant-derived formulation leaves zero toxic residue, making it safe for edible and ornamental crops alike.

This preventative solution targets a broad spectrum of common pests and fungal issues—including powdery mildew, botrytis (gray mold), mites, aphids, whiteflies, thrips, and fungus gnats—using active compounds like thyme oil and corn oil, known for their proven effectiveness in disease and pest suppression. Its ease of use is remarkable: apply weekly during both vegetative and flowering phases, with straightforward mixing ratios for foliar or root drizzle applications. No REI restrictions make it safe for regular, hands-on use in residential settings.

Mammoth Control is ideal for proactive home use—giving gardeners a simple, natural, and flexible tool to keep their plants shielded from pests and diseases, while preserving beneficial insects and maintaining peace of mind.

What is actually in it is worth reading next to the EpiShield line above, because the two solve the same problem from opposite ends. Mammoth Control declares corn oil at 55% and thyme oil at 15%, with oleic acid making up the 30% inert. Both actives sit on Table 1, and thyme oil is the one doing the pest work — thymol is the compound the EPA recognises as minimum risk. Corn oil is the carrier that puts it on the leaf and keeps it there. The listing describes the result as lab-tested for efficacy and safety, leaving no toxic residue behind. [35]

The rate is the easiest thing about it. One ounce per gallon of water, and that number does not change. It goes out as a foliar spray or as a root drench, and the drench is the part that separates it from most of this category — EpiShield and TriShield are canopy products, sprayed or dipped, while a drench reaches the fungus gnat larvae and the root aphids living in the media where a foliar pass never arrives. Running the same jug both ways, on the same arithmetic, is the practical argument for keeping it on the bench.

Two honest qualifications. The paragraphs above frame this as a home-garden product, and that was true of the sizes the article was written around — but the range now runs 500 ml, 1 litre, 1 gallon and 6 gallons, and the listing puts the gallon in commercial hands and the six gallon drum in large-scale production. It is no longer a hobbyist-only tool. And a 55% corn oil load puts far more oil on the leaf than EpiShield’s approach, whose own listing credits its lower burn risk to using roughly a tenth the volume of conventional horticultural oils. Neither is wrong. But if you are spraying a warm room in the afternoon, that difference is the one to think about before you pick.

Two of the products this article originally pointed to — Trifecta Crop Control and Flying Skull Nuke Em — are no longer carried, so they are named here as industry examples rather than linked. The table above is what is actually listed today; plan a rotation around that rather than around a product name you have seen elsewhere.

Conclusion

EPA 25(b) exempt pesticides (FIFRA minimum risk pesticides) are pest control tools that prioritize safety and natural ingredients over brute chemical force. Filling important niche in both home gardening and commercial agriculture by offering a way to manage pests and diseases without the regulatory burdens and potential hazards of conventional pesticides. While they may not be silver bullets for every pest issue, they are invaluable for what they do provide: low-toxicity, environmentally friendly options that can be used frequently and flexibly as part of an integrated pest management program.

For growers, understanding what 25(b) exempt products are opens up a toolbox of solutions that can keep plants healthy with minimal risk. Whether you’re a hobbyist trying to keep aphids off your tomatoes, or a commercial cultivator protecting acres of greenhouse herbs, minimum risk pesticides give you a way to act fast and safely when pests appear. They represent a shift towards more sustainable pest management – leveraging Mother Nature’s own pest repellents and remedies, but in a convenient bottled form.

As the demand for organic and pesticide-free produce grows, and as regulations tighten on chemical pesticide residues, it’s likely we’ll see even more innovation and reliance on these 25(b) products. The EPA continues to update the allowed substances list (for example, recently adding chitosan – a natural biopesticide derived from crustacean shells – as a new 25(b) active ingredient[29]), which could expand the effectiveness of minimum risk options.

"Minimum risk" pesticides are all about finding that sweet spot: effective enough to curb pests, but safe enough to use with peace of mind. They remind us that not every pest solution needs to be a potent synthetic chemical – sometimes a carefully chosen mix of botanical oils, or a dash of food-grade spice, can do the job. For anyone aiming to grow plants in a way that’s gentler on themselves and the environment, it’s well worth exploring the world of EPA 25(b) exempt pesticides.

If you are working out whether a 25(b) product fits your rotation, or you want to check a label against the table above before committing to a programme, get in touch or leave a comment. Ten minutes on it now beats finding out at testing.