FIFRA 25(b) Workgroup

Organ Mountains-Desert Peaks photograph by Lisa Phillips, BLM Las Cruces District 

AAPCO formed a FIFRA 25(b) workgroup in Spring 2017.

The workgroup’s mission is to facilitate the collaboration of states and industry in order to share information, provide guidance, foster label consistency, and reduce the duplication of efforts in the review and registration of Minimum Risk Pesticide products.

The workgroup is chaired by Daniel Duer (PA), Samantha Tochen (WA) and Kim Nemeth (Procter & Gamble).

Guidance Documents

Absence of Ingredient Claims – February 2022; This document is being revised for consistency with EPA’s  policy on “Absence of an Ingredient” claims. – April 2025

25(b) Inert Ingredient Research Guidance – February 2020

2024 State 25(b) Requirements with contact info-updated July 2024 (excel will download to your computer)

Data Efficacy guidance for 25(b) – March 2019

Data Efficacy guidance: Q&A for 25(b) products – November 2021

Label guidance for 25(b) products – updated December 2021

25(b) Statement of Formula form:  Word version, which will download and is fillable or PDF’d form, which is easier to view


25(b) Workgroup Members – updated February 2025 (excel will download to your computer)

*For State Lead Agencies interested in becoming a workgroup member, please email Daniel Duer (daduer@pa.gov) or Samantha Tochen (Samantha.Tochen@agr.wa.gov).

*If you are with Industry and interested in joining, please email Kimberly Nemeth at Nemeth.ka@pg.com.


Learn more about 25(b): EPA’s Minimum Risk Pesticides webpage