EPA cracks down on counterfeit flea, tick products
By Daniel R.Verdon
EXECUTIVE EDITOR
DVM Magazine April 2004
WASHINGTONThe Environmental Protection Agency (EPA) issued
a stop-sale, use and removal orders to retailers and other distributors of counterfeit
pesticide products for fleas and ticks. The agency reports the stop-sale, use
and removal orders are intended to "disrupt" an effort to distribute
counterfeit pet pesticides for Bayer s Advantage and Merit's Frontline.
Both manufacturers applaud the government intervention.
David Deegan, an EPA spokesman, tells DVM Newsmagazine, "Clearly we recognize,
there is likely a fair amount of product out there that is counterfeit"
How much is anyone's guess.
Deegan says the stop-sale order was issued to increase awareness about the problem,
"and ask people to identify the scope of the problem. We can't be everyplace
and inspect every package," he says.
EPA explains the counterfeit pesticides appear to have been unlawfully imported
and packaged in retail cartons, which are designed to look similar to legitimately
registered pesticides sold in the United States. EPAs investigation indicates
that the counterfeit products have been sold to distributors and retailers throughout
the country.
The EPA action also prohibits retailers and other distributors from distributing
or selling the counterfeit pesticide products and require proper disposal if
discovered.
John Payne, president and general manager of Bayer HeakhCare LLC, Animal Health
Division, says, "Protecting the well-being of animals is Bayer Animal Health's
first priority, and we have been working diligently with EPA and the veterinary
profession and its leadershiD
to stop counterfeiters."
In support of EPAs actions, Payne adds that Bayer has taken aggressive actions
to stop unauthorized sales of its products sold through licensed practicing
veterinarians with a doctor-client-patient relationship.
Zack Mills, DVM, executive director of veterinary services for Merial, adds:
"Merial stands behind the quality of all of our products. A good safeguard
to ensure the integrity of products such as these is to purchase them from a
reputable source. The best way to be confident about the
source of Frontline products is to purchase them through your veterinarian."
EPA says the counterfeiters have placed foreign labeled applicator package inserts
in counterfeited Advantage and Frontline retail cartons printed to resemble
the U.S.-registered products. Frontline products may be missing instruction
leaflets bearing directions for use required under U.S. law. Frontline applicators
may not be in the required child-resistant packaging.
EPA adds that consumers cannot be assured that die counterfeiters inserted the
appropriate size applicator for the animal pictured or indicated on the retail
carton of either brands, which could put pets at risk EPA says that legitimate
products will likely meet all of the following criteria:
Frontline products
1. The lot number on the retail carton matches the lot number on the applicator
package and/or the individual applicators.
2. The instruction leaflet is included. It provides the following information:
first-aid statements, including emergency U.S. telephone numbers; precautionary
statements for humans and pets; directions for use; and storage and disposal
statements.
3. The pesticide is contained in an applicator package, which is child-resistant.
The directions for opening the child-resistant applicator package include an
illustration that actually looks like the applicator package. The directions
include "To remove applicator, use scissors or lift
and remove plastic tab to expose foil, then pull down."
4.The legitimate applicator package has a notch between the individual applicator
packages, which generally are absent on counterfeit products. Text on the package
is in English only.
Once you open the applicator package, each individual applicator has a label
that includes the registrant's name; the product name; the EPA registration
number; the net contents in fluid ounces (not in metric measure); percentage
of active ingredient(s) (fipronil for Frontline Top Spot products; and fipronil
and (S)-methoprene for Frontline Plus products); and the statements "CAUTION",
"Keep out of reach of children", and "See full label for additional
directions." Text is in English only.
6. The applicator label for the dog products includes the size of the dog in
pounds.
Advantage products
1. The only way to determine a legitimate Advantage product from a counterfeit
product is by examining the actual applicator tubes that are inside the carton.
Since the directions for use on the retail carton (outer box) and instruction
leaflet of the legitimate product and the counterfeit product are identical,
check the language lhat is printed on the applicator tubes. The legitimate Advantage
products all contain applicator tubes that are printed in English. The most
obvious sign of a counterfeit product is that the applicator tubes are printed
in a foreign language (most likely French or German).
2. The legitimate applicator tubes include the EPA Registration Number, the
signal word WARNING, and the child hazard warning (Keep out of reach of children).
Counterfeit applicator tubes may lack this information.
3. Legitimate applicator tubes will also include a reference statement that
refers users to the main labeling for directions for use and will include the
manufacturing company's name (Bayer). Counterfeit applicator tubes may lack
this information.
4. Legitimate applicator tubes will contain an active ingredient statement that
agrees with the active ingredient statement on the retail carton (9.1% imidadoprid).
A counterfeit product may have an active ingredient statement that differs (such
as 10%).
For more information, go to www.epa.gov.