EPA orders retailers to stop sales of counterfeit flea and tick products for pets

April 1,2004 JAVMA ; News pg. 1051

The Environmental Protection Agency is acting to disrupt an effort to distribute counterfeit products for controlling fleas and ticks on dogs and cats. The agency has ordered pesticide distributors and retailers in a number of states to stop selling counterfeit products that contain false EPA registration numbers and labeling for Advantage and Frontline brands of pesticides.
The orders prohibit retailers and distributors from distributing or selling the counterfeit products and make them responsible for their proper disposal.
The counterfeit pesticides appear to have been unlawfully imported and packaged in retail cartons designed to look similar to legitimately registered pesticides sold in the United States. The EPA investigation is ongoing and, so far, it appears that the counterfeit products have been sold to distributors and retailers throughout the country.
"We strongly applaud the EPA's recent actions and their notification of their efforts pertaining to counterfeit pet products. This supports Bayer's efforts to take a strong stand against counterfeit products within the industry," said Bob Walker, communications director for Bayer Corp., which markets Advantage for cats and dogs.
Legitimate Advantage and Frontline products that have been through the EPA's review process are registered for use in the United States, and are not affected by this action. Pet owners who are concerned their pet may be affected by counterfeit products should contact their veterinarian.
"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 prod-
ucts is to purchase through your veterinarian," said Dr. Zachary Mills, executive director of veterinary services for Merial.
Counterfeit products should be disposed of according to local accepted procedures for other household chemicals. Many communities and municipalities have local resources to dispose of household chemicals, and consumers are encouraged to contact their local solid waste authority for more information on disposal programs for chemicals.
The EPA has identified counterfeit versions of the following products: Frontline Top Spot for Cats (EPA Reg. No. 65331-2), Frontline Top Spot for Dogs (EPA Reg. No. 65331-3), Frontline Plus for Cats (EPA Reg. No. 65331-4), Frontline Plus for Dogs (EPA Reg. No. 65331-5), Advantage 10 for Dogs (EPA Reg. No. 11556-117), Advantage 20 for Dogs (EPA Reg. No. 11556-119), Advantage 55 for Dogs (EPA Reg. No. 11556-120), Advantage 100 for Dogs (EPA Reg. No. 11556-122), Advantage 9 for Cats (EPA Reg. No. 11556-116), and Advantage 18 for Cats (EPA Reg. No. 11556-118).
The EPA regulates all pesticides used in the United States. Before a pesticide can be marketed in this country, the agency performs a rigorous scientific review to ensure that use of the product is not likely to cause harmful effects on people, pets or the environment. According to EPA spokesman David Deegan, "We cannot make any assurances to the public that these counterfeit products would be equivalent (to the rigorously tested legitimate Advantage and Frontline products.)"
The only way to determine whether a product is legitimate or counterfeit is to open the package. The EPA has posted detailed information, including photos of legitimate products, at \vww.cpa.gov/pcsticides/factsheets/pct product.htm. Veterinarians and consumers concerned about a product's authenticity can also visit www.nofleas. com for information about Advantage or \v\v\v.t''ROVnJNE.com/cpa to find out more about Merial's products.
Among other things, counterfeit products might be missing package inserts bearing directions for use required under U.S. law. Moreover, the counterfeit Frontline products are not packaged in required child-resistant packaging. Consumers cannot be assured that the counterfeiters inserted the appropriate size applicator for the animal pictured or otherwise indicated on the retail carton.
The differences between the legitimate and counterfeit products are most pronounced on the inside applicator package. Legitimate U.S. Frontline products include the following features:
• lot number on the outer package matches the lot number of the applicator package insert and/or the individual applicator
• product is in child-resistant packaging
• instruction leaflet is included
• individual applicator has a label that includes the registrant's name, Merial, product name, EPA registration number, net contents in fluid ounces, and percentage of active ingredients
• all text is in English
• applicator label for the dog products includes the poundage of the dog on which the product is to be used
The only way to determine a legitimate Advantage product from a counterfeit is by examining the product tubes inside the retail carton. Legitimate Advantage products contain tubes that are printed in English. The most obvious sign of a counterfeit is product tubes printed in a foreign language, most likely French or German.
In addition, legitimate Advantage product tubes include the EPA registration number, the word "WARNING," and a child hazard warning.
Legitimate product tubes for Advantage also include a statement referring to the main labeling directions for use and the manufacturer's name, Bayer. Product tubes should also contain an active ingredient statement that agrees with the active ingredient statement on the retail carton.