How to Fix Pesticide Yanks and Gating

How to Fix Pesticide Yanks and Gating

 

Reading Time: 16 minutes

 

Pesticide is any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest.[1] Amazon basis its pesticide policy according to the regulations of the United States Environmental Protection Agency (EPA), and the United States Food and Drug Administration (FDA) under their Natural Drug Code (NDC).

 

All Amazon sellers should comply to all federal, state, and local laws and Amazon policies applicable for these products. Pesticides and pesticide devices include: (1) any product intended for preventing, destroying, repelling, or mitigating any pest and (2) any product that makes any antimicrobial, antifungal, antibacterial, anti-mold, or pesticide claims.[2]

 

To learn more about the pesticide policies, please visit Pesticides and pesticide devices

 

Who is this for?

  • To copywriting team that creates copies for listings.

  • Every member of the Reinstatement Team that will receive Pesticide Yank, Pesticide Gating, and related tasks.

  • To all members of My Amazon Guy (MAG) that wanted to learn more about Pesticide policies

  • Sellers that wanted to learn more about Pesticide Product Regulations

Description:

This Standard Operating Procedure (SOP) will help you understand how to avoid pesticide related issues within the catalog copy creation and how to reinstate pesticide yanks and pesticide gated products.

At a Glance

How to Fix?

Non-Pesticide Products

Non-pesticide products don’t contain pesticides or substances used to prevent, destroy, repel, or reduce the impact of pests. If the product doesn’t intend to preventing, destroying, repelling, or mitigating any pest but received pesticide restriction, there’s a possibility that the seller used pesticide-related claims: either the pest or the process of preventing, destroying, repelling, or mitigating it.Here’s the violation warning:

This product has been identified as a pesticide product, pesticide device, or a product that contains pesticidal claims. To be considered for reinstatement, please provide evidence of an EPA Registration number and/or EPA Establishment number or a certification that the product is exempt from EPA regulations. You will need to provide this information in the Pesticide Marking attribute for the listing. Instructions for completing this attribute are available on Seller Central at https://sellercentral.amazon.com/gp/help/GLX9EJX844SNJX7J. For vendors, please see Vendor Central at https://vendorcentral.amazon.com/hz/vendor/members/support/help/node/GJJS6MBG5JPHSMFF. Please note that any listings that continue to make any pesticidal claims from any source will need to meet Amazon’s listing requirements for pesticides and pesticide devices. If all pesticidal claims about your product are removed, and the claims were the sole reason that the product was considered a pesticide or pesticide device, you may relist your product through Seller Central. For more information, see our Pesticides and Pesticide Devices Seller Help page here: https://sellercentral.amazon.com/gp/help/external/202115120

Troubleshooting Steps:

In order to reinstate the listing, please follow these steps. Document the changes/actions.

  1. Check the product images and remove the prohibited claims from infographics.

  2. Download a category listing report (CLR) and remove all prohibited claims from the following attributes. Please see “Pesticide Claim Keywords” here

    1. Title

    2. Description

    3. Bullet points

    4. Search terms

    5. Intended Use

    6. Other Attributes

  3. Upload the updated CLR and take the batch ID.

  4. Go to A+ contents and look for the ASIN. Remove the prohibited claims from description, images and alt text keywords.

  5. If you’re confident that everything is set, go to Performance > Account Health > Restricted Product Policy Violations > Look for the ASIN > Appeal > Check the boxes and submit. Wait 24 hours before the listing gets reinstated.

What if the listing remained yanked?

  1. Send a ticket. Follow this pathway Help > Get Support > Selling on Amazon > Or, browse for your issue in the menu > Products, Listings, or Inventory > Inventory file upload issue.

  2. Title/Reason/Short Description: “US - Restricted Products - Appeal - ASIN: B0xx”

  3. Body (the following is just an example, please don’t copy but tweak it depending on the actions you took).

Greetings,

ASIN B0xx has been identified as a pesticide product.

We thoroughly checked the listing and removed the following claims (batch ID: xxx):

Title:

Mite

Description:

Wick

Bullet 1:

Antimicrobial

Please reinstate the listing. Send this to the internal team for further review and reinstatement.

Get the case ID and monitor the updates.

NDC Registered Products

NDC registered products were approved by the FDA. The NDC system is used by the FDA to classify, identify, and track human drugs, including prescription and over-the-counter drugs, as well as some veterinary drugs. NDC registered products must meet FDA standards for quality, safety, and efficacy.

Sometimes, Amazon yanks hand sanitizers, wipes, towellettes and related products because of “disinfectant”, “sanitizer”, or similar keywords within the product description despite of complete documentation before listing the products in Seller Central. Here’s the violation warning:

This product has been identified as an unapproved alcohol-based hand sanitizer product. Amazon policy prohibits the sale or listing of unapproved hand sanitizer products. If you believe this determination has been made in error and would like to request the reinstatement of your product, please contact Seller or Vendor Support and provide your National Drug Code (NDC) for this product. For more information, please see the following FDA guidance: https://www.fda.gov/news-events/press-announcements/fda-brief-fda-withdrawing-temporary-guidances-alcohol-based-hand-sanitizers and https://www.fda.gov/drugs/pharmaceutical-quality-resources/current-good-manufacturing-practice-cgmp-regulations.

Troubleshooting Steps:

In order to reinstate the listing, please follow these steps. Document the changes/actions.

  1. See if the NDC is still active under FDA. See the National Drug Code Directory here. Take a screenshot for documentation.

  2. (Optional) Add the NDC number in the product description.

  3. Go to Performance > Account Health > Restricted Product Policy Violations > Look for the ASIN > Appeal > Check the boxes and submit. Wait 24 hours before the listing gets reinstated.

What if the listing remained yanked?

  1. Send a ticket. Follow this pathway Help > Get Support > Selling on Amazon > Or, browse for your issue in the menu > Products, Listings, or Inventory > Inventory file upload issue.

  2. Title/Reason/Short Description: “US - Restricted Products - Appeal - ASIN: B0xx”

  3. Body (the following is just an example, please don’t copy but tweak it depending on the actions you took).

Greetings,

ASIN B0xx has been identified as an unapproved alcohol-based hand sanitizer product.

The listing is NDC registered please see the following and the attached screenshot:

NDC: 82355-022-08

Please reinstate the listing. Send this to the internal team for further review and reinstatement.

Get the case ID and monitor the updates.

Remember:

Some wipes and hand sanitizers are EPA registered so update the product description accordingly

EPA Regulated Pesticide Devices

 EPA regulated pesticide devices are products that are used to control pests, but that are not classified as traditional pesticides.These devices do not require EPA registration as long as they do not contain or produce any chemicals that intend to preventing, destroying, repelling, or mitigating any pest. However, they are regulated to the extent "false or misleading” claims are made about their effectiveness of devices. If a manufacturer is making claims about a device, they should have scientific data to support the claims.[3]

Examples of Regulated Pesticide Devices:

  • Ultraviolet Light Units

  • Sound Generators

  • Insect Traps

  • Ground Vibrators

  • Water Treatment Units

  • Air Treatment Units

Remember:

DO NOT use the term “chemical” within the product description.

Troubleshooting Steps:

The policy violation warning is the same as the first example in this SOP. In order to reinstate the listing, please follow these steps. Document the changes/actions.

  1. Check the product images and remove the prohibited claims from infographics.

  2. Download a category listing report (CLR) and update the following attributes:

    1. Pesticide Marking: EPA Registration Number

    2. Pesticide Registration Status: This product qualifies for an exemption from registration under the U.S. Federal Insecticide, Fungicide, and Rodenticide Act.

  3. Remove any claims that aren’t allowed for regulated pesticide devices. Upload the updated CLR and take the batch ID.

  4. Go to A+ contents and look for the ASIN. Remove the prohibited claims from description, images and alt text keywords.

  5. If you’re confident that everything is set, go to Performance > Account Health > Restricted Product Policy Violations > Look for the ASIN > Appeal > Check the boxes and submit. Wait 24 hours before the listing gets reinstated.

  6. If the product is pesticide gated, click the Inactive link and the Request Approval Link. It’ll send you to Pesticide Course. It’ll take roughly 30 minutes to complete and you need to pass the quiz. Here’s the course’s answer sheet.

What if the listing remained yanked?

  1. Send a ticket. Follow this pathway Help > Get Support > Selling on Amazon > Or, browse for your issue in the menu > Products, Listings, or Inventory > Inventory file upload issue.

  2. Title/Reason: “US - Restricted Products - Appeal - ASIN: B0xx”

  3. Body (the following is just an example, please don’t copy but tweak it depending on the actions you took).

Greetings,

ASIN B0xx has been identified as a pesticide product.

We want to dispute that ASIN B0xx is a Regulated Pesticide Device and we updated the Pesticide Registration Status to “This product qualifies for an exemption from registration under the U.S. Federal Insecticide, Fungicide, and Rodenticide Act.”

We made sure that the product description is inline with the EPA regulation policy as stated under Examples of Regulated Pesticide Devices:

https://www.epa.gov/pesticides/pesticide-devices-guide-consumers#7

Please reinstate the listing. Send this to the internal team for further review and reinstatement.

Get the case ID and monitor the updates.

FAQ

What if the product is regulated pesticide device but has EPA Registration Number?

Note:

Amazon will ask for the Product Label and it should have the EPA number on it.

Follow the Troubleshooting Steps until 2.

  • Pesticide Marking: EPA Registration Number

  • Pesticide Registration Status: This product qualifies for an exemption from registration under the U.S. Federal Insecticide, Fungicide, and Rodenticide Act.

  • Pesticide Certification Number: [Input the EPA number]

  • Loop back to the Troubleshooting Steps

What if the listing remained yanked?

  1. Send a ticket. Follow this pathway Help > Get Support > Selling on Amazon > Or, browse for your issue in the menu > Products, Listings, or Inventory > Inventory file upload issue.

  2. Title/Reason: “US - Restricted Products - Appeal - ASIN: B0xx”

  3. Body (the following is just an example, please don’t copy but tweak it depending on the actions you took).

Greetings,

ASIN B0xx has been identified as a pesticide product.

We want to dispute that ASIN B0xx is a Regulated Pesticide Device and we updated the Pesticide Registration Status to “This product qualifies for an exemption from registration under the U.S. Federal Insecticide, Fungicide, and Rodenticide Act.”

Please see EPA Number: [Insert the EPA Number]

We have also removed all of the claims that may identify our product as a a face mask, head covering, face shield, or related protection product that makes unapproved medical marketing claims regarding viruses, bacteria, or the flu. (Add this paragraph if the product has allergen, bacteria, virus, and related pathogen claims)

We made sure that the product description is inline with the EPA regulation policy as stated under Examples of Regulated Pesticide Devices:

https://www.epa.gov/pesticides/pesticide-devices-guide-consumers#7

Please reinstate the listing. Send this to the internal team for further review and reinstatement.

Get the case ID and monitor the updates.

Minimum Risk Pesticides

Because EPA has determined that certain "minimum risk pesticides" pose little to no risk to human health or the environment, EPA has exempted them from the requirement that they be registered under the Federal Insecticide, Fungicide, and Rodenticide Act.[4] These products do not require EPA registration as long as they follow these conditions[5]

  • Condition 1: The product's active ingredients must only be those that are listed in 40 CFR 152.25(f)(1)

  • Condition 2: The product's inert ingredients may only be those that have been classified by EPA as:

    • Listed in 40 CFR 152.25(f)(2)

    • commonly consumed food commodities, animal feed items, and edible fats and oils as described in 40 CFR 180.950(a), (b), and (c); and

    • certain chemical substances listed under 40 CFR 180.950(e).

  • Condition 3: All of the ingredients (both active and inert) must be listed on the label. The active ingredient(s) must be listed by label display name and percentage by weight. Each inert ingredient must be listed by label display name.

  • Condition 4: The product must not bear claims either to control or mitigate organisms that pose a threat to human health, or insects or rodents carrying specific diseases.

  • Condition 5: The name of the producer or the company for whom the product was produced and the company’s contact information must be displayed prominently on the product label.

  • Condition 6: The label cannot include any false or misleading statements.

Examples of Minimum Risk Pesticides:

  • Cat/Dog Shampoo with tick & flea claims

  • Insect Repellan/Killer Spray

  • Insect Repellant Cream

Note:

The only document you needed from the seller is the Product Label.

Troubleshooting Steps:

The policy violation warning is the same as the first example in this SOP. In order to reinstate the listing, please follow these steps. Document the changes/actions.

  1. Check the product images and remove the prohibited claims from infographics.

  2. Download a category listing report (CLR) and update the following attributes:

    1. Pesticide Marking: EPA Registration Number

    2. Pesticide Registration Status: This product qualifies for an exemption from registration under the U.S. Federal Insecticide, Fungicide, and Rodenticide Act.

  3. Remove any claims that aren’t allowed under the conditions of the minimum risk pesticides set by EPA. Upload the updated CLR and take the batch ID.

  4. Go to A+ contents and look for the ASIN. Remove the prohibited claims from description, images and alt text keywords.

  5. If you’re confident that everything is set, go to Performance > Account Health > Restricted Product Policy Violations > Look for the ASIN > Appeal > Check the boxes and submit. Wait 24 hours before the listing gets reinstated.

  6. If the product is pesticide gated, click the Inactive link and the Request Approval Link. It’ll send you to Pesticide Course. It’ll take roughly 30 minutes to complete and you need to pass the quiz. Here’s the course’s answer sheet.

What if the listing remained yanked?

  1. Send a ticket. Follow this pathway Help > Get Support > Selling on Amazon > Or, browse for your issue in the menu > Products, Listings, or Inventory > Inventory file upload issue.

  2. Title/Reason/Short Desription: “US - Restricted Products - Appeal - ASIN: B0xx”

  3. Body (the following is just an example, please don’t copy but tweak it depending on the actions you took).

Greetings,

ASIN B0xx has been identified as a pesticide product.

We want to dispute that ASIN B0xx is compliant with the Minimum Risk Pesticides of the Environmental Protection Agency (EPA).

https://www.epa.gov/minimum-risk-pesticides/conditions-minimum-risk-pesticides 

According to EPA, in order to qualify for the minimum risk pesticide, a product must meet the following conditions:

Condition 1: The product's active ingredients must only be those that are listed in 40 CFR 152.25(f)(1).

Condition 2: The product's inert ingredients may only be those that have been classified by EPA as:

  • Listed in 40 CFR 152.25(f)(2)

  • commonly consumed food commodities, animal feed items, and edible fats and oils as described in 40 CFR 180.950(a), (b), and (c); and

  • certain chemical substances listed under 40 CFR 180.950(e).

Condition 3: All of the ingredients (both active and inert) must be listed on the label. The active ingredient(s) must be listed by label display name and percentage by weight. Each inert ingredient must be listed by label display name.

Condition 4: The product must not bear claims either to control or mitigate organisms that pose a threat to human health, or insects or rodents carrying specific diseases.

Condition 5: The name of the producer or the company for whom the product was produced and the company’s contact information must be displayed prominently on the product label.

Condition 6: The label cannot include any false or misleading statements.

We properly declared the active ingredients on the product label and in the product description. The product does not bear claims either to control or mitigate organisms that pose a threat to human health, or insects or rodents carrying specific diseases. We have attached the product label for further review.

Please send this to the internal team for further review and reinstatement

Get the case ID and monitor the updates.

FAQ

What if my appeals are constantly rejected?

Please follow these suggestions:

  1. Recheck the label and see if it’s compliant with the Minimum Risk Pesticides.

  2. Sometimes it takes weeks before the appeal gets accepted. Keep insisting.

Pesticide/Pesticide Device

Make sure that everything is set especially the following attributes under compliance section of the product in SC:

  1. Pesticide Marking: EPA Registration Number / EPA Establishment Number

  2. Pesticide Registration Status: This product is a pesticide or pesticide device, as defined under the U.S. Federal Insecticide, Fungicide, and Rodenticide Act

  3. Pesticide Certification Number: [Input the EPA number]

Note:

Amazon will ask for the Product Label and it should have the EPA number on it.

Troubleshooting Steps:

The policy violation warning is the same as the first example in this SOP. In order to reinstate the listing, please follow these steps. Document the changes/actions.

  1. Make sure that all of the claims in the images, product descriptions (TBD), search term keywords, and A+ content are within the product label information.

  2. Take the Pesticide Course. It’ll take roughly 30 minutes to complete and you need to pass the quiz. Here’s the course’s answer sheet.

  3. If you’re confident that everything is set, go to Performance > Account Health > Restricted Product Policy Violations > Look for the ASIN > Appeal > Check the boxes and submit. Wait 24 hours before the listing gets reinstated.

What if the listing remained yanked?

  1. Send a ticket. Follow this pathway Help > Get Support > Selling on Amazon > Or, browse for your issue in the menu > Products, Listings, or Inventory > Inventory file upload issue.

  2. Title/Reason: “US - Restricted Products - Appeal - ASIN: B0xx”

  3. Body (the following is just an example, please don’t copy but tweak it depending on the actions you took).

Greetings,

ASIN B0xx has been identified as a pesticide product.

ASIN B0xx is a registered pesticide product an EPA Registration number and/or EPA Establishment number. We have updated the following product information:

EPA Registration Number / EPA Establishment Number: [Input the EPA number]

We confirm that all the product description, images, and search term keywords are within the policy compliance set by Amazon and EPA. Also, it’s within the product information as seen on the label and in the product manual.

We’ve attached the product label [and manual] for review and see that the EPA registration number is present [on them].

Please send this to the internal team for further review and reinstatement.

  1. Get the case ID and monitor the updates.

  2. What is a Pesticide (https://www.epa.gov/minimum-risk-pesticides/what-pesticide)

  3. Pesticides and pesticide devices (https://sellercentral.amazon.com/help/hub/reference/G202115120)

  4. Examples of Regulated Pesticide Devices (https://www.epa.gov/pesticides/pesticide-devices-guide-consumers#7)

  5. Minimum Risk Pesticide: Definition and Product Confirmation (https://www.epa.gov/minimum-risk-pesticides/minimum-risk-pesticide-definition-and-product-confirmation#:~:text=For%20more%20information-,What%20is%20a%20minimum%20risk%20pesticide%3F,%2C%20Fungicide%2C%20and%20Rodenticide%20Act.)

  6. Conditions for Minimum Risk Pesticides (https://www.epa.gov/minimum-risk-pesticides/conditions-minimum-risk-pesticides)


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