Counterfeit Pesticide Products for Dogs and Cats

1. What action is EPA announcing?
2. Why is EPA taking this action?
3. Are all of the Frontline and Advantage brands of pesticides counterfeit?
4. What products are affected by this action?
5. How can I determine if I have purchased the legitimate products?
6. Is there a penalty for purchasing the counterfeit products?
7. I discovered that a dog product was contained in a package intended for use on cats. Will my cat be harmed if I apply the product to it?
8. How should I dispose of a counterfeit product?
9. Who should I contact if I discover the counterfeit products in a store?
10. Who can I contact if I suspect that my pet has been harmed by one of these counterfeit products?
11. Will EPA's action mean that these counterfeit products will no longer be available?

1. What action is EPA announcing?

EPA, in cooperation with its state and regional regulatory partners, is announcing the issuance of stop sale, use, and removal orders to retailers and other distributors of certain counterfeit pesticide products for control of fleas and ticks on dogs and cats. The stop sale, use, and removal orders are intended to disrupt an effort to distribute counterfeit pet pesticides. The counterfeit pesticides appear to have been unlawfully imported and were packaged in cartons designed to look like legitimately registered pesticides available in the U.S. under the trade names "Advantage" and "Frontline." The orders prohibit retailers and other distributors from distributing or selling the counterfeit pesticide products and require their proper disposal.

2. Why is EPA taking this action?

EPA is responsible for assuring that all pesticides sold in the United States do not cause adverse effects under EPA-approved label use conditions. 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, among other things, may be missing instruction leaflets bearing directions for use required under U.S. law. Further, the Frontline applicators may not be in the required child-resistant packaging. In addition to the inadequate labeling and packaging, consumers cannot be assured that the counterfeiters inserted the appropriate size applicator for the animal pictured or otherwise indicated on the retail carton of either the Advantage or Frontline products. So, use of the counterfeit products may put the treated pet at risk.

3. Are all of the Frontline and Advantage brands of pesticides counterfeit?

Consumers should be aware that the Frontline and Advantage brands of pesticides are registered by EPA. The manufacturers of these two product lines are not implicated in the enforcement actions EPA is announcing. However, product inventory that may be available at the retail level at this time could include both counterfeit and legitimately registered and marketed pesticides. Therefore, EPA is advising you about this problem and recommending that you determine whether the product you are considering or have purchased appears to be a counterfeit of the EPA-registered pesticides.

4. What products are affected by this action?

The following are brand names and EPA registration numbers of legitimate products. The counterfeit products may use these same names and numbers.

• 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)
• Advantage 18 for Cats (EPA Reg. No. 11556-118)

5. How can I determine if I have purchased the legitimate products?

The pesticide products are sold in a carton. It is difficult to distinguish counterfeit products from EPA-registered products because they look very much alike. To determine if the product you have purchased is legitimate, check to see if it meets the following criteria. If the product fails any one of these criteria, it most likely is an illegitimate product and should be disposed of properly.

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 looks like this; note the notch between the individual applicator packages, which generally are absent on counterfeit products. Text on the package is in English only.

   Frontline Applicator Package (Front)
   
   Frontline Applicator Package (Back)
   

5. Once you open the applicator package, each individual applicator has a label that includes the registrant's name "Merial;" the product name; the EPA registration number (see list above); the net contents in fluid ounces (fl. oz.) (not in metric measure, i.e., ml); 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 on which the product is to be used.

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 that 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.

   Advantage applicator tube
   

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% imidacloprid). A counterfeit product may have an active ingredient statement that differs (such as 10%).

6. Is there a penalty for purchasing the counterfeit products?

For individual consumers, there is no penalty for purchasing a counterfeit product. Penalties only apply to persons who distribute or sell counterfeit products. However, purchasing a counterfeit pesticide may place you and your family at risk. For example, first-aid treatment directions may not be immediately available in case of an emergency. Further, a child may be harmed if he or she is able to open a package that is not child-resistant. Thus, EPA is recommending that consumers dispose of product that has been discovered to be counterfeit.

7. I discovered that a dog product was contained in a package intended for use on cats. Will my cat be harmed if I apply the product to it?

If you discover inconsistencies like this, do not use it. EPA encourages consumers to dispose of counterfeit pesticides they may have inadvertently purchased.

8. How should I dispose of a counterfeit product?

If you discover that you have one of the counterfeit products, you should contact your local solid waste agency* for information on proper disposal in your community. Your local government may recommend that you take the product to a household hazardous waste collection program. If allowed by your local government, you may put the counterfeit product in your trash. You may also contact an organization named Earth 911 at 1-800-CLEANUP or http://www.earth911.org/ to obtain community disposal information.

* To identify your local solid waste agency, look in the government section of your phone book under categories such as solid waste, public works, or garbage, trash or refuse collection.

9. Who should I contact if I discover the counterfeit products in a store?

You should notify the store staff. You may also alert EPA to counterfeit products by visiting the Agency's Web site at www.epa.gov/compliance/complaints.html for enforcement matters or by contacting the Agency's regional office serving your state. See http://www.epa.gov/pesticides/local/index.htm to determine which office serves your state.

10. Who can I contact if I suspect that my pet has been harmed by one of these counterfeit products?

First, contact your veterinarian for medical assistance and advice. In addition, the National Pesticide Information Center (NPIC) is an EPA-sanctioned toll-free helpline designed to assist in providing answers to most questions regarding pesticides and pesticide poisonings. You can reach NPIC at 1-800-858-7378, daily from 6:30 a.m.- 4:30 p.m. (PT). NPIC also has a Web site with comprehensive pesticide information at http://npic.orst.edu/.

11. Will EPA's action mean that these counterfeit products will no longer be available?

EPA is continuing to pursue this issue. Unfortunately, it is likely that counterfeit and other illegal products may still be available. You should be careful when purchasing products such as these to look for the indicators described above. In addition to the counterfeited products described above, other illegal versions of these products may be available, including the following:

• foreign labeled product with stickers containing some U.S. information
• foreign-labeled products.

Related Information

For more information on problems with illegal pesticides and tips for flea and tick control please see the following:

http://www.epa.gov/pesticides/health/illegalproducts/ or
http://www.epa.gov/pesticides/factsheets/flea-tick.htm

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