EPA v. CJH, INC, D/B/A/ GINESIS NATURAL PRODUCTS

Case summary

MAY 13, 2025 - CONSENT AGREEMENT On or around March 27, 2023, EPA reviewed Respondent's website and identified various products being advertised and offered for sale via an add-to-cart feature. The website included images of labels for various products including Ginesis Antimicrobial and Nit Free Mint Repelling Lice Spray. The website displayed certain pesticidal claims being made for Ginesis Antimicrobial, including: ?inactivates viruses and bacteria? and Safe formulation is effective against Corona. The website also displayed certain pesticidal claims being made for Nit Free Mint Repelling Lice Spray, including: ?Designed to repel lice using natural peppermint oil and Light mist on your child's hair, head wear, backpack, etc. will repel any lice that you might come in contact with. Because the website URL was displayed on the labels for the Ginesis Antimicrobial and Nit Free Mint Repelling Lice Spray products, the website is considered to be a form of labeling for those pesticidal products. On April 28, 2023, an authorized representative of EPA conducted an inspection at the Respondent?s Facility to determine Respondent?s compliance with FIFRA. During the inspection, the inspector observed the Ginesis Antimicrobial and Nit Free Mint Repelling Lice Spray products being held for sale or distribution at the Facility and collected labels and sales and distribution records for the products. The Ginesis Antimicrobial product label collected during the inspection included statements That the product was exempt from FIFRA registration as a minimum risk pesticide. However, because the product label and website labeling bore specific claims that the product could control or mitigate microorganisms (bacteria and viruses) that pose a threat to human health, the product did not meet the minimum risk pesticide requirement found in 40 C.F.R. 152.25(f)(3)(ii) but was a pesticide that was required to be registered under Section 3 of FIFRA. The sales records collected during the inspection showed that Respondent sold and distributed the Ginesis Antimicrobial product on one or more occasions between August 17, 2020, and December 12, 2022. Additionally, the product was being offered for sale on Respondent?s website at the time of EPA?s website review on March 27, 2023. At the time the product was being offered for sale, sold, and/or distributed, it was not registered as a pesticide with EPA. A review of the sales records collected during the inspection demonstrated that Respondent sold and distributed the Nit Free Mint Repelling Lice Spray product on one or more occasions between April 22, 2019, and July 23, 2021. Because the label and website labeling for the Nit Free Mint Repelling Lice Spray product bore pesticidal claims, this product was a pesticide as defined in Section 2(u) of FIFRA, 7 U.S.C. ? 136(u) at the time it was being offered for sale, sold, and/or distributed as described in the previous paragraphs. EPA?s examination of the Nit Free Mint Repelling Lice Spray product label and website labeling revealed that this product did not display the name and percentage of each active ingredient, thus did not meet the minimum risk pesticide requirement found in 40 C.F.R. 152.25(f)(3)(ii) and was therefore a pesticide that was required to be registered under Section 3 of FIFRA. At the time the Nit Free Mint Repelling Lice Spray product was being offered for sale, sold, and/or distributed, it was not registered as a pesticide with EPA as required by Section 3 of FIFRA. EPA alleges that Respondent violated Section 12(a)(1)(A) of FIFRA, 7 U.S.C. ? 136j(a)(1)(A), by offering for sale, selling, and/or distributing unregistered pesticides on multiple occasions between April 22, 2019, and March 27, 2023. Respondent consents to the payment of a civil penalty, in the amount of FORTY-FIVE THOUSAND DOLLARS ($45,000.00), which is to be paid within thirty (30) days of the Effective Date of this CAFO.

Defendants (2)

• GINESIS NATURAL PRODUCTSNamed in complaintNamed in settlement
• CJH, INC,Named in complaintNamed in settlement

Facilities (1)

• CHJ, INC. D/B/A GINESIS PRODUCTS AND GINESIS NATURAL PRODUCTS

  2600 COUNTY ROAD 5, FLORENCE, AL, 35633

  Registry ID: 110064036671

Statutes cited

• FIFRA 12A1A — Unregistered Pesticide

Enforcement conclusions (1)

• CJH, INC, D/B/A/ GINESIS NATURAL PRODUCTSentered 2025-05-13

  Primary law: FIFRA

  Federal penalty: $45,000

Timeline (4 milestones)

• 2025-05-13Final Order Issued
• 2025-05-13Complaint Filed/Proposed Order
• 2025-05-14Enforcement Action Data Entered
• 2025-06-06Enforcement Action Closed