EPA v. RBR PRODUCTIONS, INC.

Case summary

FIFRA NOW: 8/21/2025 RBR Productions, Inc. Notice of Warning for Violations of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Case File No. FIFRA-04-2025-3522 The U.S. Environmental Protection Agency regulates the registration, distribution, sale, and use of pesticide products pursuant to the provisions of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA or the Act), as amended, 7 U.S.C. 136 et seq. The EPA is issuing this Notice of Warning (NOW) to RBR Productions, Inc. (hereinafter RBR Productions), pursuant to section 14(a)(4) of FIFRA. As explained below, the EPA finds that RBR Productions violated FIFRA section 12(a)(2)(S) by violating a regulation issued under section 3(a) or 19. On August 21, 2024, Georgia Department of Agriculture (GDA) inspected the RBR facility located at 425 South Jackson Street, Hartwell, Georgia. During the inspection, the inspector collected the label and sale and distribution records of Let's Touch (EPA Reg. No. 62296-1). A review of the product was conducted, and it was found that the Let's Touch label collected during the inspection did not match the most recently EPA-approved label from June 20, 2017. The collected label appears to match the EPA-approved label dated August 5, 2003. There were differences between the collected label and most recent EPA-approved label. Pursuant to Section 19(a)(1)(B) of FIFRA, 7 U.S.C. 136q(a)(1)(B), the EPA may require under Sections 3 or 6 of FIFRA, 7 U.S.C. 136a and 136d, that the labeling of a pesticide contain requirements and procedures for the transportation, storage, and disposal of the pesticide, any container of the pesticide, any rinsate containing the pesticide, or any other material used to contain or collect excess or spilled quantities of the pesticide. By not including a correct Storage and Disposal section, the product does not appear to meet the Section 19 requirements, in violation of to Section 12(a)(2)(S) of FIFRA, 7 U.S.C. 136j(a)(2)(S). Furthermore, no batch code was observed on the products in inventory. RBR Productions stated that the company does not use batch codes on the repackaged Let's Touch (EPA Reg. No. 62296-1) products. Pursuant to Title 40 of the Code of Federal Regulations (C.F.R.) 156.140(a)(4), a lot number, or other code used by the registrant or producer to identify the batch of the pesticide product which is distributed and sold is required. By not including a batch code, the product does not appear to meet the Section 19(a)(1)(B) of FIFRA, in violation of to Section 12(a)(2)(S) of FIFRA, 7 U.S.C. 136j(a)(2)(S).

Defendants (1)

• RBR PRODUCTIONS, INC.Named in settlement

Facilities (1)

• RBR PRODUCTIONS INC

  425 SOUTH JACKSON ST, HARTWELL, GA, 30643

  Registry ID: 110067093120

Statutes cited

• FIFRA 12A2S — Violate Regulations Under 3(a) or 19

Enforcement conclusions (1)

• RBR PRODUCTIONS, INC.entered 2025-08-21

  Primary law: FIFRA

Timeline (3 milestones)

• 2024-12-05Enforcement Action Data Entered
• 2025-08-21Enforcement Action Closed
• 2025-08-21Final Order Issued