“Bug-Off” Soaps and Lotions Are Pesticides

Every summer, I start seeing handcrafted “bug-off” lotions, sprays, and soaps pop up at markets and online shops. Many of them are labeled as “natural insect repellents,” “mosquito-repelling lotions,” or even “outdoor soaps.”

Here’s the truth that surprises a lot of makers: If your product claims to repel insects, it’s a pesticide.

Not “like” a pesticide. Not “sort of” a pesticide. It is a pesticide—and it must follow the pesticide rules.

What Makes a Product a Pesticide

That means if your product’s intended use is to repel mosquitoes, ticks, fleas, ants, or any other pest—no matter how gentle, plant-based, or “natural” it may be—you’re making a pesticide.

Typical pesticide products include:

• Insect-repellent lotions or sprays used on people
• Dog flea and tick products
• Garden or lawn bug sprays
• Household insect control products
• Commercial pest-control applications

So if your lotion or soap says it “repels bugs” (in whatever wording), you’re in the same regulatory category as those products.

Who Regulates It

Pesticides are regulated by the EPA Office of Pesticide Programs (OPP) within the Office of Chemical Safety.

They must pre-approve every pesticide that goes on the market. Preapproval is based on the testing, registration, and labeling of every pesticide to ensure it “will not generally cause unreasonable adverse effects on the environment.”

That’s a high bar—and for good reason. Many pesticides are toxic at even very low levels.

Minimum-Risk Pesticides: The Only Exception

Now, not all pesticides are synthetic chemicals. Some use naturally derived ingredients that repel insects without posing serious risks to people or the environment. The EPA recognizes this and they have created an exception called “Minimum Risk Pesticides.”

These products are still pesticides, but they don’t require EPA pre-approval before sale—if (and only if) they meet strict criteria.

You still have to follow the pesticide rules for labeling, ingredients, and claims—you just don’t need to go through EPA testing and approval first.

What Qualifies as a Minimum-Risk Pesticide

To qualify for this exemption, your product must meet ALL of the following requirements:

1. Active Ingredients – Every active ingredient must be on the EPA’s approved list of minimum-risk actives (see below).
2. Inert Ingredients – All other ingredients must be on the approved “inert” list (usually food items or edible oils).
3. Label Disclosure – Every ingredient must be listed on the label. Active ingredients must show the percentage in the total product; inert ingredients must be listed after that.
4. Company Identification – The label must show the producer or distributor name, address (with street address and ZIP code), and phone number. (There is no exemption for omitting the street address.)
5. Allowed Claims Only – You may say “repels mosquitoes” or “controls ticks,” but you cannot claim to control disease-carrying insects (e.g., “repels mosquitoes that carry malaria”).
6. No Health or Safety Hype – You may not say “safe,” “non-toxic,” “harmless,” “all natural,” or “chemical-free.” Those are considered misleading unless approved.

Even though you don’t need EPA registration, the EPA can take enforcement action if you fail to meet these criteria—including warnings, stop-sale orders, or civil penalties.

Approved Active Ingredients

Below is the EPA’s table of active ingredients that can be used in a minimum-risk pesticide (as of 40 CFR § 152.25(f)(1)).
You can use one or a combination of these ingredients in any percentage.

Label Display Name	Chemical Name	CAS No.
Castor oil	Castor oil (USP or equivalent)	8001-79-4
Cedarwood oil (China)	Cedarwood oil (China)	85085-29-6
Cedarwood oil (Texas)	Cedarwood oil (Texas)	68990-83-0
Cedarwood oil (Virginia)	Cedarwood oil (Virginia)	8000-27-9
Cinnamon	Cinnamon	—
Cinnamon oil	Cinnamon oil	8015-91-6
Citric acid	2-Hydroxypropane-1,2,3-tricarboxylic acid	77-92-9
Citronella oil	Citronella oil	8000-29-1
Clove oil	Clove oil	8000-34-8
Corn gluten meal	Corn gluten meal	66071-96-3
Corn oil	Corn oil	8001-30-7
Cornmint oil	Cornmint oil	68917-18-0
Cottonseed oil	Cottonseed oil	8001-29-4
Dried blood	Dried blood	68991-49-9
Eugenol	4-Allyl-2-methoxyphenol	97-53-0
Garlic oil	Garlic oil	8000-78-0
Geraniol	(2E)-3,7-Dimethylocta-2,6-dien-1-ol	106-24-1
Geranium oil	Geranium oil	8000-46-2
Lauryl sulfate	Lauryl sulfate	151-41-7
Lemongrass oil	Lemongrass oil	8007-02-1
Linseed oil	Linseed oil	8001-26-1
Malic acid	2-Hydroxybutanedioic acid	6915-15-7
Peppermint oil	Peppermint oil	8006-90-4
2-Phenylethyl propionate	2-Phenylethyl propionate	122-70-3
Potassium sorbate	Potassium (2E,4E)-hexa-2,4-dienoate	24634-61-5
Putrescent whole egg solids	Putrescent whole egg solids	51609-52-0
Rosemary oil	Rosemary oil	8000-25-7
Sesame oil	Sesame oil	8008-74-0
Sodium chloride	Sodium chloride	7647-14-5
Sodium lauryl sulfate	Sulfuric acid monododecyl ester, sodium salt	151-21-3
Soybean oil	Soybean oil	8001-22-7
Spearmint oil	Spearmint oil	8008-79-5
Thyme oil	Thyme oil	8007-46-3
White pepper	White pepper	—
Zinc	Zinc	7440-66-6

These ingredients haved been tested and validated as repelling insects, and are considered safe enough to do so without posing unreasonable risks when used properly.

(Yes, there may be others, but these are the ones that have been approved and therefore the only ones that can be used.)

Inert Ingredients

Other ingredients (the “inerts”) must be:

• Included in the EPA list of approved inert ingredients (mostly chemicals that are safe and allowed), OR
• Commonly consumed food items (except allergens like peanuts, milk, soy, eggs, fish, crustacea, and wheat), OR
• Edible fats and oils (not essential oils used for fragrance or flavor).

In other words, all your inert ingredients—carrier oils, water, emulsifiers, etc.—must be on an approved list.

Label Requirements for Minimum-Risk Products

Your label must include:

• Product Name – A clear name that does not imply false claims or government endorsement.
• Active Ingredients – Each listed with its percentage by weight.
• Inert Ingredients – Listed collectively by name.
• Company Information – Name, street address, ZIP code, and phone number.
• Directions for Use – How to apply the product safely and effectively.
• Precautionary Statements – As needed (e.g., “Keep out of reach of children”).

You may not include any of the following:

• “EPA approved,” “safe,” “harmless,” “non-toxic,” “all natural,” or similar language.
• Health-related pest claims (“repels mosquitoes that carry West Nile virus”).
• Misleading comparisons to other pesticides.
• Legal disclaimers that contradict required statements.

Don’t Forget State Rules

The Minimum-Risk Pesticide exemption applies only at the federal level.

Each state has its own pesticide laws and registration requirements, and not all states recognize or exempt minimum-risk pesticides. In those states, you must register even minimum-risk pesticides before you sell them.

Before you invest in packaging and marketing, check with your state Department of Agriculture or Environmental Protection Agency to see what’s required.

Bottom Line

“Bug-off” soaps and lotions are always pesticides.

You can make a minimum-risk pesticide if you stick to the approved ingredients and follow the labeling and claim rules—but you can’t skip the pesticide requirements altogether.

Knowing the difference helps you stay compliant, avoid EPA or state violations, and give your customers accurate information about what they’re buying.