EPA cracks down on counterfeit flea, tick products

Washington-The Environmental Protection Agency (EPA) issued a stop-sale, use and removal orders to retailers and other distributors of counterfeit pesticide products for fleas and ticks.

The agency reports the stop-sale, use and removal orders are intended to "disrupt" an effort to distribute counterfeit pet pesticides for Bayer's Advantage and Merial's Frontline.

Both manufacturers applaud the government intervention.

David Deegan, an EPA spokesman, tells DVM Newsmagazine, "Clearly we recognize, there is likely a fair amount of product out there that is counterfeit." How much is anyone's guess.

Deegan says the stop-sale order was issued to increase awareness about the problem, "and ask people to identify the scope of the problem. We can't be every place and inspect every package," he says.

EPA explains the counterfeit pesticides appear to have been unlawfully imported and packaged in retail cartons, which are designed to look similar to legitimately registered pesticides sold in the United States. EPA's investigation indicates that the counterfeit products have been sold to distributors and retailers throughout the country.

The EPA action also prohibits retailers and other distributors from distributing or selling the counterfeit pesticide products and require proper disposal if discovered.

John Payne, president and general manager of Bayer HealtchCare LLC, Animal Health Division, says, "Protecting the well-being of animals is Bayer Animal Health's first priority, and we have been working diligently with EPA and the veterinary profession and its leadership to stop counterfeiters."

In support of EPA's actions, Payne adds that Bayer has taken aggressive actions to stop unauthorized sales of its products sold through licensed practicing veterinarians with a doctor-client-patient relationship.

Zack Mills, DVM, executive director of veterinary services for Merial, adds: "Merial stands behind the quality of all of our products. A good safeguard to ensure the integrity of products such as these is to purchase them from a reputable source. The best way to be confident about the source of Frontline products is to purchase them through your veterinarian."

EPA says 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 may be missing instruction leaflets bearing directions for use required under U.S. law. Frontline applicators may not be in the required child-resistant packaging.

EPA adds that consumers cannot be assured that the counterfeiters inserted the appropriate size applicator for the animal pictured or indicated on the retail carton of either brands, which could put pets at risk.

EPA says that legitimate products will likely meet all of the following criteria:

Once you open the applicator package, each individual applicator has a label that includes the registrant's name; the product name; the EPA registration number; the net contents in fluid ounces (not in metric measure); 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.

Frontline products

• The lot number on the retail carton matches the lot number on the applicator package and/or the individual applicators.

• 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.

• 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."

• The legitimate applicator package has a notch between the individual applicator packages, which generally are absent on counterfeit products. Text on the package is in English only.

• The applicator label for the dog products includes the size of the dog in pounds.

• 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).

• 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.

• 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.

• 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%).

For more information, go to www.epa.gov.

Advantage products