COMPLAINT ALLEGES IN TWO SEPARATE COUNTS THAT RESPONDENT SOLD AND DISTRIBUTED TWO UNREGISTERED PESTICIDES. RESPONDENT'S PRODUCTS ADD LIFE I AND ADD LIFE II BOTH CLAIM TO SANITIZE . SUCH STATEMENTS CONSTITUTES A PESTICIDAL CLAIM. 40 CFR SECTION 152.15 (A)(1) STATES THAT A PRODUCT MAKING A PESTICIDAL CLAIM REQUIRES REGISTRATION PURSUANT TO SECTION 3 OF FIFRA. RESPONDENT'S PRODUCTS ARE NOT REGISTERED UNDER FIFRA.