On April 5, 2018, EPA issued a Stop Sale, Use or Removal Order (SSURO) against Mack Molding Company, Inc. (MMC) for FIFRA violations related to the sale and/or distribution of two unregistered pesticides. MMC is a custom plastics molder and contract manufacturer that operates EPA-registered production establishments in Arlington and Cavendish, VT. To date, MMC appears to have considered these products to be devices not requiring registration under FIFRA Section 3. However, based on a review of the products and the claims made about them, it has been determined that the products are pesticides and not devices. Under FIFRA, any pesticide must be registered under Section 3 before being distributed or sold. Neither of the MMC products has been registered. The FIFRA labeling and registration requirements are enforced federally and not by states under primacy or delegation