The importer, Dennis Sung, attempted to import a shipment of unregistered Virus Shut Out cards into the United States. All pesticides are required to be registered with EPA before their entry into the United States, unless certain exemptions are met, pursuant to Section 3 of FIFRA (see Section 17 of FIFRA, 7 U.S.C. Section 136o(c)). The distribution of an unregistered pesticide, without an exemption, is an unlawful act under FIFRA Section 12(a)(1)(A), 7 U.S.C. Section 136j(a)(1)(A).