On August 27, 2020, EPA Region 1 issued a Stop Sale, Use or Removal Order to Global Shield Solutions, LLC d/b/a SD Labs for FIFRA violations related to the sale and/or distribution of five unregistered pesticides claiming to be FIFRA-exempt 'treated articles' (Case No. SSURO-2020-0001). SD Labs is a surface cleaning and disinfection company based out of Brookfield, CT and operates by utilizing a contract manufacturer, Phoenix Product Solutions for production of their products. SD Labs appears to have considered these products to be 'Treated Article Exempt' under FIFRA and therefore not requiring registration under FIFRA Section 3; however, based on the review of the products and the claims made about them, it has been determined that the products are pesticides and not 'Treated Article Exempt.' Under FIFRA, any pesticide must be registered under Section 3 before being distributed or sold. The SSURO will help to ensure compliance with FIFRA by preventing the distribution or sale of violative products and is intended to protect against unreasonable adverse effects on human health and the environment. The FIFRA labeling and registration requirements are enforced federally and not by states under primacy or delegation.