Reuman Consulting, LLC obtained a company number in 2018 but began producing pesticides prior to obtaining the required EPA establishment number. Section 7(a) of FIFRA, 7 U.S.C. ? 136e(a) states, ?No person shall produce any pesticide subject to this subchapter or active ingredient used in producing a pesticide subject to this subchapter in any State unless the establishment in which it is produced is registered with the Administrator.? Any pesticide production prior to obtaining the required EPA establishment number constitutes a violation of section ? 7(a) of FIFRA, 7 U.S.C. ? 136e(a).