MARCH 9, 2023 - CONSENT AGREEMENT
On or about May 4, 2020, a shipment containing the product General Household Wipes arrived at the port of Memphis, Tennessee at the Memphis FedEx Hub (Port Code 2095). The wipe products were imported by the licensed customs broker, FedEx Trade Networks Transport & Brokerage
(FedEx), on behalf of the consignee, FPG. On or around May 12, 2020, FedEx filed an entry into
the CBP ACE system on behalf of FPG, for the shipment of General Household Wipes under
entry number 799-71755887. The entry was filed by Fedex as Program Code PSI which indicates
that the product being imported was a registered pesticide, but the entry was further coded under
disclaimed A, indicating the product was a pesticide that would be sold for non-pesticide use, and
therefore not regulated by the EPA under FIFRA.
17. On May 15, 2020, the EPA emailed the broker and FPG to inform them that the General
Household Wipes product being imported may be a pesticide regulated by the EPA and that a
Notice of Arrival of Pesticides and Devices [NOA; EPA Form 3540-1] may be required. The EPA
also requested that the broker and FPB provide copies of the labels affixed to the General
Household Wipes product packaging. On May 15, 2020, FPG submitted copies of labels on the
product packaging.
18. Upon review of the labels, written solely in Korean, the EPA determined that the labels contained
pesticidal claims which, when translated to English, stated: Super str