Based on the label language referenced above, the pesticide product Trusepta, EPA Reg.
No. 96194-1-100220 is misbranded because the complete labeling does not bear the EPA
Establishment Number assigned under section 7 of Natures Distribution, 98179-UT-1 and
instead has the EPA Establishment 51435-WI-06 in accompanying materials. Since
Trusepta is a registered pesticide that is produced in sequential steps at multiple
establishments, the label is required to indicate the last establishment where the product
is produced. The Trusepta EPA Reg. No. 96194-1-100220 that was available at the time of
the inspection was labeled with EPA Establishment Number 51435-WI-06, which is where
the product was going for final production, rather than where the product was actually
produced. Therefore, sale or distribution of the Trusepta, EPA Reg. No. 96194-1-100220
reviewed during inspection is a violation of FIFRA section 12(a)(1)(E), 7 U.S.C.
? 136j(a)(1)(E), as a distribution or sale of a misbranded pesticide