Bilt-Hamber Touch-Less Sugar Based Prewash is not registered pursuant to section 3 of
FIFRA, 7 U.S.C. ? 136a. Therefore, Bilt-Hamber Touch-Less Sugar Based Prewash is an
unregistered pesticide. Importing Bilt-Hamber Touch-Less Sugar Based Prewash in the
shipment referenced above is a violation of FIFRA section 12(a)(1)(A), 7 U.S.C.
? 136j(a)(1)(A), as a distribution or sale of an unregistered pesticide.
The shipment that arrived at the border for import is also in violation of FIFRA section
12(a)(2)(N), 7 U.S.C. ? 136j(a)(2)(N), because a registrant, wholesaler, dealer, retailer, or
other distributor failed to file reports required by FIFRA.