The SpiroPure products in the shipment referenced above are misbranded pursuant to FIFRA section 2(q)(1), 7
U.S.C. ? 136(q)(1) and 40 CFR 156.10(a)(5) because the labeling bears statements, designs, or graphic
representations that are false or misleading and fails to bear the required EPA establishment number, directions
for use, and caution or warning statement.
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 correctly file
reports required by the Act. As required by 19 C.F.R. ? 12.114, a Notice of Arrival of Pesticides and Devices
(NOA), EPA form 3540-1, and a copy of one product label must be submitted.