The U.S. Environmental Protection Agency (EPA), Region IX, through the duly delegated Assistant Director of the Enforcement and Compliance Assurance Division (Complainant), alleges that United Supplies for Aquariums and Pets (Respondent) failed
to comply with Section 7(c)(1) of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), 7 U.S.C. Section 136e(c)(1), and its implementing regulations at 40 C.F.R. Section 167.85.