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> Your first citation is simply a blanket site registration...
Yes, the registration is a prerequisite requirement for anyone doing anything with any product - even just putting a label on a pesticide.
> So, I suppose there is also some kind of registration process for your lawn and garden store so the government knows where they are located.
No, FIFRA Section 7 applies only to the types of entities I listed - those who make, distribute, package and label pesticides. Retailers are not included.
> In the case of oxalic acid this simply means anyone selling oxalic acid to be used as a miticide would need to have the last packaging site registered.
> That is where he fills the bottles and puts his site number on the pesticide use label on the product.
Yes, one would need such a facility registration.
> Or do what Mann Lake is doing and only label it as bleach to clean your wooden ware and you do not need a pesticide site number.
Bleach clearly can have a pesticidal effect, but bleach is not considered pesticide under FIFRA unless a "pesticidal claim is made on their labeling in connection with their sale and distribution." 40 C.F.R. ยง 152.10(a). That said, there have been lots of enforcement actions where the EPA fined a company distributing/selling something where they had "actual or constructive knowledge that the substance will be used or is intended to be used as a pesticide".
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