> But when I did work in the area there was no production or formulation facility registration...
> I find nothing on the current EPA pesticide registration web site that says production or formulation facilities require any registration today.

FIFRA Section 7 says that production of pesticides, active ingredients or devices must be conducted in registered establishments. ("Production" includes formulation, packaging, repackaging, labeling and relabeling.) 

Production in an unregistered establishment is a violation of the law. 

https://www.epa.gov/compliance/pesticide-establishment-registration-and-reporting
https://tinyurl.com/yypf87ss

Here's the enforcement statute:

https://www.govinfo.gov/content/pkg/USCODE-2011-title7/html/USCODE-2011-title7-chap6-subchapII-sec136g.htm
https://tinyurl.com/y2pu2eu9

But this is all a moot point - outsourced to a contract packaging house, or done in house by Oompa-Loompas, I still don't see beekeepers paying a markup for oxalic acid over and above the lowest price that they can find in  a walk down the hardware aisle, as they would do so even to avoid a shipping charge.

 

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