Preparations for Perfuming or Deodorizing Rooms

FIFRA registration is required when a product is intended to prevent, destroy, repel, or mitigate pests — including bacteria or mold — as part of its deodorizing function. A product claiming to 'eliminate odor-causing bacteria' or 'inhibit mold growth' is a pesticide under FIFRA and must be registered with the EPA before importation. Products that only mask or cover odors with fragrance generally do not require FIFRA registration, but the label's precise language is determinative.

The CPSC has issued voluntary safety standards (ASTM F2179) for candles covering flame height, container integrity, and labeling of burn instructions. While compliance is voluntary at the federal level, failure to meet these standards can expose importers to CPSC enforcement action if products cause fires or injuries. Some retail buyers require ASTM certification as a condition of purchase, making pre-shipment testing a practical necessity for market access.