Why Some Flea and Tick Products Say EPA and Others Say FDA

Who regulates what, in EPA’s words

EPA’s page on its regulation of flea and tick products opens with its own remit: EPA “is responsible for ensuring that all pesticides, including flea and tick products, sold in the United States do not cause unreasonable adverse effects when they are used according to label directions.” A flea collar, a spray, a shampoo, a powder, and most spot-on liquids have been pesticides under that rule.

The dividing line is stated on the same page. “Since the mid-1970s, EPA and the Food and Drug Administration (FDA) have determined oversight for products topically administered to animals to treat fleas and ticks based on whether the chemical is systemically absorbed into the bloodstream (FDA oversight) or remains on the skin (EPA oversight).” A product that works from inside the animal is a drug. A product that works from the surface is a pesticide. FDA’s own consumer page lists “pills and chews given by mouth” among the products it covers.

What EPA reviews before a product is sold

EPA states what registration involves. “Prior to registering a flea and tick product, EPA conducts a human health risk assessment and an ecological risk assessment,” and “also reviews companion animal safety data to determine if the product has the potential to cause harm to the animal receiving the pesticide treatment.” The human assessment “evaluates the nature and probability of adverse health effects in people who may be exposed to a flea and tick product via skin, mouth, or air.” The ecological one looks at how the product moves through and breaks down in the environment.

The review doesn’t end at registration. EPA states that it “reviews active ingredients in flea and tick product at least every 15 years,” a process it calls registration review, which “may result in label changes to pet collar products to address any identified risks of concern.”

Why EPA says the line no longer fits

The same page is unusually direct about the rule’s limits. “The agencies now understand that many of the topically administered products currently regulated by EPA do not remain on the skin and are absorbed into the bloodstream, highlighting challenges with the current approach and raising different safety concerns than originally anticipated.”

What followed is stated too. “In February 2023, EPA and FDA jointly released a whitepaper that outlines a proposal for an updated approach to clarify regulatory oversight of specific products in alignment with each Agency’s expertise,” including “a process for transferring oversight of flea and tick pet products from EPA to FDA.” So a spot-on that carries an EPA registration today may be an FDA product later, with the same chemistry. The agency on the box tells you which rules it was reviewed under, and that is the whole of what it tells you.

What both agencies say the label requires

EPA’s page on controlling fleas and ticks on your pet and FDA’s consumer update on the safe use of flea and tick products in pets give the same instructions, and the overlap is the useful part.

Use the product “only on the animal species and size/weight specified by the product label,” EPA says, and “never apply dog products to cats, and visa versa, as some pesticides are more toxic to one species than another.” Apply “only the amount indicated for the size/weight of the animal being treated,” because “using more product or a product designed for a larger animal than yours may overexpose your pet to the pesticide.” Do not apply to kittens or puppies “unless the product label specifically allows this treatment,” since “the label will tell you the minimum age or size of the pet for use.” FDA’s page says the same of young animals and adds that for pets too young for a product, a flea comb and a tick remover are the tools.

Both agencies say to talk to a veterinarian before using a product on a weak, old, medicated, sick, pregnant or nursing animal, or one that has reacted to a product before. FDA adds a line for multi-pet households: apply a spray or spot-on “to one pet at a time and keep the treated animal separated from the other(s) until the product dries,” so one animal doesn’t groom the product off another.

If something goes wrong

EPA’s instruction is specific. “If your pet experiences an adverse reaction, immediately bathe the pet with mild soap and rinse with large amounts of water,” remove a collar “if the pet experiences any adverse reaction,” and contact a veterinarian or the National Pesticide Information Center. FDA’s page says to call a veterinarian right away and that the veterinarian may recommend bathing the animal, “if it’s safe to do so,” with mild dish soap. Reports go “to EPA or FDA, depending on the label information,” which is the practical reason to keep the package: the agency that reviewed the product is the one that takes the report.

Runlow does not yet carry product records for flea and tick products, so this post names no brand. When it does, the agency, the registration or approval, and the label’s species and weight limits will render from the record, the way every product fact on this site does.

Where this comes from

Every regulatory statement above is quoted from EPA’s two pages on flea and tick products or from FDA’s consumer update, all linked in the text. Runlow has not tested any flea or tick product and makes no claim about any brand. Nothing here is veterinary advice; both agencies say to involve a veterinarian, and this post repeats that rather than adding to it.