What “Minimum-Risk” Means on a Bug Repellent Label

There’s no EPA registration number on a tube of Notch. People ask about that, and they should. It isn’t a gap. It’s a different path to the shelf, with its own rules, and once you know them you can read any repellent label in about a minute.

The first thing to know: to the EPA, a pesticide is anything meant to repel, kill or control pests. That includes the lotion you rub on your arms before dinner on the patio, so every repellent sold in the U.S. falls under the federal pesticide law, FIFRA.

How to read the label in three steps

1. Find the active and its percentage

   “Geraniol 5%” tells you exactly what’s doing the work and how much of it there is. “Proprietary essential oil blend” tells you nothing. Plant actives only work above a certain strength, so the number matters as much as the name.

2. Look for an EPA Reg. No.

   If it’s there, the product went through EPA registration. Registered actives include DEET, picaridin, IR3535 and oil of lemon eucalyptus.

   If it isn’t there, the product is claiming the minimum-risk exemption, FIFRA 25(b). The EPA keeps short lists of active and inactive ingredients it considers to pose minimum risk, mostly plant oils and plant-derived compounds like geraniol, lemongrass oil, citronella oil and peppermint oil. A product made only from listed ingredients, and labeled to the rules, is exempt from federal registration.¹ Those rules say the label must:¹

   • List every ingredient, with the percentage of each active.
   • Use only listed actives and permitted inactives.
   • Name the company that made it, with a full street address and phone number.
   • Make no disease claims. It can say it repels mosquitoes or ticks, not that it protects you from what they carry.
   • Make no false or misleading claims. The EPA gives “chemical-free” and “recommended by EPA” as examples.

   Federal exemption isn’t the whole story, either. Many states require minimum-risk products to register with them before they can be sold there.¹

   Geraniol research on BugRepellent.GuideCitronella oil research on BugRepellent.Guide

   BugRepellent.Guide is a repellent research site run by the Notch team.

3. Check the directions and the promises

   The directions tell you how much to use and how often to reapply. The promises tell you whether the brand knows the rules. Disease claims or “chemical-free” on a product with no EPA Reg. No. are red flags.

When a “natural” repellent doesn’t follow the rules

The exemption only covers products that meet every condition. A repellent that misses even one isn’t minimum-risk, and if it isn’t registered with the EPA either, it can’t legally be sold. The EPA itself warns that there are products on the market that neither qualify for the exemption nor are registered.²

Researching labels for BugRepellent.Guide, we’ve seen the same problems come up again and again in products sold as natural repellents:

• An active that isn’t on the list. Oil of lemon eucalyptus is the most common example. It’s an EPA-registered active, not a minimum-risk one, so a repellent that relies on it needs an EPA registration number.
• No percentages. A label that just says “essential oils,” or names the oils without amounts, doesn’t meet the rule.
• Actives hidden as “fragrance.” When the ingredients doing the repelling are listed only as fragrance or a proprietary blend, there’s no way to know what’s in the bottle or how much.
• Repellent claims on a cosmetic. Some body mists are sold as fragrance but say they help repel mosquitoes. Once a product claims to repel pests, it’s a pesticide, whatever aisle it sits in.
• Claims the rules don’t allow. Promises about disease protection, or lines like “chemical-free” and “recommended by EPA,” which the EPA gives as examples of misleading claims.¹

This matters because the rules are what make a minimum-risk label something you can rely on. Skip them and you can’t tell which active is on your skin, how much, or whether there’s enough to do anything. Geraniol, for example, needs to be around 5%; an undisclosed amount can mean minutes of protection instead of an hour. And every product that overpromises makes it harder to trust the plant-based repellents that do the work.

Does “minimum-risk” mean it works?

No. Minimum-risk describes what goes into a product, not how well it performs. Two repellents can both be minimum-risk and work very differently, because the ingredient and its strength make all the difference. Geraniol at 5% is one of the best-studied plant-based options, while some popular oils wear off in minutes. That’s the whole reason we built Nourish + Defend the way we did: a minimum-risk lotion, 5% geraniol, every ingredient on the tube.

Our journey to Notch

Want to go deeper? Here’s which natural repellents actually work, and how BugRepellent.Guide scores every product, ours included, by the same published rules.

Two questions we get a lot