There is a sentence that comes up in almost every white-label enquiry we take: “we want to sell hypochlorous acid as a disinfectant under our own brand.” It is a reasonable thing to want. It is also, as phrased, two quite different projects wearing the same coat, and separating them early saves a great deal of money.
Hypochlorous acid is a substance. A disinfectant is a legal category. In the United States, a product sold with a claim that it kills, controls or reduces micro-organisms on surfaces is an antimicrobial pesticide, regulated by the EPA under FIFRA, and it may not be distributed or sold unless it is registered. The claim creates the obligation. It does not matter how pure the solution is, how good the literature is, or how carefully the wording is hedged.
So this page is about the second project: how a brand puts its own name on a product that already carries an EPA registration, what that mechanism permits, and — more usefully — what it does not.
To be direct about it, since most of what follows is constraints: EcoloxTech does offer HOCl-AS200 for white label. The registration is ours, the manufacturing is ours, and the brand name on the bottle can be yours, through the supplemental distribution mechanism set out below. What that buys you is a registered disinfectant under your own label without a multi-year registration programme of your own. What it does not buy you is freedom to change the product, or freedom to change what the product says. That trade is the whole subject of this page, and it is better understood before you brief an agency than after.
About claims on this page
EcoloxTech generators produce a hypochlorous acid solution on site. They are regulated by the EPA as devices, are not registered disinfectants, and we make no efficacy claims for them or for the solution they produce. The only EcoloxTech product that carries disinfection claims is HOCl-AS200 (EPA Reg. No. 101112-1), used according to its accepted label. Research referenced here describes published studies of hypochlorous acid and electrolysed water under their own test conditions; it is not a claim for any product, and it is not a substitute for the testing your own product will need.
What the registered product is
EcoloxTech’s registered product is HOCl-AS200, EPA Reg. No. 101112-1. Its label was accepted by the EPA on 10 December 2025. Everything in this section is taken from that accepted label, because that is the only place these facts are allowed to come from.
| Label element | As accepted |
|---|---|
| EPA Registration Number | 101112-1 |
| EPA Establishment Number | 101112-FL1 |
| Active ingredient | Hypochlorous acid, 0.0174% |
| Registrant / manufacturer | EcoloxTech Inc., 160 Elaine Rd, West Palm Beach, FL 33413 |
| Minimum strength in use | Do not use the product if it contains less than 149 ppm of available chlorine |
| Surfaces | Hard, non-porous surfaces |
| Pre-cleaning | Surfaces must be precleaned before treatment |
| Application | Spray 6–8 inches from the surface |
| Contact time | Surface must remain visibly wet for 5 minutes |
| Label acceptance date | 10 December 2025 |
The organisms the label covers, with the strains tested and the contact time, are below. This table is the complete set of efficacy claims available to anyone distributing this product, including under their own brand. There is no additional list held in reserve.
| Organism (as listed on the label) | Strain | Contact time |
|---|---|---|
| Pseudomonas aeruginosa | ATCC 15442 | 5 minutes |
| Staphylococcus aureus | ATCC 6538 | 5 minutes |
| Methicillin-resistant Staphylococcus aureus (MRSA) | ATCC 33591 | 5 minutes |
| Salmonella enterica | ATCC 10708 | 5 minutes |
| Enterococcus faecium | ATCC BAA-2320 | 5 minutes |
| Escherichia coli | ATCC 43888 | 5 minutes |
| Listeria monocytogenes | ATCC 19114 | 5 minutes |
| Streptococcus pyogenes | ATCC 12344 | 5 minutes |
| SARS-CoV-2 | USA-WA1/2020 | 5 minutes |
| Norovirus (as feline calicivirus) | F9 | 5 minutes |
| Murine norovirus | MNV-G | 5 minutes |
| Adenovirus type 5 | ATCC VR-5 | 5 minutes |
| Herpes simplex virus type 2 | ATCC VR-540 (strain MS) | 5 minutes |
| Avian influenza A H3N2 | A/Turkey/Kahle/04 | 5 minutes |
| Bovine viral diarrhea virus | ATCC VR-534 | 5 minutes |
| Influenza A H1N1 | ATCC VR-1520 (A/WS/33) | 5 minutes |
| Respiratory syncytial virus | ATCC VR-26 (strain Long) | 5 minutes |
| Rhinovirus type 14 | ATCC VR-284 (strain 1059) | 5 minutes |
| Herpes simplex virus type 1 | ATCC VR-260 (strain H) | 5 minutes |
| Duck hepatitis B virus (surrogate for human hepatitis B) | — | 5 minutes |
| Human immunodeficiency virus type 1 (HIV-1) | strain MN | 5 minutes |
The mechanism: supplemental distribution
The route by which a brand sells an existing registered pesticide under its own name is supplemental distributor registration, provided for under FIFRA and set out in EPA’s regulations on distributor products. The shape of it is straightforward once you see it.
The registrant — here, EcoloxTech — notifies the EPA that a named distributor will market the registered product under a different brand name. The distributor is issued a registration number derived from the registrant’s: the base number, then a distributor suffix. The product itself does not change in any respect. What changes is the brand name on the front and the name and address of the distributor.
The registrant remains responsible for the product’s compliance. That is worth dwelling on, because it explains why a registrant will be particular about a distributor’s artwork and marketing: a distributor’s non-compliant label is the registrant’s problem too.
| You may change | You may not change |
|---|---|
| The brand name the product is sold under | The formulation, in any respect — concentration, pH, fragrance, colour, anything |
| The distributor’s name and address on the label | Any efficacy claim, or the organisms listed |
| Trade dress, within the constraints of the required label content | The directions for use, including the contact time and the pre-clean requirement |
| Which markets and channels you sell into, subject to state registration | The precautionary statements, first aid, storage and disposal text |
| Your own commercial terms | The use sites the label covers, or the surfaces named |
The practical summary: you are getting a brand name and a route to market, not a formulation. Brands that arrive wanting a bespoke concentration or a scented version are describing a different product, which would need its own registration and its own efficacy data — a multi-year exercise with a six-figure testing programme behind it.
The rule that catches everyone: your website is labelling
Most compliance trouble in this category does not come from the printed label, which has been reviewed by several people. It comes from everything else: the website, the Amazon listing, the sell sheet, the trade stand, the social post written by someone who was not in the regulatory conversation.
The governing principle is that claims made in connection with the sale of a registered pesticide may not substantially differ from the accepted label. Advertising and web copy are treated as part of the product’s labelling. Every one of the following is a claim that goes beyond the label, and each of them is common:
- Naming an organism that is not on the label. If it is not in the table above, it cannot be in your copy.
- Quoting a faster contact time than the label states, because a study or a competitor uses one.
- Describing the product as a sanitiser where the label supports a disinfectant use, or the reverse.
- Words like “sterilise”, “sterilising” or “hospital-grade sterilant”. This product is not a terminal sterilant or a high-level disinfectant.
- Implying use on skin, wounds, laundry, food, produce or in air, none of which is a surface-disinfectant use.
- Percentage reduction figures from published literature presented as product performance.
- “Non-toxic”, “safe”, “harmless” or “eco-friendly” used without qualification. Safety claims on a registered pesticide are their own category of problem.
The discipline that works is simple and slightly boring: write the marketing from the label, not from the research, and have someone whose only job is to check the copy against the label before it goes live. Put that step into the artwork approval workflow, and into the web publishing workflow, because the web copy will be rewritten more often than the bottle.
State registrations are yours
Federal registration is necessary and not sufficient. Almost every state requires a pesticide product to be registered in that state before it is sold there, most charge a fee, and most renew annually. For a supplementally distributed product, that obligation generally sits with the distributor selling under its own brand.
This is routinely underestimated. It is administrative rather than difficult, but it is fifty separate administrative processes with fifty separate calendars, and a national launch date is set by the slowest of them. If you are planning a retail listing with a fixed on-shelf date, start this before the artwork, not after it.
Two related points. First, some states apply additional scrutiny to antimicrobial claims and to certain use sites, so a label that sails through in one state can attract questions in another. Second, if you sell online, you are selling into every state, which is a fact about your registration obligations as much as about your logistics.
Reading the directions as constraints, not suggestions
The directions for use on HOCl-AS200 are not guidance. Under FIFRA it is unlawful to use a registered pesticide in a manner inconsistent with its labelling, and a distributor whose marketing shows the product being used inconsistently with the label has a problem regardless of what an end user actually does.
Three constraints on this label are worth restating because they shape how a product can honestly be marketed.
Pre-cleaning. The label requires surfaces to be precleaned. A photograph of the product being sprayed onto a visibly soiled surface, or copy describing it as a one-step clean-and-disinfect, is inconsistent with that.
Visibly wet for five minutes. The contact time is not a target, it is a condition of the claim. On a vertical surface in a warm room, five minutes of visible wetness may require reapplication, and the honest way to market that is to say so. Copy implying a wipe-and-walk-away use is claiming something the label does not support.
Hard, non-porous surfaces. Not fabric, not skin, not produce, not porous stone. The moment marketing shows a use outside that, the claim has moved beyond the label.
There is also the 149 ppm floor: do not use the product if it contains less than 149 ppm of available chlorine. That is a statement about the product’s condition at the point of use, which is why stability and packaging matter as much in this lane as in any other, and why a distributor should care about how the product is stored in its own supply chain.
Why the equipment side carries no claims
EcoloxTech both manufactures generation equipment and holds a product registration, and the two must not be blurred. Generators that produce a pesticidal substance on site are regulated by the EPA as devices. Devices are not registered products, they are not required to demonstrate efficacy in the way a registered product is, and we therefore make no efficacy claims for our generators or for the solution they produce.
For a distributor this has a clean practical consequence: the claims live with HOCl-AS200 and travel only with HOCl-AS200. If you also sell or place generation equipment, that equipment’s marketing cannot borrow the registered product’s organism list. Keep the two stories separate in your catalogue, on your website and in your sales training, and the boundary looks after itself. Blur them once and it becomes very hard to unblur.
How to use the research library without turning it into a claim
We maintain a large indexed library of published work on hypochlorous acid and electrolysed water — for example electrochemically activated saline against MRSA, the antimicrobial activity of electrolysed oxidising water and hypochlorous acid against oral pathogens and a SARS-CoV-2 surrogate. It is genuinely valuable material, and distributors reasonably want to use it.
The rule that keeps it safe is to treat research and claims as separate genres with separate places to live. Research describes what other people found, under their conditions, with their solutions, and it belongs on a resources or science page that is clearly not product labelling. Claims describe what this product does, they come from the label, and they belong on the product page. Do not let a study’s percentage reduction appear next to a buy button, do not let a study’s organism appear in a product claim, and do not paraphrase a study into something that reads as a performance statement.
Kept that way, the library does the job you actually want from it: it explains the chemistry to a technically literate buyer, and it makes the category credible, without putting the registration at risk.
The practical build
Once the lane is settled, the rest of the programme looks much like any other white-label project — specification, packaging compatibility, stability on the actual configuration, batch records and certificates of analysis. Those mechanics are covered in what a turnkey programme actually involves. The differences in this lane are the ones above: the formulation is fixed, the claims are fixed, the artwork has required content and a required layout, and the registrations are on your calendar rather than ours.
Numbers we deliberately have not put on this page
Minimum order quantities, fill sizes, unit pricing, lead times and tooling costs depend on the format, the regulatory lane and the volume, and quoting a single figure here would be misleading for most of the people reading it. Those come back in writing with the specification. Ask on the quote form and say which lane you are in — registered disinfectant, cosmetic, or not yet decided.
This is not legal advice
We can tell you what our label says and what we see brands get wrong. We are not your regulatory counsel, we cannot review your file, and FIFRA enforcement is not a place to rely on a supplier’s summary. Engage someone who does pesticide registration for a living before you print.
Questions we get asked
Do you actually offer white label on the registered product?
Yes. HOCl-AS200 is available for supplemental distribution under your own brand name. The formulation and the claims stay exactly as registered; the brand name, and the name and address on the label, become yours. Terms come back in writing with the specification — ask on the quote form and say you are asking about the registered product rather than the cosmetic line, because they are two different conversations.
Do we get our own EPA registration number?
A supplemental distributor is issued a number derived from the registrant’s: the base registration number followed by a distributor suffix. It identifies you as the distributor of that registered product. It is not a registration of your own product, and it does not let you alter the formula or the claims.
Can we change the concentration or add a fragrance?
No. A supplementally distributed product is the registrant’s product, unchanged. Any change to the formulation makes it a different product requiring its own registration, with its own efficacy data. This is the single most common misunderstanding in white-label disinfectant conversations.
Can we use a different brand name?
Yes — that is the point of the mechanism. The brand name and the distributor’s name and address change. The substance of the label, including every claim, the directions for use and the precautionary statements, does not.
Does the label cover food-contact surfaces?
Read the accepted label and follow exactly what it says for the surface in question, including any rinse requirement. Do not infer a food-contact use from a general surface claim, and do not transfer a figure from a food-additive authorisation onto a disinfectant label. They are different authorities with different limits.
Is it a sterilant or a high-level disinfectant?
No. HOCl-AS200 is not registered as a terminal sterilant or a high-level disinfectant, and must not be presented as one. Instruments requiring sterilisation or high-level disinfection are outside what this label covers.
What about the generator — can we sell that under our brand with the same claims?
The claims belong to the registered product, not to equipment. EcoloxTech generators are EPA devices; we make no efficacy claims for them or for the solution they produce, and neither should a distributor. Equipment and registered product are two separate conversations that should stay separate in your marketing.
How long do state registrations take?
It varies widely by state, and several states have annual renewal cycles and fees. Plan on it being the critical path for a national launch rather than a formality at the end.
Where to go next
The product page for HOCl-AS200 carries the label detail. If your product is a cosmetic rather than a disinfectant, the constraints are entirely different — see white-label HOCl for cosmetics and personal care. Our position on what we claim and what we do not is set out under regulations.
Written by the EcoloxTech engineering team. If you want this applied to your own facility, the free sanitation audit sizes the system and models the payback in writing, at no charge.