With different states implementing new regulations on rodenticides seemingly every day, it is easy to get lost in the sauce and not know what is expected of us a distributers, dealers, and pest control professionals. Therefore, we wanted to do our best to make sure that you all know as much as we do about the new rodenticide rules popping up in different states.

This list does not include every pre-existing pesticide licensing requirement in each state for non-RUPs. Please contact your state’s Pesticide Regulatory Agency, Department of Agriculture, or local extension agent to inquire further about state specific rules.

Definitions:

  • FGARs = first generation anticoagulant rodenticides
  • Warfarin (JT Eaton Product #s: 777-4, 777-9, 777-18)
  • Chlorophacinone (JT Eaton Product #: AC-90)
  • Diphacinone (JT Eaton Product #s: 704-PN, 704-AP, 709-AP, 709-PN, 276, 277)
  • SGARs = second generation anticoagulant rodenticides
  • Brodifacoum
  • Bromadiolone (JT Eaton Product #s: 716-S, 716-B)
  • Difenacoum
  • Difethialone
  • Non-anticoagulant rodenticides
  • Bromethalin (JT Eaton Product #s: 750, 754, 937, 939)
  • Cholecalciferol
  • Zinc phosphide
  • Strychnine
  • RUP = restricted use pesticides
  • PFAS = Per- and polyfluoroalkyl substances

EPA: Federal

  • SGARS are NOT currently federally listed as RUP by EPA.
  • EPA is considering legislature changes on FGARs and SGARs
  • Current EPA rules from the 2008 RMD:
    • prohibit the use of the four main SGARs in residential consumer products.

*States can choose to implement stricter restrictions than EPA, meaning a pesticide might be considered RUP in one state but not in another.

State Specific:

California

Currently, FGARs and SGARs are considered RUPs in California. As a result, there are approved and non-approved uses for products containing those actives.

The approved uses are listed below:

  • Use by mosquito or vector control districts
  • Eradication of non-native invasive species on offshore islands
  • Eradication of invasive rodent populations for the protection of threatened or endangered species or their habitats as determined by the Department of Fish and Wildlife
  • To control actual or potential infestations associated with an urgent, non-routine public heath need declared by the State Public Health Officer or a local public health officer
  • Under a research authorization issued by the Department of Pesticide Regulation or for certain research funded by the California Department of Food and Agriculture
  • At certain medical waste generators, such as:
    • Medical, dental, and veterinary offices, clinics, hospitals, surgery centers, etc.
    • Pet shops; and
    • Trauma scene waste management practitioners
  • At certain Federal Drug Administration registered and inspected facilities.
  • On agricultural sites producing any horticultural, viticultural, aquacultural, forestry, dairy, livestock, poultry, bee, or farm product.
  • At warehouses used to store food for human or animal consumption;
  • At food manufacturing or processing plants, such as a slaughterhouse or cannery;
  • At factories, breweries, or wineries;
  • On-farm water storage and conveyance facilities, or on-farm sites storing rights-of-way or other on-farm transportation infrastructure materials.

New permits and licensing requirements:

  • If an entity is the first to sell, offer to sell, distribute into, or bring into California for sale any pesticide product (including RUPs), and the entity is not a licensed pest control dealer or the company that actually registered the pesticide (the “registrant’), that entity must obtain a pesticide “broker’s” license, but the product being an RUP doesn’t require the entity to obtain an additional Department of Pesticide Regulation (DPR)-license.
  • Any RUP rodenticide labeled for any use prohibited in CA can only be sold to an end user by a Department of Pesticide Regulation (DPR)-licensed pest control dealer.
  • The end-user needs a Restricted Use Permit to purchase RUP rodenticides for the purpose of applying it for non-approved purposes.
  • If the end-user is going to apply the RUP rodenticide for an approved use purpose, they DO NOT require a Restricted Use Permit to purchase the product.
  • Dealers are required to obtain a copy of the permit authorizing the use of restricted pesticides for non-approved uses prior to delivery of the pesticide. Dealers also need to routinely question potential purchasers to determine if they are intending to use the RUP rodenticides for an approved or non-approved purpose prior to sale or delivery of the pesticide. It is also the dealer’s responsibility to keep records of questioning and sales of these RUP products.

If you have any questions about this law or determining if your use site meets an exemption, please contact your local County Agricultural Commissioner: https://www.cdfa.ca.gov/exec/county/countymap/

Connecticut

As of January 1st, 2026, SGARs will be considered RUPs in Connecticut.

  • This classification requires pesticides to be applied only by, or under the direct supervision of, a certified applicator or subject to other restrictions the commissioner imposes through regulations.

Additional neonicotinoid restriction in Connecticut:

As of October 1, 2027, using a pesticide that has any neonicotinoid is banned in Connecticut.

The exemptions are for the following if the Commissioner of Energy 1582 and Environmental Protection, after consultation with the director of the 1583 Connecticut Agricultural Experiment Station, determines that no other 1584 effective control option is available:

  • for use in, or application to, agriculture, seeds, ornamental shrubbery, or trees.
  • if not labeled for plant use, like those for personal care products, pet care, veterinary purposes, or indoor or structural pest control.
  • To eliminate an invasive invertebrate pest.

The bill authorizes the DEEP commissioner to assess a civil penalty of up to $2,500 per violation to anyone who violates the ban.

Maine

Proposing to prohibit the use of rodenticides (S.P. 142, L.D. 356 not yet passed), including rodenticidal baits, in outdoor residential settings. A certified applicator is exempt from the prohibition.

  • This bill includes the proposed rule that a person may not use any pesticide outdoors within 500 feet of a property owned by another person unless the person provides written notification to the owner, lessee or other legal occupant of the property of the intent 32 to apply pesticides at least 7 days prior to the pesticide application

Additional pesticide restrictions in Maine:

  • Bromethalin is listed as “Currently Unavoidable Use” (CUU) of PFAS in pesticide products

Massachusetts

Proposing to limit the use of anticoagulant rodenticides by licensed applicators for only public health emergencies (HB 1721, SD 1447 not yet passed).

  • If passed, will be effective on January 1st, 2027
  • Local municipalities in Massachusetts have similar bills they are voting on locally

Minnesota

Bromethalin is listed as “Currently Unavoidable Use” (CUU) of PFAS in pesticide products

New York

Considering legislature changes on FGARs and SGARs

Permits and licensing requirements:

  • Anticoagulant rodenticides above a certain active ingredient percentage threshold may only be distributed, sold, purchased, possessed and used upon issuance of a commercial or purchase permit. None of the JT Eaton products qualify for needing a commercial or purchase permit in New York.

Rhode Island

Proposed legislature (S 0651 not yet passed) for restricted use of FGARs and SGARs. These proposed rules include:

  • If passed, starting March 1, 2026, FGARs shall be prohibited from being sold in “consumer” stores and online retail stores
    • shall not apply to the sale of anticoagulant rodenticides by a wholesaler to a business that employs the following: certified private applicator, commercial applicator, certified commercial applicator or licensed commercial applicator.
  • If passed, starting January 1, 2027, SGARs shall be prohibited from being sold in “consumer” stores and online retail stores
    • shall not apply to the sale of anticoagulant rodenticides by a wholesaler to a business that employs the following: certified private applicator, commercial applicator, certified commercial applicator or licensed commercial applicator.
  • If passed, starting January 1, 2026, all FGARs and SGARs usage shall be prohibited. Exceptions to this proposed bill are the same as California.

South Carolina

Effective February 1st, 2025, all SGARS will RUP in South Carolina for a temporary period of 1 year.

New permits and licensing requirements:

  • SC requires dealers and retailers to separate stocks so RUPs are separated from non-restricted use
  • Dealers and distributors need a dealer license to sell RUPs, and then must only sell to licensed applicators
  • Dealer record keeping requirement: 2-year requirement for sales of RUPs
  • 30-day period to request compliance assistance after implementation on February 1st
  • 30-mile supervision distance, meaning there has to be a certified applicator within 30 miles from application site

Vermont

SGARs are RUP, so they fall in “Class A” pesticides

Permits and licensing requirements:

  •  A “Class A” dealer license is required to distribute or sell RUPs in Vermont, and only licensed applicators can apply RUPs.

Washington state

FGARs and SGARs are NOT RUP, but do have specific licensing requirements (see below)

Permits and licensing requirements:

  • SGARs require a dealer/manager license to sell and are not for home/garden use
  • FGARs and non-anticoagulant rodenticide products require a dealer/manager license to be sold in quantities greater than 1lb and are not for home/garden use
    • If sold in quantities less than 1 lb in a bait station, it does NOT require a license.
    • If sold in quantities less than 1 lb for below ground baiting of moles and pocket gophers only, without a bait station, it does NOT require a license.
  • If a pesticide label includes the following phrases, they require a dealer/manager license to sell and are not for home/garden use
    • Federally Restricted Use (RUP)
    • Category 1, Danger/Poison
    • Professional Use Only
    • Industrial Use
  • The pesticide label must include directions for home, residential, or animal use to be used for home and garden use and to not require a dealer/manager license to sell (all other licensing requirements still apply)

Please contact WSDA (360-902-2040 or pregistration@agr.wa.gov) for questions or clarification

The information provided in this document is to the best of our knowledge, but there are still many things that remain unclear about these new regulations. Please contact your state’s Pesticide Regulatory Agency, Department of Agriculture, or local extension agent to inquire further about state specific rules.