Is placing mothballs outside on the grass along a fence line to repel cats an illegal use of mothballs?
Generally, it is unlawful to use any registered pesticide in a manner inconsistent with its labeling under FIFRA sec. 12(a)(2)(G). At present, there are no registered pesticides containing the active ingredients in moth balls that are approved for use in repelling cats. The FIFRA section 2(ee) definition of “to use any registered pesticide in a manner inconsistent with its labeling” provides for certain exceptions under which use is lawful. For example, it is not unlawful to use a registered pesticide “against any target pest not specified on the labeling if the application is to the crop, animal, or site specified on the labeling…” This exception would not allow application of mothballs along a fence line because registered mothballs products specify the use site as “air-tight containers and storage closets.” Because applying mothballs to a fence line would not be applying them to a site specified on the labeling, such use is unlawful.