UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, DC 20460

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, DC 20460
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                         WASHINGTON, DC 20460

                                                                                          OFFICE OF CHEMICAL SAFETY
                                                                                          AND POLLUTION PREVENTION

                                                  February 19, 2020

 Georgia Anastasiou
 Agent for International Consolidated Business Inc.
 c/o Lewis & Harrison, LLC
 2461 South Clark Street, Ste.710
 Arlington, VA 22202

Subject:                Label Amendment – Label Amendment to Add the USDA Biobased certification
                        mark on the label with the following disclaimer statement: "*This mark is not an
                        indication of safety. [Read and follow all label instruction] and; Add the language
                        "Made from Naturally Derived ingredient”.

                          Product Name: Toilet Bowl Cleaner
                          EPA Registration Number: 88472-2
                          Application Date: December 2, 2019
                          Decision Number: 558442

 Dear Ms. Anastasiou:

 The amended label referred to above, submitted in connection with registration under the Federal
 Insecticide, Fungicide and Rodenticide Act, as amended, is acceptable. This approval does not
 affect any conditions that were previously imposed on this registration. You continue to be
 subject to existing conditions on your registration and any deadlines connected with them.

 A stamped copy of your labeling is enclosed for your records. This labeling supersedes all
 previously accepted labeling. You must submit one copy of the final printed labeling before you
 release the product for shipment with the new labeling. In accordance with 40 CFR 152.130(c),
 you may distribute or sell this product under the previously approved labeling for 18 months
 from the date of this letter. After 18 months, you may only distribute or sell this product if it
 bears this new revised labeling or subsequently approved labeling. “To distribute or sell” is
 defined under FIFRA section 2(gg) and its implementing regulation at 40 CFR 152.3.

 Should you wish to add/retain a reference to the company’s website on your label, then please be
 aware that the website becomes labeling under the Federal Insecticide Fungicide and Rodenticide
 Act and is subject to review by the Agency. If the website is false or misleading, the product
 would be misbranded and unlawful to sell or distribute under FIFRA section 12(a)(1)(E). 40
 CFR 156.10(a)(5) list examples of statements EPA may consider false or misleading. In addition,
 regardless of whether a website is referenced on your product’s label, claims made on the
 website may not substantially differ from those claims approved through the registration process.
 Therefore, should the Agency find or if it is brought to our attention that a website contains false
 or misleading statements or claims substantially differing from the EPA approved registration,
 the website will be referred to the EPA’s Office of Enforcement and Compliance.

 FQPA Label Acceptable v.20150320
Page 2 of 2
EPA Reg. No. 88472-2
Decision No. 558442

Your release for shipment of the product constitutes acceptance of these conditions. If these
conditions are not complied with, the registration will be subject to cancellation in accordance
with FIFRA section 6. If you have any questions, please contact Srinivas Gowda by phone at
703-308-6354, or via email at gowda.srinivas@epa.gov.

                                                     Sincerely,

                                                     Jacqueline Hardy
                                                     Product Manager 34
                                                     Regulatory Management Branch II
                                                     Antimicrobials Division 7510P

Enclosure: Stamped Accepted Label
Toilet Bowl Cleaner
                                                                   Limited Disinfectant             02/19/2020
.

                         Active Ingredient:                                                                88472-2
                         L-lactic Acid………………………………………….. 7.2%
                         Other Ingredients………………………………… ... 92.8%
                         Total……………………………………………….. 100.0%

                                                                       CAUTION
                                             KEEP OUT OF REACH OF CHILDREN

Manufactured by:
International Consolidated Business Inc.
19800 MacArthur Blvd. Suite 300,
Irvine, CA 92612
Product of U.S.A.
1-866-578-4395

EPA Reg. No. 88472-2
EPA Est No.
Net Contents:

Bold italicized language is information for the reviewer and not part of the label.       Toilet Bowl Cleaner 2/11/2020
Bracketed is intended to be optional language                                                                Page 1 of 4
Optional Marketing & Cleaning Claims
-Bleach Free
-Bottle made of XX post-consumer [waste] [recycled plastic]
-Brighten your home
-Brighten your world
-Cleaner [Cleanser]
-Deodorizes
-Fights or removes [tough] [hard water] stains
-Removes [rust stains] [hard water build-up] [lime scale stains] [mineral deposits]
-Lemon Scent
-Coats the bowl [to stay in contact longer]
-Contains no (does not contain) [abrasives] [bleach] [chlorine] [harsh acids] [petroleum solvents] (and)
[phosphates]
- Contains non-VOC emitting agents
- Commercial
- Custodian [Custodial] [cleaner]
 -Dye Free
- Easy to Use
- Every day we make choices that impact our lives, including the products we used to clean our homes.
With this in mind we’ve developed a line of highly effective home care products called _____.
-For daily [everyday] use [cleaning]
-Maximum cleaning power
-New (Introductory 6 month claim)
-No petroleum solvents
-Phosphate free
-Residential [cleaner]
- For use in:
       Colleges                      Hotels [Motels]                      Public restrooms
       Day Care facilities           Manufacturing facilities [plants]    Schools
       Correctional facilities       Office buildings                     Sport facilities
       Commercial facilities         Prisons                              Universities
       Health clubs
       Homes [Households]
- Will not harm septic tanks
-Thick cleaning action

Optional Biodegradable Surfactant Claims
-Biodegradable Surfactants§
-The surfactants [contained] in this product are biodegradable§
§
  Surfactants are cleaning agents
§§
   Only the surfactants contained in this product are biodegradable. Surfactants are cleaning agents.

Bold italicized language is information for the reviewer and not part of the label.     Toilet Bowl Cleaner 2/11/2020
Bracketed is intended to be optional language                                                              Page 2 of 4
Optional Claims
- Antimicrobial [action] [formula]
- Kills gram-negative bacteria
- Kills salmonella enterica and pseudomonas aeruginosa
 -Limited disinfectant against bacteria of intestinal origin
-This product is effective against salmonella enterica and pseudomonas aeruginosa.
- Made from Naturally Derived ingredients

Optional Symbols:

This mark is not an indication of safety. [Read and follow all label instructions.]

Bold italicized language is information for the reviewer and not part of the label.   Toilet Bowl Cleaner 2/11/2020
Bracketed is intended to be optional language                                                            Page 3 of 4
Directions for Use:
It is a violation of federal law to use this product in a manner inconsistent with its labeling.
To Clean and Deodorize
   1. Empty water from toilet. Remove gross filth or heavy soil from all surfaces.
   2. Squeeze and twist nozzle “OPEN”.
   3. Point nozzle under the rim of your toilet bowl and squeeze gently.
   4. Spread evenly over all surfaces with your toilet cleaning brush.
   5. To kill gram-negative bacteria let stand for 5 minutes.
   6. Stubborn stains may need scrubbing.
   7. Repeat if necessary.
   8. Turn nozzle “Off” for safe storage.

Precautionary Statements
Hazards to Humans & Domestic Animals
CAUTION: Causes moderate eye irritation. Avoid contact with eyes, skin or clothing. Wash
thoroughly with soap and water after handling and before eating, drinking, chewing gum, using
tobacco or using the toilet.

FIRST AID
If in        Hold eye open and rinse slowly and gently with water for 15-20 minutes.
Eyes:        Remove contact lenses, if present, after the first 5 minutes, then continue rinsing.
             Call a poison control center or doctor for treatment advice.
If on        Take off contaminated clothing.
Skin or      Rinse skin immediately with plenty of water for 15-20 minutes.
Clothing Call a poison control center or doctor for treatment advice.
Have the product container or label with you when calling a poison control center or doctor, or
going for treatment. [For emergency information call xxxxx]

Physical or Chemical Hazards: Contains lactic acid. Do not mix with chlorine bleach or other
household chemicals, as hazardous gases may be released.

Storage & Disposal language for household containers
Storage & Disposal
Store in areas inaccessible to small children. Non-refillable container. Do not re-use or refill this
container. Offer for recycling if available or discard in trash.

Storage & Disposal language for commercial and institutional use sites
Storage & Disposal
Do not contaminate water, food, or feed by storage and disposal
Pesticide Storage: Store in areas inaccessible to small children.
Pesticide Disposal: To avoid wastes, use all material in this container by application according
to label directions. If wastes cannot be avoided, offer remaining product to a waste disposal
facility or pesticide disposal program.
Container Handling: Nonrefillable container. Do not reuse or refill this container. Offer for
recycling if available or dispose of in sanitary landfill or by other procedures approved by state
and local authorities.
Bold italicized language is information for the reviewer and not part of the label.   Toilet Bowl Cleaner 2/11/2020
Bracketed is intended to be optional language                                                            Page 4 of 4
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