U.S. ENVIRONMENTAL PROTECTION AGENCY

Office of Pesticide Programs Registration Division (7505P)

Ariel Rios Building 1200 Pennsylvania Ave., NW

Washillgton, D.C. 20460

NOTICE OF PESTICIDE: 1L Registration ' _ Reregistration

(under F1FRA, as amended)

Name and Address of Registrant (include ZIP Code):

Combat Insect Control Systems c/o Henkel Consumer Goods Inc. , Georgia Anastasiou, Lewis and Harrison LLC, Agent 122 C Street, NW Suite 740 Washington, DC 20001

EPA Reg.

Nwnber:

64240-62

Date of Issuance:

JAN 232009

Tenn of Issuance: unconditional

Name of Pesticide Product:

Combat Ant Killing Gel F42

On the basis of infonnation furnished by the registrant, the above named pesticide is hereby registered/reregistered under the Federal lnsecticide, Fungicide and' Rodenticide Act. Registration is in no way to be construed as'an endorsement or recommendation of this product by the Agency. In order to protect health and the environment, the Administrator, on his motion, may at any time suspend or cancel the registration of a pesticide·in accordance with the Act. The acceptance of any name in connection with the registration of a product under this Act is not to be construed as giving the registrant a right to exclusive use of the name or to its use if it has been covered by others.

This product is unconditionally registered in accordance with FIFRA Sec. 3(c)(5) provided you make the label changes specified below. Once a pesticide is registered; however, it is not regarded as permanently acceptable. Registration does not eliminate the need for continual reassessment of pesticides. If the Agency determines that, at any time, additional data are required to maintain in effect an existing registration, the Agency will require submission of such data under FIFRA section (3)(c)(2)(B).

Make the following label changes: Change the EPA Reg. No. to 64240-62.

Revise the statement "Use only in areas not easily accessible to children and pets" to read: Use only in areas inaccessible to children and pets.

Signature of Approving Official: • Date: I

'JAN 2 3 2009

/

(/ i . ..,,// t~?' /;~?/ ')"r;f.,~ , , .. ·V·'I\./)~'-· . ,y"-" '""': ,! l' l7 '-

Richard Gebken Product Manager 10 Insecticide Branch Registration Division (7505P)

EPA Fonn 8570-6

Mua

page 2 EPA Reg. No. 64240-62

On page 2, delete the following implied safety claims: , Quality & Responsibility Worldwide for more than 130 years, our brands have combined quality with respect for people and the· environment. This is what Henkel stands for- today and tomorrow.

The label claims must exclude fire and harvester ants;

Clarify the storage statements to. delete or use only one temperature.

Delete the brackets in the Precautioriary statements and the Storage and Disposal statements.

Revise the statement "for consumer use only" to read "for residential use only" and delete thebrackets.

Move the paragraph entitled "General Infonnation" so that it is not part of the Directions for Use.

Move the instruction about gel changing color to a section entitled "Use Restrictions", delete the brackets, pick one temperature and revise, in accordance with the cited product as follows: . When exposed to higher temperatures above XO for extended periods of time the gel may change color and lose effectiveness. If the gel inside the tube is darker than the color bar below, do not apply.

Delete or clarify the reference to package insert.

Delete "should" from the directions to apply a's spots as follows: Apply bait as spots.

Provide a definition of "spot" that ~an be understood by a homeowner applicator.

Move the instruction about applying gel away from food and food contact surfaces to the Use Restrictions.

Revise the statement about gel application as follows: Do not apply gel in direct sunlight. Apply gel in kitchens, garages and attics into cracks, crevices, comers and areas under and behind kitchen appliances and along baseboards, under sinks, in pantries, around pipes and water heaters.' ,

Delete brackets from the application instructions.

Delete "for best results" and "tips" from the application structions .

. ----_._-------------------

page 3 EPA Reg. No. 64240-62

Move the following revised statements to the "use restrictions" and delete brackets: Do not spray insecticides or smoke tobacco around gel bait. Clean greasy or dirty surfaces before placement. Do not use strong cleaners around bait placements. In more open areas, such as walls and floors, inside cabinets and near food, also use Combat Quick Kill Formula 3 baits for maximum ant control. Read and follow label. directions for this product.

In the section for indoor use, delete brackets and deletethe statement about use in or on electri~al equipment, which is already part of the Physical and Chemical Hazards statements and move other statements to the Use Restrictions.

In the section for outdoor use, delete the reference to "structures" which may permit . misuse. Revise the first sentence as follows and place in the Use Restrictions:. Place gel into cracks and holes in the exterior of house where you see ants, next to ant trails and areas of ant activity ..

Move the following statements on page 4 to general information: You will notice fewer ants in days. Pest population will be apparent within a week.

Delete the brackets from and move the following revised statements on page 4 to Use Restrictions: Keep exposed applied gel away from open food, feed, water, food utensils and food contact surfaces. Do nottreat food/feed preparation surfaces. Do not get on textiles or clothing. Product may stain textiles or clothing.

Delete the following statements which detract from the directions for use: Gel placements should be near ant trails, next to ant nests or in areas of suspected ant activity. This product's gel may be used as a spot or crack and crevice treatment for the indoor and outdoor control of ants.

In addition to the comments on marketing claims listed above, also revise the marketing claims as provided in Attachment A

Statements on the unit syringe label must be revised in accordance with revisions specified above.

On this label, any reference to uses of other Combat products does not constitute approval of label statements on those products.

Submit two copies of the revised final printed label for the record.

- .4

page 4 EPA Reg. No. 64240-62

This product is exempt from child resistant packaging requirements (CRP) because it is marketed as one syringe weighing 0.95 oz. Changes in package net contents may trigger CRP and must be submitted as an amendment, not as a notification.

If these conditions are not complied with', the registration will be subject to cancellation in accordance with FIFRA sec. 6(e). Your release for shipment of the product constitutes acceptance of these conditions.

A stamped copy of the label is enclosed for your records.

The basic and alternate confidential statements of formula (CSFs) dated 10/31108 are acceptable.

Summary of Comments·on Scanned Document Page: 1 Sequence number: 1 Author: asibold Subject: Cross-Out Date: 1/23/200910:02:15 AM

. TDelete the fol/owing claims which are not on the label of the cited product. [Fast acting gel that] starts killing ants on contact and the queen and colony within hours .

. [Fast acting gel that] starts killing ants, the queen and colony within hours. . , [Gel] contains Fipronil -- one of the fastest and most effective active ingredients available. Ants eat the gel, return to the colony, share the gel [insecticide] with the queen and other ants, and eradicate the colony. Kills [the] queen and entire colony

Sequence number: 2 Author: asibold Subject: Cross-Out Date: 1/23/2009 10:03:01 AM -T0elete the following comparative claim:

First specially formulated [Carpenter] Ant gel

Sequence number: 3 Author: asibold Subject: Cross-Out Date: 1/23/2009 10:04:35 AM TDelete the following comparative claim:

Unique [Carpenter] Ant formula

Sequence number: 4 Author: asibold Subject: Cross-Out Date: 1/23/2009 10:42:25 AM TDelete the following claims which are not on the label of the cited product:

[24 Hour] [Non-Stop] [Round the Clock] Ant Control [24 Hour] [Non-Stop] [Round the Clock] Ant Kill Advanced Gel Formula Advanced Gel Technology Contains [both] food and water [that ants crave] [that ants need]

Sequence number: 5 Author: asibold Subject: Cross-Out Date: 1/23/2009 10:05:08 AM ..gp.Delete the following comparative claim:

Preferred food form for [Carpenter] Ants

Sequence number: 6 Author: asibold Subject: Cross-Out Date: 1/23/2009 11 :08: 19 AM "~f.Delete the following safety and enhanced efficacy claim:

or Quality

Comments from page 1 continued on next page

............ _----_. -----------

Sequence number: 7 Author: asibold Subject: Cross-Out Oate:1/23/2009 10:06:42 AM ~Oelete or pick one temperature in accordance with the revised storage statements on this label:

Store below [80°F] [100°F]

Note: Bold. Italicized text is information for the reader and is not part of the label. [Bracketed information is optional tex!.]

Claims for front or back

~(~." : 0\

!>.-.... ter Label. October 31.2008 EPA Reg. No: 64240-

Combat Ant Killing Gel F42 Pg50f9

• "[Fast acting gel that] starts killing ants on contaot and the <'lueen, aRa coloay '.vi thin hOHrs.

• [Fast acting gel that] starts killiflg ants, the queetl and oolOflY witflin hom-so

• [Gel] contains Fi~fofiil onc of the fastest afi6 most effectivc active ingredicflts availab1e.

• ABtseat the gel, retHffi to the oolony, share the gel [insecticide] with the qY8B1l and otlu~r ants, and eradicate the colony.

• Kills [the] qHCetl and entire oolony

• Fast killing fonnula

• First specially foRHulated [caFflenter] Ant gel

• Elimination [Control] within 3-5- days

• Kills [Carpenter] Ants and the colony

• Gain control of your [Carpenter] Ant problem"

• Works within hours and up to 1 month

• Uniql:lc [Carpenter] Ant fommla

• f24 HOHr] [Non Stop] [Round the Clock] P...nt Control"

• [24 Hour] [Non Stop] [RoHnd the Clook] ,<\ont Kill

• Advanced Gel Fornmla

• M¥afleed Gel Techn~

• Contains [both] food and water [that ants CfMT@] [that ants RB@d]

• Visible results overnight

• Starts killing [ Carpenter] [Ants] in hours

• Fast acting fonnula that quickly kills [Carpenter] Ants

• Provides control of (Carpenter] Ants

• Prcrerred food form for [Carpenter] Ants

• Kills [Carpenter] Ants in the colony

• Effective against Carpenter, Pharaoh, Argentine, Ghost, Acrobat, Big-Headed, Cornfield, Field, Odorous House, Thief, Pavement, White Footed, Little Black Ants

• Satisfaction or QHality guaranteed

• Kills [Carpenter] Ants at the source

• With Fipronil

• IZkore below [gO°F] [IOODF]

5

1/a~

Page: 2 Sequence number: 1 Author: asibold Subject: Cross..:Out Date:'1/23/2009 10:40:24 AM .qp.Delete the following claims which are not on the label of the cited product:

Easy to use - nothing to activate , Long lasting defense from ants Long lasting ant defense Keeps killing for up to 1 month Kills non-stop for up to 1 month Kills ants and keeps on killing for up to 1 month Provides maximum ant control for up to 1 month Starts working [killing] in hours, [doesn't stop] [keeps] working for 1 month Laboratory [and home use] tests prove Combat provides up to 1 month of effective ant confrol Kills ants quickly Kills [ants] in hours Quick kill formula Quick killing action Quick defense Quick defense from ants Instant defense Instant defense from ants Kills ants where they hide Kills ants where they breed Kills ants where they live Kills ants you see and [even] those you don't Protects your home against ants Protects your home Protection for your home against ants Protect your home against ants Defend your home against ants Defends your home against ants Defense for your home against ants Defend[s] your home from ants

Sequence number: 2 Author: asibold Subject: Cross-Out Date: 1/23/2009 11 :09:20 AM .gp.Delete the following safety/enhanced efficacy claim:

Quality Guaranteed

Sequence number: 3 Author: asibold Subject: Cross-Out Date: 1/23/2009 10:39:47 AM , TDelete the following claims which are not on the label of the cited product:

Effective [!I Effective ant control

I· ,

Note: Bold, Italick.ed text is in/ormation/or the reader and is not part o/the label. [Bracketed information is optional text.)

Claims for front or back

• !1ksy to use .... nothing to activate • Long lasting defense from ants • Long lasting ant d€lfuns€ • Kceeps ldl1ing for sp Fe 1 month • Kills non stop for up to I month • KiHs--BfltS Bfld keeps on killing for up to 1 month • ProYide~mllximumlIDt control for up to I month

..... Maste~ Label. October 31. 2008

. EPA Reg. No. 64240-_ Combat Ant Killing Gel F42

Pg 6of9

• Starts working [killing] in hol:H's, [doesn't stop] [k@8ps] v/orking for 1 montA • . Laboratory [and home use] tests prove Combat provides up to 1 mORth of@ffectiv@ ant

control

• Kills ants quickly • Kills [ants] in hol:H's • Quick kill formula • Quick killing action • Quiek defense • QMiok def8ns6 from ants • Instant d@foos@ • Instant·defens@ from ants

• Kills ants 'llhere they hide • Ktlls ants vlhere they breed • Kills ants 'where they live • Kills flflts you see Ilfld [even] those you don't

• Protects YOMr home against ants • Protects your hOin@

• Protection for your home against ants • Protect your hom@ against ants • Defend YBUF home agaiBst ants • . Defends your home against aRts • Defense for your home against ants • D@fend[s] yom homs from ants

• Guaranteed to work [or your money back] o Satisfaction Guaranteed • ~ality Guarant@sd

• @ffectj,,ze [1] • Effuctiv@ ant control

6·

Page: 3 Sequence number: 1 Author: asibold Subject: Cross-Out Date: 1/23/2009 10:37:39 AM .qp.Delete the following claims which are not onthe label of the cited product:

Take control [!I Take control of your ant problem Stay protecte-d Stay protected from ants The hard line on ants a Combat - the hard line on ants Take the hard line on ants Take the hard line on ants with Combat With [a blend ofl [multiple] foods ants eat With multiple foods to kill ants [and the nest] Targeted Targeted ant control Targets ants Targets ants where they live Targets the nest Targets the colony For nooks and crannies For cracks and crevices Precise [!I Precise killing action Precise ant killing action Precise ant control Precision control Precision ant control Precise ant control targets ants Precise ant control targets ants where they live Advancing pest control Advancing ant control a Advancing ant control with targeted killing action a Advancing ant control with precise killing action a Advancing ant control with Combat a Specially formulated Specially formulated for ant control Specially formulated for long term control a Specially formulated for long term ant control

\O/aa

Note: Bold, Italicized text is information for the reader and is not part of the label. [Brackt:ted infurmation is optional text.]

Claims for front or back

• lIb.Jee control El] • Take control of YOHf ant problem

• Stay-proteete4 • Stay protected from ants • The hB:fti lifte en tlflts .. Eembat the h8:l'd line en ants • Take the hlU'(:llinc en flflts • Take the hSftlline eft flflts vAlli Cerm,at

• With [a blend of] [mHltipls] foods ants eat • With mHltiple feeds to kill ants [and the oost].

" 'f.aFgetea. • Targ@ted ant control • Targ@ts ants • Targsts ants whers they live • Targets the nest • . Targets the coloRY

eo For nooks and crannies . • For cracks and crsviGss

• Pr@cis@ [I] • Precise killing action • PFecise ant killing action • PR3cise ant control • Precision control • Precision ant control • Preciss ant control targets ants • Preoise ant oontrol targets ants wher€l they live

• Advancing pest control • Advancing ant control .. Advancing flHt centro I with targeted killing astion • Advancing ant centrol with precise killing action .. Advancing ant centrol with Combat

.. ~ial1y formulated " Specially formHlated for ant control " Specially formulated for long term control .. Specially formulated for long term ant eentrol

7

/--

~!,

Master Label, October 31,2008 EPA Reg. No. 64240-_

Combat Ant Killing Gel F42 Pg 70f9

"1~

Page: 4 Sequence number: 1 Author: asibold Subject: Cross-Out Date: 1/23/2009 10:38:44 AM .,gp-Delete the following claims which are not on the label of the cited product:

Professional strength . Professional performance Professional ant control strength Professional ant control performance No bad odor No objectionable odor No mess and no bad odor No mess and no objectionable odor No mess or bad odor \ No mess or objectionable odor For best results[.] use Combat [brand] ant baits. and gels For best results[.] use Combat [brand] ant baits and gels and sprays For best ant contraiL] use Combat [brand] baits and gels For best ant contraiL] use Combat [brand] baits and gels and sprays For best ant control results[,] use Combat [brand] baits and gels For best ant control resultsL] use Combat [brand] baits and gels and sprays For best results[,] use Combat [brand] products as part of a complete ant control system For best results[.] use Combat [brand] products for [your] ant control needs .

Note: Bold, Ito/iciud text is infol7ffaJion for the reader and is not part of the label. [Bmcketed information is optional tex!.]

Claims for front or back I

• 111-0fessio~al strOflgth • Professional performance • Professional ant 60ntrol strength • Professioftal ant control performance

• No bad odor • No o~ ectionable odor • No mess and no bad odor • No mess and ftO objectiomtblc odor • No mess or bad odor • No mess or objectionable odor

• For best results[,] use Combat [brand) ant baits aRe g8Js • For best resalts[,] use Cernbat [bFalHi] ant baitsaRa g~ls ana sprays • For best ant contrel[,] use Combat [brand] baits and gels • For best aftt cofttrol[,] ase Combat [braBd] baits and gels and sfJrays • For best ant eontrol results[,] use Combat [bflUle] baits and gels

MI:s;:"er Label, October 31, 2008 EPA Reg. No. 64240-_

CombatAnt Killing Gel F42 Pg 80f9

• For best aftt contrel results[,] ass Combat [bflUld] baits aRe gels and sprays • FDf best results[,] use Combat [brand] fJrodl:lcts as part of a oomplete ant control system • . For best results[,] use Combat [bran a] fJroduots for [your] ant 6ontrol needs

8

Note: Bold, Italicized text is injorma .. unjor the reader,and is not part ojthe label. [Bracketed information is optional text.]

Master Label, October 31, 2008 EPA Reg. No. 64240-_

Combat Ant Killing Gel F42 Pg 1 of 9

!

COMBAT® Ant Killing Gel F42 [Alternate Brand Names to be Determined]

[The label may include illustrations of target pests (ants) and/or the syringe]

ACTIVE INGREDIENT: Fipronilt ...... O.OOl% OTHER INGREDIENTS: ................... 99.999% tCAS No. 120068-37-3

CAUTION:

KEEP OUT OF REACH OF CHILDREN

USE ONLY IN AREAS NOT EASILY ACCESSIBLE TO CHILDREN AND PETS

.SEE COMPLETE PRECAUTIONS ON END [SIDE] [BACK] [BOTTOM] PANEL.

Distributed by & ©2008 [2009] Combat Insect Control Systems 15101 N. Scottsdale Rd., Scottsdale, AZ 85254 EPA Reg. No. 64240-EPA Est. No. ----

[Combat] GUARANTEED to work

Contains 1 syringe [ reservoir]

TOTAL NET WT 0.95 oz (27g)

/t()r':¥SPtK~ED 1~rr:-~I? C~iJ~~~~~r&If~l;JTS

lL~~ jEr-~1J~ f.!~t:tC~7~J TI11~y~®d.!

JAN 232009 tJ~.'!1~~f' t~1\:~ Fl1;·~(;:tti·i r,::i~·0(.t~C~.~(~~ JY'~E~;,~dr~';.~;:< t!!f'~tJ :t~c:(~~,L::.:!.~.lt;~.le fU::.'f ~ Lt2, ~?:.r':l'i.;:t3!;!J(~~ £'.::;::.' t~>;; ~l'~:D~;ici,~e ~:5i:!t.:1!J'·~d _llirS~-eL~ E!;~'l ~l~\5~ r,~o .. .... .if). q.J.~a.::.Jv~.-:._.".~

o _ u _ t,_ :J (,

v

" u .

'" () (. (J ( ".' tJ (,...

'., u '. ',l· ... \..; ~(.t (

v\ U (., ,. II {~ 'J t..)

The label may include illustrations ofsuggested application placement sites.

[U.S.PATENTNOS. _____ ----']

Note: Bold, Italicized text is information for the reader and is not part of the label. [Bracketed information is optional text.]

PRECAUTIONARY STATEMENTS: Hazards to Humans and Domestic Animals CAUTION:

Master Label, October 31, 2008 EPA Reg. No. 64240-_

Combat Ant Killing Gel F42 Pg 2 of 9

Hannful if swallowed or absorbed through the skin. Causes moderate eye irritation. A void contact with skin, eyes, and clothing. Prolonged or frequently repeated skin contact may cause allergic reactions in some individuals. Wash thoroughly with soap and water after handling. PHYSICAL OR CHEMICAL HAZARDS: Do not use this product in or on electrical equipment due to the possibility of a shock hazard. FIRST AID: Call a poison control center or doctor for treatment advice. IF ON SKIN OR CLOTHING: Take off contaminated clothing. Rinse skin immediately with plenty of water for 15-20 minutes. [Have the product container or label with you when calling a poison control center or doctor or going for treatment.] IF IN EYES: Hold eye open and rinse slowly and gently with water for 15-20 minutes. Remove contact lenses, if present, after the first 5 minutes, then continue rinsing eye. [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. [HOT LINE NUMBER:] Combat [information] Helpline: 1-800-426-6228 STORAGE AND DISPOSAL: Do not contaminate water, food or feed by storage or disposal. . STORAGE: Store is a cool, dry area below [SO°F] [100°F] out of reach of children. DISPOSAL: If empty: Nonrefillable container. Do ncitreuse or refill this container. Offer for recycling, if available. If recycling is not available, place in trash. If partly filled: Call your local solid waste agency or [toll free number] I-SOO-CLEANUP for disposal instructions. Never place unused product down any indoor or outdoor drain.

For front or back or side panel:

Quality & .

\\~iCddwi(Je!f{;( rYll)re lr~n120 ~\;)ar$, our brards have cOfltjnGd quality v.;1h rl3GpaC1 jor PE!(t:le (IInCI tile eINirr)rln)~nL Trli~; if;. wrt3t Herkol stands fa- " tOday and lomCYfovv.

-or-

Quality & . .ili''''if1lllla&E~3>] f!:f..ote to Reviewer: Per PR-Notice 2007-4, this product will receive a batch code. The number will be laser-coded on each primary package of the product after the container is seaJed.)

G) [[The paperboard in this] [C]carton [contains] [is made from] __ . % Recycled fiber [minimum % post consumer content].]

2

Note: Bold, Italicized text is information for the reader and is not part of the label. [Bracketed information is optional tex!.]

DIRECTIONS FOR USE

Master Label, October 31, 2008 EPA Reg. No. 64240-_

Combat Ant Killing Gel F42 Pg 3 of 9

It is a violation of Federal Law to use this product in a manner inconsistent with its labeling.

GENERAL INFORMATION

This product provides fast control of [Carpenter] Ants in 3-5 days. This product is formulated to effectively control [Carpenter] Ants. That's because this product contains Fipronil, a fast-acting active ingredient. Its speed is still slow enough[, however,] for foraging ants to return to the qolony and feed the bait to larvae and queen(s) so that the entire colony is killed [through the Domino EffectTM].

[When exposed to higher temperatures [above 80°F] [above 100°F] for extended periods Of time, the gel may change color.] , . [FOR CONSUMER USE ONLY] . [SPANISH INSTRUCTIONS INSIDE BOX]

APPLICATION INSTRUCTIONS

[This package [insert] should be in possession of applicator.] Application rate is dependant on level of infestation and species to be controlled. Bait should be applied as spots.

Keep exposed gel away from open foods and food contact surfaces.

1. Inspect for ants: Place gel in areas of suspected ant activity, next to ant trails and near ant nests. Avoid applying gel in direct sunlight. Gel can be placed in cracks, crevices, comers, and areas such as tinder and behind kitchen appliances, along baseboards, under sinks, in pantry, around pipes.and water heater and in the garage and attic.

-or-1. To apply gel: [Remove cap from tip] [Break tip off], touch tip to surface and depress plunger. Recap tube after use. 2. Apply gel in spots in cracks and crevices. For best results, [make] [place 1 many spots or dabs of gel where you see ants foraging and entering the structure. 3. Do not apply gel to areas which have been recently sprayed with insecticide or contaminated. with foggers, and do ~ot spray insecticide over gel as this may cause the bait to become repellant. 4. Inspect placements and reapply as needed.

[Tips for Best Results:] • [Do not spray iJ;lsecticides or smoke around gel bait] • [Clean greasy or dirty surfaces before placement] • [In more open areas, such as walls and floors, inside cabinets, and near food, also use

Combat Quick Kill Formula 3 baits for maximum ant control] • [Do not use strong cleaners around bait placements]

3

Note: Bold, Italicized text is informaTIOn/or the reader and is not part of the label. [Bracketed information is optional text.]

DIRECTIONS FOR USE (contimued)

Master Label, October 31,2008 EPA Reg. No. 64240-_

Combat Ant Killing Gel F42 Pg 4 of 9

For indoor use: Visually inspect for ants and place gel in areas where you see ants. Do not place bait in locations that are [routinely] [frequently] washed, as bait will be removed by washing. Do not treat food preparation surfaces. Do not use this product in or on electrical equipment because a possibility of shock hazard exists. [A void contact with textiles and clothing as bait may stain.] [Product may stain textiles and clothing.]

For outdoor use: Place gel into or on adjacent to structures where you see ants, next to ant trails and suspected areas of ant activity. [You will notice fewer ants in days] [Pest population reduction will be apparent within a week]

[Keep [exposed] [applied] gel away from open food and food contact surfaces. Do not treat food/feed preparation surfaces.] [Gel placements should be near ant trails, next to ant nests or in areas of suspected ant activity.] [This product's gel may be used as a spot or crack and crevice treatmentJor the indoor and outdoor control of ants.

For questions or comments about COMBAT, call 1-800-426-6228.

4

Note: Bold, Italicized text is information for the reader and is not part of the label. [Bracketed'information is optional text.]

Claims for front or back

",~, '

Master Label, October 31,2008 EPA Reg. No. 64240-_

Combat Ant Killing Gel F42 Pg 5 of 9

• [Fast acting gel that] starts killing ants on contact and the queen and colony within hours.

• [Fast acting gel that] starts killing ants, the queen and colony within hours ..

• (Gel] contains Fipronil -- one of the fastest and most effective active ingredients available.

• Ants eat the gel, return to the colony, share the gel [insecticide] with the queen and other ants, and eradicate the colony.

• Kills [the] queen and entire colony

• Fast killing formula

• First specially formulated [Carpenter] Ant gel

• Elimination (Control] within 3-5- days

• Kills [Carpenter] Ants and the colony

• Gain control of your [Carpenter] Ant problem

• Works within hours and up to 1 month

• Unique [Carpenter] Ant formula

• [24 Hour] [Non-Stop] [Round the Clock] Ant Control

• (24 Hour] [Non-Stop] [Round the Clock] Ant Kill

• Advanced Gel Formula

• Advanced Gel Technology

• Contains [both] food and water (that ants crave] [that ants need]

• Visible results overnight

• Starts killing [Carpenter] [Ants] in hours

• Fast acting formula that quickly kills [Carpenter] Ants

• Provides control of [Carpenter] Ants'

• Preferred food form for [Carpenter] Ants

• Kills [Carpenter] Ants in the colony

• Effective against Carpenter, Pharaoh, Argentine, Ghost, Acrobat, Big-Headed, Cornfield, Field, Odorous House, Thief, Pavement, White Footed, Little Black Ants

• Satisfaction or Quality guaranteed

• Kills (Carpenter] Ants at the source

• With Fipronil

• Store below [80°F] [100°F]

5

-,-

Note: Bold, Italicized text is information for the reader and is not part of the label. [Bracketed infonnation is optional text.]

Claims for front or back

• Easy to use - nothing to activate • Long lasting defense from ants • Long lasting ant defense • Keeps killing for up to 1 month • Kills non-stop for up to 1 month • Kills ants and keeps on killing for up to 1 month • Provides maximum ant control for up to 1 month

Master Label, October 31,2008 EPA Reg. No. 64240-

Combat Ant Killing Gel F42 Pg 6 of 9

• Starts working [killing] in hours, [doesn't stop] [keeps] working forI month • Laboratory [and home use] tests prove Combat provides up to 1 month of effective ant

control

• Kills ants quickly

• Kills [ants] in hours

• Quick kill formula

• Quick killing action

• Quick defense

• Quick defense from ants

• Instant defense

• Instant defense from ants

• Kills ants where they hide • Kills ants where they breed • Kills ants where they live • Kills ants you see and [even] those you don't

• Protects your home against ants • Protects your home • Protection for your home against ants • Protect your home against ants, • Defend your home against ants • Defends your home against ants • Defense for your home against ants • Defend[s] your home from ants

• Guaranteed to work [or your money back] • Satisfaction Guaranteed • Quality Guaranteed

• Effective [!] • Effective ant control

6

Note': Bold. Italicized text is inform'a.ovtlfor the reader and is not part of the label. [Bracketed information is optional text.]

Claims for front or back

• Take control [!] • Take control of your ant problem

• Stay protected • Stay protected from ants • The hard line on ants • Combat - the hard line on ants • Take the hard line on ants • Take the hard line on ants with Combat

• With [a blend of] [multiple] foods ants eat • With multiple foods to kill ants [and the nest] • Targeted • Targeted ant control • Targets ants • Targets ants where they live • Targets the nest • Targets the colony

• For nooks and crannies • For cracks and crevices

• Precise [!] • Precise killing action • Precise ant killing action • ,Precise ant control • Precision control • Precision ant control • Precise ant control targets ants • Precise ant control targets ants where they live

• Advancing pest control • Advancing ant control • Advancing ant control with targeted killing action • Advancing ant control with precise killing action • Advancing ant control with Combat

• Specially fonnulated • Specially fonnulated for ant control • Specially fonnulated for long term control • Specially fonnulated for long term ant control

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Master Label. October 31. 2008 EPA Reg. No. 64240-_

Combat Ant Killing Gel F42 . Pg 7 of9

Note: Bold, Italicized text is information for the reader and is not part of the label. [Bracketed information is optional texL]

Claims for front or back

• Professional strength • Professional performance • Professional ant control strength • Professional ant control performance

• No bad odor

• No objectionable odor

• No mess and no bad odor • No mess and no objectionable odor • No mess or bad odor • No mess or objectionable odor

• For best results[,] use Combat [brand] ant baits and gels • For best results[,] use Combat [brand] ant baits and gels and sprays • For best ant control[,] use Combat [brand] baits and gels

Master Label, October 31, 2008 EPA Reg. No. 64240-_

Combat Ant Killing Gel F42 Pg 8 of 9

• For best ant control[,] use Combat [brand] baits and gels and sprays • For best ant control results[,] use Combat [brand] baits and gels • For best ant control results[,] use Combat [brand] baits and gels and sprays • For best results[,] use Combat [brand] products as part of a complete ant control system • For best results[,] use Combat [brand] products for [your] ant control needs

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Note: Bold, Italicized text is informatio"for the reader a"d is "ot part of the label. [Bracketed information is optional tex!.]

UNIT(Syringe) LABEL

{Not shown actual size]

Master Label, October 31, 2008 EPA Reg. No. 64240-_

Combat Ant Killing Gel F42 Pg 9 of 9

COMBAT® Ant Killing Gel F42 [Alternate Brand Names to be Determined}

Note: Do not remove this label.

ACTIVE INGREDIENT: Fipronilt ...... O.OOI % OTHER INGREDIENTS: ................... 99.999% tCAS No. 120068-37-3

KEEP OUT OF REACH OF CHILDREN USE ONLY IN AREAS NOT EASILY ACCESSIBLE TO CHILDREN AND PETS

PRECAUTIONARY STATEMENTS: Hazards to Humans and Domestic Animals CAUTION: Hannful if swallowed or absorbed through the skin. Causes moderate eye irritation. Avoid contact with skin, eyes, and clothing. Prolonged or frequently repeated skin contact may cause allergic reactions in some individuals. Wash thoroughly with soap and water after handling. PHYSICAL OR CHEMICAL HAZARDS: Do not use this product in or on electrical equipment where a possibility of shock hazard exists. FIRST AID: Call a poison control center or doctor for treatment advice. IF ON SKIN OR CLOTHING: Take off contaminated clothing. Rinse skin immediately with plenty of water for 15-20 minutes. [Have the product container or label with you when calling a poison control center or doctor or going for treatment.] IF IN EYES: Hold eye open and rinse slowly and gently with water for 15-20 minutes. Remove contact lenses, if present, after the first 5 minutes, then continue rinsing eye. [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. [HOT LINE NUMBER:] Combat [information] Helpline: 1-800-426-6228 STORAGE AND DISPOSAL: Do not contaminate water, food or feed by storage or disposal. STORAGE: Store is a cool, dry area [below 80°F [I OO°F]] out of reach of children. DISPOSAL: If empty: Do not reusethis container. Recap syringe(s) [reservoir(s)] and place in trash. If partly filled·: Recap syringe(s) [reservoir(s)] and call your local solid waste agency or toll free number 1-800-CLEANUP for disposal instructions. Never place unused product down any indoor or outdoor drain. Product may stain textiles and clothing. [For] Questions or [C]comments [7] [about Combat,] call toll free 1-800-426-6228. Distributed by & ©2008 [2009]Combat Insect Control Systems EPA Reg. No. 64240-_ 15101 N. Scottsdale Rd., Scottsdale, AZ 85254 EPA Est. No. ___ _ [U.S. Patent Nos. ]

SEE CARTON [INSERT] FOR COMPLETE DIRECTIONS AND PRECAUTIONS

NET WT 0.95 oz (27g)

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