Food additive, pesticide, or both? Understanding FDA and EPA compliance
May 22, 2025
The Food and Drug Administration (FDA) and the Environmental Protection Agency (EPA) oversee a complicated statutory framework for antimicrobials that are used in food and food-contact applications. The EPA has jurisdiction over antimicrobials that meet the definition of a “pesticide” under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), while the FDA has jurisdiction over antimicrobials that meet the definition of a “food additive” under the Federal Food, Drug, and Cosmetic Act (FDCA). In some cases, both Agencies may even have joint jurisdiction. This webinar will provide an overview of how antimicrobials used in these applications are regulated, and how companies can establish compliance under the applicable statutory schemes.
Speakers: Michael Boucher, Partner, Steptoe and Joe Dages, Partner, Steptoe
