Companies that register disinfectant products can allow other companies to sell the product under their own product and company name. This is called supplemental distribution.
Supplemental distributor products have the same chemical composition and efficacy as primary products, but often have different brand or product names.
Whereas products with primary registrations have two-part registration numbers (e.g., EPA Reg. No. 1234-12), supplemental distributor products have three-part registration numbers (e.g., EPA Reg. No. 1234-12-1). The first two parts of this registration number reflect the primary registration, while the third identifies the distributor’s EPA company number.
List N only displays products with primary registrations because EPA has reviewed and approved the labels of primary registrations during the registration process. The labels of supplemental distributor products can only contain language in the EPA-approved master label for the primary registration but may contain only a subset of the master label’s claims. While EPA does not review the labels of supplemental distributor products, the labels of supplemental distributors are generally reviewed and approved by the states where those products are sold.
If a primary registration is on List N, EPA expects that product, as well as any supplemental distributor products associated with it, to be effective against SARS-CoV-2 when used according to the label directions.
Regardless of whether you are using a primary registration product or a supplemental distributor product, always check that the product's label includes directions for use for the pathogen on List N. For example, if List N indicates that a product will kill SARS-CoV-2 (COVID-19) if you follow the directions for rotavirus, make sure the label contains directions for use against rotavirus.