On or about March 14, 2009, AG Specialties LLC attempted to import 160, 275 gallon totes of a glyphosate product called ÂStrike OutÂ. EPA had reason to believe that the product was misbranded and in violation of Section 12(a)(1)(E) of FIFRA in that the establishment number appearing on the product label, EPA Establishment Number (EPA Est. No.) 74716-CHN-001, was invalid. The establishment, owed and operated by the Taicang City Pesticide Factory Company (Taicang) in Jiangsu, China, had not submitted its 2006, 2007, and 2008 annual pesticide production reports as required by Section 7 of FIFRA, 7 U.S.C. § 136e.
On March 24, 2009, prior to EPA formally issuing the SSURO, AgBio Consulting, Inc., regulatory agent for Taicang, submitted all three years (2006, 2007, 2008) of production information as required by the SSURO. EPA simultaneously issued the SSURO and the Vacation in response to the information submitted by the regulatory agent.