The Illegal Trade in Chemicals

Late in 2014, the EPA started investigating online sales of pesticides through several retailers. After discovering that Amazon was distributing unlicensed pesticide products, the EPA issued several removal orders to prohibit the sales, whereupon Amazon stopped the sales and cooperated with the EPA. The EPA (2018a) estimates that, “Amazon committed nearly 4,000 violations of the Federal Insecticide, Fungicide and Rodenticide Act dating back to 2013.” The illegal sales were carried out through a service called Fulfillment by Amazon that enables third parties to use Amazon’s facilities in order to sell products, among which illegal pesticides were discovered. Following the stop sale orders, the company increased the monitoring of its website for illegal pesticides, identified and made contact with the consumers who had purchased the illegal products between 2013 and 2016, refunded them the cost of the products and signed an agreement with the EPA.

of illegal pesticide sales. This online training set up by Amazon LLC is available in English, Spanish and Chinese. According to the EPA, the illegal pesticide traffic is especially a danger for non-English speaking consumers who use some pesticide products that are illegal in the US, but that have been used for a long time in Asia. The completion of the training is a sine qua non condition for every person wishing to sell pesticides on Amazon. The agreement also provides for the payment of an administrative penalty of $1,215,700 by Amazon LLC. This Amazon agreement falls within the EPA policy based on good faith effort. Indeed, EPA encourages companies to self-disclose and remedy any environmental violation in exchange for the mitigation or cancellation of the penalties. In December 2015, the EPA announced the launch of a new portal, eDisclosure, which modernizes implementation of self-disclosure policies by creating a centralized web-based portal to receive and automatically process self-disclosed civil violations of environmental law (US EPA 2018c). The goal is to make the disclosure procedure easier, faster and more efficient, saving time for the companies and the EPA (US EPA 2018b).

The agreement provides for the development of an online training course in order to spread the awareness of the danger

The Illegal Trade in Chemicals

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