Comment submitted by Briana R. (no surname provided)

Hello. I am I am a student interested in public health and environmental policy, particularly how regulations affect consumer safety. During the COVID-19 pandemic, my family relied heavily on disinfectants and became more aware of how product labels communicate effectiveness. This experience motivates my interest in the EPA’s interim guidance on expanding antiviral claims. This comment addresses the EPA’s interim guidance allowing antimicrobial pesticides that meet sanitizer or disinfectant criteria to carry virucidal claims. The policy does not change testing standards and is limited to a maximum of ten years, after which the EPA will review its effectiveness. Expanding antiviral claims increases access to products that protect against viruses, which is beneficial, especially in non-healthcare settings. Shorter contact times may also improve real-world use. However, allowing antiviral claims on sanitizer-only products could confuse consumers about effectiveness levels. Research shows that labeling influences how people interpret risk and use products (Wogalter et al., 1999). Additionally, the 10-year review period may be too long to address unintended consequences. The EPA also does not clearly explain how it will evaluate the success of this policy or measure consumer understanding. The EPA should improve labeling clarity by requiring clearer distinctions between sanitizers and disinfectants, even when both are allowed to carry antiviral claims, so that consumers can better understand appropriate use contexts (Wogalter et al., 1999). The Agency should also conduct periodic evaluations of the policy, ideally every two to three years, rather than waiting up to ten years, in order to identify and address any unintended consequences in a timely manner. While the guidance expands access to useful antimicrobial products, clearer communication, earlier evaluation, and better transparency are needed. Implementing these recommendations would strengthen the policy’s impact on public health.