I’ve been inundated with ads for Tougher Than Tom’s Mosquito TNT so I thought I’d post some thoughts on the device in case they might be helpful to anyone considering whether to purchase them. They are clear plastic containers that hold a liquid bait and supposedly trap mosquitoes.

A further nudge to finally write something up was the recent announcement that the company had to pay an $80,800 fine for selling this and two other products without EPA registrations, a violation of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). According to this consent decree, the labels on the Mosquito TNT (1) failed to include the names of all the ingredients and (2) lacked contact information. These violations might seem minor, but it demonstrates that the EPA conducted an investigation for some reason, possibly consumer complaints or concerns from state regulators. Therefore, if the EPA were to discover that Tougher Than Tom is still violating other aspects of FIFRA, a future enforcement action might be stronger.

The sections below document the claims the company is currently making about the product, plus my perspective on whether those claims might be warranted. I should state at the outset that I have not purchased or tested a Mosquito TNT. If somebody wants to gift one to me here’s my Amazon wishlist. My birthday is in July.

Claims about the active ingredient

According to the label, the active ingredient is sodium lauryl sulfate (0.1%). This is an implicit claim that the chemical kills mosquitoes. However, I have been unable to find any scientific publication that shows sodium lauryl sulfate kills adult mosquitoes. There are certainly web pages that claim a few drops of soap in a bucket of water can reduce surface tension enough that mosquitoes will sink when they land to oviposit, but there’s no actual evidence this happens (i.e., it might just be a rumor or myth). It could be the case, of course, that the company conducted its own research and has demonstrated toxicity against adults, but nowhere on its website is any declaration that that’s the case. All they have is this ad that asserts, “Once they land on the liquid inside they get trapped like in quicksand.” So my guess is that the company chose the chemical in part because there is evidence it can kill mosquito larvae and it is listed as a “minimum risk” ingredient (which allows it to be used without going through a complicated registration process with the EPA). A state regulatory agency could easily request that the company provide evidence to support the claim that sodium lauryl sulfate kills adult mosquitoes and, if no such data can be presented, that company revise its labels accordingly.

Claims about the inactive ingredients

According to EPA requirements, no ingredient listed as inactive may play a role in a product’s pesticidal action. But given statements by the company, the remaining ingredients are the bait and thus the reason why mosquitoes end up getting trapped. Here’s an example of the wording they use: “So how they work is they attract the mosquitoes from our yeast blend that emits a chemical reaction similar to carbon dioxide” (source). Similar statements shows up in video ads, too. This means the company views the carbon dioxide produced by (1) the yeast as it consumes the sugar (D-glucose) and (2) the reaction of sodium bicarbonate and citric acid as the reason why female mosquitoes locate the container and then decide to go through the holes in the sides. Furthermore, the company says the CO₂ is what kills the mosquitoes. Taken together, it seems like the true active ingredient is a byproduct of the inactive ingredients, especially given that the listed active ingredient has no proven toxicity to adult mosquitoes (as far as I know).

The only inert ingredient that seems to be actually inert is the silica (sand).

“All natural” claim

Tougher Than Tom asserts on Amazon and Facebook that the Mosquito TNT is “natural” or (at times) “all natural,” which legally means that no ingredient can be synthetic. This seems to be a false statement because both sodium lauryl sulfate and sodium bicarbonate are synthetically produced. The company also uses the word “natural” inside hidden meta-text on its website. Finally, most of the Facebook posts (e.g.) use #naturalingredients as a hashtag (along with #chemicalfree which is also false).

Efficacy claims

In order to qualify for exemption from EPA registration, a pesticide product cannot make any false or misleading claims, and that is especially true for efficacy claims for mosquitoes (which can transmit pathogens that cause disease). Here’s a partial list of statements made on Tougher Than Tom’s website and social media accounts that likely lead consumers to believe these devices are highly effective. An exaggerated efficacy claim is misleading.

1. “Extremely effective.“
2. “Ready to enjoy a mosquito-free season??“
3. “Just hang around your property and enjoy a mosquito-free yard.“
4. “Keep mosquitoes away from your yard this summer.”
5. “Say goodbye to mosquitoes.“
6. “Finally, a simply way to keep mosquitoes away.”
7. “No more worrying about itchy bites.“
8. “Enjoy the outdoors without the buzzing.”
9. “Enjoy your outdoor space in peace!”
10. “Proven to work for up to 30 days.”
11. “Provides up to 30 days of protection.“
12. “Highly effective bait formula.”
13. “Irresistible to mosquitoes.”
14. “Mosquito TNT begins working immediately after the jars are hung on your property.”
15. “Enjoying a mosquito-free yard couldn’t be easier.“
16. “Proven ingredients used for generations.”
17. “New and improved.”

It should be pointed out that Tougher Than Tom does not seem to have any photographs or videos of mosquitoes going into the Mosquito TNT. A state regulatory agency could ask the company to provide proof that device attracts mosquitoes when used outdoors. I suspect that Tougher Than Tom has no photographic or video evidence of mosquitoes near its traps (if it did, they’d appear on the website and in ads, I think).

But Tougher Than Tom does use photographs of the mosquitoes inside the Mosquito TNT as a way to visually demonstrate their effectiveness. For example, on the Amazon product page a smiling woman is shown holding a Mosquito TNT that is filled with mosquitoes, and there’s another one featured in the graphic that compares the device to repellents. But if you look at the mosquitoes in the liquid, some seem to be clinging to the sides of the jar as if they weren’t actually underwater. I’m sure I’m not the first to notice that this image looks fake. It took me approximately 10 minutes to find the original photograph that Tougher Than Tom photoshopped into the two ads. To make the manipulation clear I’ve created a file that shows the two trap images and the source image, then used colored circles to show recognizable groupings of mosquitoes. Tougher Than Tom does not indicate anywhere that the images in its ads are fake. These images could easily be viewed as misleading.

As an aside, Getty prohibits the use of the photograph in ads so I think Tougher Than Tom did not purchase the rights to the image. There’s an article on West Nile virus in Illinois that licensed it, so perhaps that’s where they obtained it.

Relative efficacy claims

Another rule about pesticide products is that ads may not make false or misleading comparisons with other pesticides. Here’s a link to what Tougher Than Tom says about repellents, using an illustration that looks a bit like something made by Cutter. The ad states that a repellent (1) needs constant reaplication [sic], (2) requires messy set up, (3) nasty smell, and (4) limited coverage. I’d say only the final criticism is fair. The ad is repeated on the website, Facebook, Amazon, and elsewhere.

Trap claim

It’s notable that Tougher Than Tom refers to the Mosquito TNT as a trap and that 100% of the mosquitoes that enter die (“They can’t get out”). This should mean, therefore, that if traps at the end of the recommended usage period have zero mosquitoes inside, then no mosquito ever entered.

It’s also interesting that the company asserts that the Mosquito TNT was “designed to attract, trap, and eliminate mosquitoes,” which seems to be a false statement because the trap was designed to kill wasps, as shown here, here, here, and here. Furthermore, given that so many other companies use the exact same container, it seems unlikely that Tougher Than Tom’s statement, “designed by a family-owned business in Texas …” is true. Tougher Than Tom imports the wasp traps at approximately $1.10/each from Xiamen Consolidates Manufacture And Trade (Xiamen, China).

Ads feature actors playing customers

Because I do a lot of internet searches for mosquito information, I end up getting served a lot of ads and reels for Mosquito TNT. A lot of them are seemingly pitched as “I’m just a happy customer here to tell you about Mosquito TNT,” but I think some, if not all, of the people are actors. Tougher Than Tom sometimes hires these “spokespeople” via Backstage.com. For example, the person in this ad looks similar to the actor David Lilly (the tattoos match). As further proof that these testimonials are in fact ads, the exact same script is delivered by a woman in this ad.

Similarly, many of the video reviews on Facebook reels and Tiktok that are pitched as unbiased might actually be funded by Tougher Than Tom. An example of this can be found in this ad/review by @freelivingtennessse on Tiktok where she claims that the CO₂ produced by the tubes attracts mosquitoes from 1/4 mile away. In her bio she provides her email address “for UGC and affiliate inquiries,” which sounds like she’s for hire. She makes no disclosures about being paid in the video.

Safety claims

Many of the scripted ads mention “safe,” a word that may not be used to sell pesticides unless the word is followed by “when used as directed.” This might seem like a minor point but it’s an established EPA requirement that I suspect Tougher Than Tom is fully aware of. Indeed, the company seems to comply with this rule in text-based ads. I think the company views it unlikely that the EPA or FTC would be watching its ads.

Children in ads

You’re also not supposed to use kids to market pesticides, but Tougher Than Tom features them in the background of many ads (e.g., this one) and photographs (e.g., this one). One ad even has a kid holding the product. The header image on Facebook also has two kids.

Reviews

Tougher Than Tom has disabled the ability to leave or read reviews on its Facebook page. And on its website it seems to show just curated, highly-positive “testimonials.” I don’t think the EPA cares much about ads but the FTC has a requirement that curated reviews must be representative of actual efficacy. Because no negative reviews are shown I think an average person might easily be misled. The only place to read unfiltered, unsponsored reviews seems to be on Amazon and PissedConsumer.

Tougher Than Tom also deletes every negative comment, even questions, on its Facebook page. The people posting the comments are then blocked to prevent them from leaving further messages or from contacting customer service. Over time, this leaves only positive comments on the page and might lead a typical viewer to assume they are representative.

Here’s a review of the Mosquito TNT by a guy in Los Angeles, California. I highly recommend reading the comments, too. FYI, these black containers were a previous iteration of the device.

Where can Mosquito TNT be shipped?

Per Tougher Than Tom’s website, the Mosquito TNT “is not currently available in New Mexico and Tennessee,” but the Amazon listing says that product may not be shipped to Oklahoma, North Carolina, or Maine (same details at Walmart and eBay). It’s confusing that these two lists are different so I searched Purdue’s NPIRS as well as databases maintained by individual states. The outcome of these searches reveals that the Mosquito TNT can be shipped to AK, AZ, AR, CO, DE, FL, GA, HI, IA, NJ, NY, KS, KY, MI, MS, MT, NH, ND, PA, SD, TX, VT, WI, and D.C. That said, I have found in the past (for other pesticides) that the databases are not always up to date so this listing likely has some errors.

Alabama 🚫	Maine 🚫	Oklahoma 🚫
Alaska ✅	Maryland 🚫	Oregon 🚫
Arizona ✅	Massachusetts 🚫	Pennsylvania ✅
Arkansas ✅	Michigan ✅	Rhode Island 🚫
California ✅ ?	Minnesota 🚫	South Carolina 🚫
Colorado ✅	Mississippi ✅	South Dakota ✅
Connecticut 🚫	Missouri 🚫	Tennessee 🚫
Delaware ✅	Montana ✅	Texas ✅
Florida ✅	Nebraska 🚫	Vermont ✅
Georgia ✅	Nevada 🚫	Virginia 🚫
Hawaii ✅	New Hampshire ✅	Washington 🚫
Idaho 🚫	New Jersey ✅	West Virginia 🚫
Indiana 🚫	New Mexico 🚫	Wisconsin ✅
Iowa ✅	New York ✅	Wyoming 🚫
Kansas ✅	North Carolina 🚫	D.C. ✅
Kentucky ✅	North Dakota ✅	Puerto Rico ?
Louisiana 🚫	Ohio 🚫

NB: Per a presentation by Ana Rodriguez (DuPont, Inc.), GA, HI, NE, NJ, NY, TN, and TX don’t require registration of “minimum risk” pesticides, and Tougher Than Tom declares it has met all of these exemptions. That said, California tends to actually confirm exemption when a product is brought to its attention so I’ve added a “?” to the listing above for that state. Also, even though TN doesn’t require a registration I’m deferring to company’s declaration on its website and indicating above that sales are banned in that state. I’m still trying to figure out whether the device can be sold in Puerto Rico.