You don't need a licenced product to kill wax moth larvae in stored frames - only if used in the hive (which you don't do)
I dont think holmbee is concerned if it needs approval to use it. But since it is no longer approved it is hard to obtain.
And regarding approval, if you want to get technical...
Pesticides can only be used for approved purposes. Unless it has been specifically approved for a given purpose and states so in the supporting literature, then technically it is not legal to use it in that way.
There are currently no products I know of that are approved for use on bee frames outside the hive.
To my understanding there is a complication regarding jurisdiction. I may or may not have been told the regulators cannot decide if it should be classed as a wood treatment, wax treatment, or bee/hive treatment. Basically there is not a nice place for it in their current classification and regulatory structure.
To my knowledge there are no established guidelines for a test system in practice to produce the data to present to the regulators. And if you did invent a protical and somehow get something approved, you may end up repeatedly retesting as the guidelines evolve over time in order to maintain your approval - very expensive.
It would also involve very long studies, ie, treating frames, overwintering, then exposing bees to the treated frames. Then the regulators may decide they want a residue accumulation study over 3 applications, then you are talking years.
So for any manufacture producing a wax-moth pesticide its just not worth the expense and delays it would cause. Especially when you consider the quantities bee keepers will use compared to other farmers.
So in short "You
do need a licensed product to kill wax moth larvae in stored frames"
However that being said, I dont know of a single case of a bee keeper being put in prion for misappropriate use of pesticides!
And sorry for the rant, it is not my intention to belittle you. My work is related to this kind of stuff, so unlike bee keeping is a topic I actually have some knowledge on.