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New York Household Cleansing Product Information Disclosure Program

By: Paula Stanley, Manager Environmental Health & Safety, email

Introduction

New York State has finalised its Information Disclosure program for Household cleansing products. Manufacturers and some suppliers will be required to post a list of all chemicals in their products on their websites starting July 1, 2019.

There is an initial registration as well as a two-year renewal requirement. When a new substance is added to any of the documented lists noted in the regulation, formulations will have to be checked and website information will be required to be updated.  Any changes are required to be updated within six-months. This will be very challenging for all involved

Applicability

The regulations cover soaps and detergents used in commercial or consumer cleaning applications and “includes but is not limited to” cleaning fabric, dishes, utensils and household and commercial properties. The listed manufacturer of ‘bottled for’ entity must post these on each of their websites.

This regulation sets some very prescriptive requirements with registrations, renewals and references to substances of concern.

What must be posted?

Manufacturers are required to list all ingredients on their webpage or via a one click link for all cleaning products in descending order (they are not required to list the volume by weight). This includes by-products and contaminants.

Along with this; chemicals of concern are to be identified if they are in any of the 29 lists noted in the legislation, the main ones are listed below:

  • US EPA Chemicals of concern
  • EU Endocrine Disruptor list
  • EU list of substances of Very High Concern (SVHCS)
  • Reproductive toxic chemicals and or carcinogens if they are listed in California Prop 65
  • Chemicals designated as 1, 2a, or 2b in the international agency for Research on Cancer
  • Any chemicals listed that fall into the categories of skin or eye irritant respiratory or skin sensitizers and mutagens and aquatic toxins under the GHA regulations

Trade Secret Allowance

There are confidential business exemptions for trade secret information and a generic name can be used in its place, the manufacturer must provide written documentation if asked to prove justification.

Will you be ready?

Deadline Description
by July 1, 2019 Manufacturers must post all required information for the following ingredients:

  • Intentionally added ingredients other than fragrance ingredients; and
  • Non-functional ingredients present above trace quantities.

manufacturers who are independently owned and operated and employ 100 or less persons are not required to post such information until July 1, 2020:

by July 1, 2020 Manufacturers must post all required information for the following ingredients:

  • Fragrance ingredients;
  • Non-functional by-products listed in Appendix D present at or above 100 ppm, except for 1,4 dioxane, which should be reported at or above 350 ppt, and PFOA and PFOS, which should be reported at a combined level of at or above 70 ppt;
  • Non-functional contaminants listed in Appendix D present at or above 100 ppm, except for 1,4 dioxane, which should be reported at or above 350 ppt, and PFOA and PFOS, which should be reported at a combined level of at or above 70 ppt
by January 1, 2023 Manufacturers must post all required information for the following ingredients:

  • Non-functional by-products which appear on one or more of the lists of chemicals of concern named in Appendix B and are present at or above the practical quantitation limit; and 21
  • Non-functional contaminants which appear on one or more of the lists of chemicals of concern named in Appendix B and are present at or above the thresholds described in Section V.A.3 of this Policy, “Confidential Business Information and Extent of Disclosure,” above.

 Dell Tech can help you to get these registrations in place and support your compliance through this process – email or call us at 519-858-5021 today!


Dell Tech has provided professional, confidential consulting services to the chemical specialty industry in Canada, USA, Europe and Asia for the last 35 years. Contact us today for more information.

www.delltech.com

 

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