California Cleaning Product Right to Know Act Deadlines

 In Cleaning Products, Consumer Products, Regulatory Affairs

By: Kirsten Alcock, Manager of Product Safety, email

On October 15, 2017 the California Cleaning Product Right to Know Act of 2017 was signed by Governor Jerry Brown. The first of the two deadlines has passed: Website disclosure was required on January 1, 2020.

This law required Manufacturers and Distributors of Consumer & Commercial air care (including air fresheners and reed diffusers), automotive cleaning/maintenance, general cleaning, polish and floor maintenance products to provide a specific list of the chemicals used in their products on their website.  There are no exemptions for small labels or small businesses.

The information to be disclosed on your website as of January 1, 2020 included:

  • A list of all non-functional constituents present ≥ 0.01 percent (100 ppm).
  • 1, 4 dioxane if it is present at ≥ 0.001 percent (10 ppm).
  • CAS number for each listed ingredient.
  • The functional purpose served by each intentionally added ingredient.
  • Web links to the designated lists for any ingredient disclosed.
  • A link to the Safety Data Sheet for the Product.

The next deadline is looming. Are you ready for it? Label Disclosure is required January 1, 2021.

The required changes for the product label include,

  • Disclosure of intentionally added ingredients.
  • Disclosure of any ingredient present on any one of the 23 different Designated Lists and present at ≥ 0.01%.
  • Disclosure of Fragrance allergens present at ≥ 0.01%.
  • A toll free number to the manufacturer.
  • A website address for the manufacturer.

When was the last time your formula was reviewed to determine the ingredients within your product?  Do you need help to determine if you are on any of these designated lists?

Dell Tech Laboratories has created an Excel®-based search tool that will allow you to quickly and easily search all your CAS numbers against all of the Designated Lists. Create your product’s label and website disclosure in minutes instead of hours. For more information on how to use our tool, please see the Ingredient Disclosure Solution Tool video produced by Joe McCarthy.

If you’re not interested in the tool but would still like our help to identify the components as you only sell a handful of products, we can also help you.  As part of our Enhanced CPSC classification service, we not only classify your product properly for US consumer, but provide you a document that contains your mandated label information for California.  This is a process that can take hours to research without the proper tools set in place.

Contact us today to ensure that your labels are compliant for both California and the Federal Consumer Product Safety Commission. We have in-house expertise to help you become compliant and keep you that way. Do not take the risk of being caught with non-compliant labels.

Dell Tech
Kirsten Alcock, B.Sc. (Hons) 
Manager, Product Safety Group

Dell Tech has provided professional, confidential consulting services to the chemical specialty industry in Canada, the USA, Europe, and Asia for the last 40 years.

Contact us today for more information.

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