California Cleaning Product Right To Know: Are you ready for the second deadline?
By: Kirsten Alcock, Manager of Product Safety, email
On October 15, 2017, the California Cleaning Product Right to Know Act of 2017 (Senate Bill: SB258) was signed by Governor Jerry Brown. At this point in time, the first of the two deadlines have passed: Website disclosure was required on January 1, 2020. In looking at many websites of some very large companies recently, we are finding that many companies are not aware of this requirement for California. If you are selling to California, this is a requirement not only for your website but also label disclosure.
Label creation is a very time-consuming process and if you haven’t started yet, it may be too late. Your labels also have a requirement for disclosure under this new Right To Know Act.
This law required Manufacturers and Distributors of Consumer & Commercial air care (includes air fresheners, 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 nonfunctional 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.
- Weblinks to the designated lists for any ingredient disclosed.
- A link to the Safety Data Sheet for the Product.
The next deadline is coming up very soon. Are your labels ready? Do you understand the requirements for your Label Disclosure that is required on 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.
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 following 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 consumers 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 with both California and the Federal Consumer Product Safety Commission. We have the 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.
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.