Option 1: Label Review

Single Label & Online Disclosure Content

 

If you can provide the complete formula, we can search the ingredient(s) against the 23 Designated Lists under the California CPRTKA and can provide you:

  • The 2 options for label content disclosure.
  • The online disclosure requirements including:
    • Acceptable chemical nomenclature.
    • Function of the ingredient(s).
    • Which designated list the ingredient(s) are listed on, if any.
    • Direct links to the relevant designated list(s).

 

 

OPTION 2: Custom Search Tool

INGREDIENT DISCLOSURE SEARCH TOOL WITH LABEL & ONLINE DISCLOSURE GENERATOR

 

The designated lists cited in the Act are in different formats, often embedded within a larger regulation, difficult to find and navigate. It probably takes an hour or more for each ingredient to search all 23 California designated lists. With this tool, all the lists can be searched at that same time with a copy & paste of a CAS#.

Dell Tech Laboratories has a created an Excel based California Ingredient Disclosure Search Tool with label and online content generator.

If you can provide a consolidated list of all the CAS# in your products, we can provide a custom search tool for your formulary. We do not need to know which product(s) the ingredient is in or how much is in the product. The tool includes:

  • Universal results: all your CAS# against all the lists, with CAS#, acceptable nomenclature, and ingredient function.
  • A searchable table into which you can enter a formula based on your CAS# list which will generate the label and online disclosure for that formula.

Under the California Cleaning Product Right To Know Act (SB258), the deadline for online ingredient disclosure was January 1, 2020. The deadline for on-label disclosure is January 1, 2021.

New York has announced public consultations starting February 2020 to revive the New York State Department of Environmental Conservation (NY DEC) Household Cleansing Product Information Disclosure Program.

The California Cleaning Product Right To Know Act (CPRTKA) applies to household, institutional, commercial, concentrates and ready-to-use (RTU), air care, automotive care, cleaning, polish and floor maintenance products.

 

The Act requires on-label disclosure in one of two formats:

  1. Disclose each intentionally added ingredient that is on any one of 23 designated lists & each fragrance allergen present at or above 0.01% (100 ppm).
  2. Disclose all intentionally added ingredients and the statement “contains fragrance allergen(s)” of fragrance allergens present at or above 0.01% (100 ppm).

 

The Act requires on-line disclosure including:

  • All intentionally added ingredients.
  • All fragrance components and fragrance allergens when present at or above 0.01% (100 ppm).
  • Any of 34 non-functional constituents listed in the Act when present at or above 0.01% (100 ppm).
  • CAS# for each ingredient.
  • Function of each ingredient.
  • Links to the designated list any ingredients appears on.

Ingredient Disclosure Search Tool Demonstartion Video

Joe McCarthy

Manager, Laboratory Services Group Senior Regulatory Affairs Specialist

Call: 519-858-5024
Email: jmccarthy@delltech.com

Limitations:

The tool only works with CAS#. It does not search by text or class of compounds. So categories such as “nickel compounds”, “mercury compounds” or similar categories that are listed on Prop 65, California Toxic Air Contaminants, and/or California Non-Cancer Hazards cannot be found with this tool.

The tool defaults that all Prop 65 listed non-functional constituents will trigger a product warning pursuant to Prop 65.