Complying with the new ingredient disclosure law in California
Growing public demand for ingredient transparency across the marketplace is prompting regulators to require manufacturers to disclose the toxic ingredients in their cleaning products. Starting this January, cleaning product manufacturers will have to post their product ingredients online to comply with a new ingredient disclosure law in California.
Green Seal believes that public disclosure of product ingredients can empower building management and maintenance professionals to choose healthier, safer products.
As the nation’s leading environmental certification organization, Green Seal has always required manufacturers to fully disclose their product ingredients in order to qualify for certification. Green Seal believes that public disclosure of product ingredients can empower building management and maintenance professionals to choose healthier, safer products. Yet it is also clear that reading a long and complicated list of ingredients without context can be confusing and sometimes misleading, which defeats the purpose of ingredient transparency.
To help both purchasers and companies get the most out of the new ingredient transparency laws, Green Seal has launched Formula Facts, an ingredient label that will make it easier for companies to provide clear, accurate and meaningful ingredient communications. This is what industry professionals should know about the ingredients in cleaning products and the benefits of ingredient transparency:
- Manufacturers don’t always know all of their product ingredients
Cleaning product manufacturers often don’t have access to information about some of their own ingredients because they buy their raw materials from other suppliers who keep their formulas confidential. Manufacturers know whether the raw material acts as a solvent or a stabilizer, but they may not know the specific identity of the active ingredient or whether any other chemicals have been added. Think of it like making homemade cookies with bakery-bought chocolate chips: you know the chips will taste great, but you may not know where the chocolate was sourced or whether the manufacturer used any preservatives.
- Some chemicals are good at hiding
Cleaning products often contain impurities, including byproducts that are unintentionally created during a chemical reaction. One example is 1,4-dioxane, a carcinogen found as a reaction by-product in ethoxylated substances, which are often used as surfactants.
State laws require manufacturers to identify certain byproducts and other impurities, but manufacturers often don’t know this information.
State laws require manufacturers to identify certain byproducts and other impurities, but manufacturers often don’t know this information. Raw materials suppliers aren’t required to disclose all of the byproducts and impurities in their products, and these chemicals also tend to be present at much lower concentrations that are harder to detect. However, Green Seal always screens for byproducts and impurities when evaluating a cleaning product for certification.
- “Chemicals of Concern” lists keep growing
The ingredient labeling laws require companies to clearly communicate whether their products contain any “chemicals of concern,” which include carcinogens, reproductive toxins, and other ingredients harmful to human health. This task is, in fact, more complicated than it sounds. There are dozens of different lists of chemicals of concern that are constantly updated as new studies and information become available about the potential health impacts of the chemicals available on the marketplace. Green Seal routinely tracks these lists and prohibits the use of such chemicals in certified products.
- Ingredients have aliases
The law requires cleaning product producers to list ingredients in descending order of weight. However, something as simple as communicating an ingredient’s name can be complicated. There are more than 2,000 chemicals used in conventional cleaning products—but more than 10,000 names for those chemicals. For example, the carcinogenic byproduct 1,4-dioxane goes by a number of aliases, including Diethylene Oxide, Diethylene Dioxide, Dioxane, para-Dioxane, 1,4-Dioxacyclohexane, and Diethylene Ether, to name just a few. Green Seal’s Formula Facts labels use the Household Cleaning Products Association (HCPA) naming conventions for product ingredients to provide concise, consistent and recognizable ingredient names.
- Communication won’t do the job of certification
Consumers have a right to information that helps them choose safer products. However, even the clearest ingredient labels can be difficult to decipher for anyone but a toxicologist. Consumers can’t be expected to know whether chemical combinations are producing harmful byproducts, or whether an ingredient that is considered a carcinogen is only a concern when it’s inhaled.
Green Seal standards stay far ahead of public awareness about the health risks of toxic chemicals.
An independent certification from a respected ecolabel is a clear signal that the product is among the safest and healthiest on the market. Green Seal standards stay far ahead of public awareness about the health risks of toxic chemicals. For example, commonly found toxins like methylene chloride and 1,4-dioxane—which have only recently spurred widespread public concern—have been prohibited in Green Seal-certified products for decades.
While ingredient communication itself is not sufficient to transform the market, these requirements do often encourage manufacturers to move toward safer product formulations—in effect taking their first step towards Green Seal certification. With ingredient labels that purchasers can access and understand, transparency will continue to spur innovation and guide the economy towards a healthier, cleaner future.
By Mary Swanson, Vice President of Certification, Green Seal