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Intentionally added ingredients must be disclosed by July 2019


New York’s Department of Environmental Conservation has published its finalized cleaning product disclosure policy, which sets out information requirements for manufacturers. Manufacturers will be required to post specific information about their products and the ingredients they contain on their websites. Adoption of the policy, the Household Cleansing Product Information Disclosure Program, follows an announcement last year that the state would begin to mandate ingredient disclosure from the sector. It covers soaps and detergents that contain a surfactant as a “wetting or dirt emulsifying agent and used primarily for domestic or commercial cleaning purposes, including but not limited to the cleansing of fabrics, dishes, food utensils and household and commercial premises.”


New York State’s Department of Environmental Conservation Commissioner Basil Seggos said the policy will “help the state better understand what chemical hazards the public is exposed to, especially from products made in countries with less protective environmental laws than the U.S. and reduce exposure to chemicals of concern.” The manufacturer’s webpage must list intentionally added and nonfunctional ingredients in the product, by weight in a descending order.


The function of intentionally added ingredients must also be provided, such as stating if it acts as a surfactant, colorant, preservative or fragrance. Nonintentionally added ingredients should be reported as nonfunctional ingredients, byproducts or contaminants.


“Chemicals of concern” must also be identified by manufacturers. These include substances found on a number of “authoritative lists” set out in the policy.


These include those identified by the Environmental Protection Agency as chemicals of concern, PBTs, priority chemicals, or ozonedepleting substances; the EU Endocrine Disruptor list and the list of substances of very high concern (SVHCs); substances listed as reproductive toxicants or carcinogens under California’s Proposition 65; chemicals classified as a group 1, 2a or 2b by the International Agency for Research on Cancer (IARC); and those ingredients classified under the GHS as skin or eye irritants, respiratory or skin sensitizers, mutagens or aquatic toxicants. An ingredient in a product must be disclosed if it is present on one or more of the authoritative lists of chemicals of concern. This includes those being withheld as confidential business information (CBI).


Manufacturers are also required to list any nanoscale materials, as defined under the new TSCA. This includes any substance that is processed to form particles in the size range of 1-100 nanometers. They must also post on their websites any investigations or research they have carried out or commissioned on the effects the products or ingredients have on human health and the environment. Ingredient disclosure has been a focus for both state and federal legislators in recent years. Fragrance ingredients have also been a key industry issue, with the likes of Unilever, Procter & Gamble and SC Johnson all increasing disclosure efforts.




Ingredients intentionally added to these products that are present above trace quantities must be posted online by 1 July 2019. This does not apply to fragrance and nonfunctional ingredients – such as byproducts and contaminants – which must be disclosed by 1 July 2020. However, manufacturers with 100 employees or fewer have until the later July 2020 deadline to make available information on intentionally added ingredients.


Source: New York State Department of Environmental Conservation