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Label Management
Published:
July 30, 2024
Updated:
August 5, 2024

Environmental Compliance: All the Regulations Around Green Cleaning Home Products [+ free checklist]

Mitha Shameer

Environmental Compliance: All the Regulations Around Green Cleaning Home Products [+ free checklist]

Published:
July 30, 2024
Updated:
August 5, 2024
Mitha Shameer

Highlights

Green cleaning home products aren't just about keeping our homes sparkling clean—they're about protecting our health and the planet too. With more people becoming eco-conscious, the labels on your products can make all the difference in attracting savvy shoppers.

But achieving a green cleaning stamp involves more than just good intentions. In fact, you need to follow the right compliance rules and labeling regulations if you wish to claim your product as eco-friendly. Here, we break down the nitty-gritty in an easy-to-understand way!

What is green cleaning?

Green cleaning is all about using natural ingredients like baking soda, vinegar, and lemons, or creating commercial products that are gentle on the environment. Key characteristics of green products include:

  • No phosphates or chlorine
  • No artificial fragrances or colors
  • Biodegradable or recyclable packaging
  • Organically grown ingredients from sustainable farming

To make sure your product stands out as green, focus on your labels. The EPA’s Design for the Environment (DfE) program certifies products that meet their chemical safety standards, allowing you to display the DfE label proudly. Also, look for opportunities to label your products as “low VOC” or “no VOC,” indicating minimal or no volatile organic compounds.

Third-party certifications are key to building trust and meeting standards. Aim for certifications like Green Seal, Safer Choice, and EcoLogo. Another good practice is achieving a rating of 8.1 or higher on Goodguide.

By following these friendly tips, you can create packaging and labels that clearly showcase your dedication to green cleaning, making it easier for consumers to choose environmentally friendly products.

The EPA: Your green cleaning guru

When it comes to green cleaning home products, the Environmental Protection Agency (EPA) should be your go-to reference. Think of the EPA as the gatekeeper of eco-friendly products. They require you to list any active disinfectants or potentially harmful ingredients. Basically, they make sure that what you’re selling is safe for both your buyers and the environment.

But how do buyers know that your product meets the high standards for safety, quality, and environmental friendliness? Safer Choice Program!

What is the Safer Choice Program?

The EPA’s Safer Choice Program encourages the use of green chemistry in cleaning products and other consumer items. It signifies that every component in the product is carefully evaluated for its impact on human health and the environment. 

Performance-wise, these green products must match or exceed the effectiveness of conventional alternatives, meaning consumers won't have to sacrifice cleaning power for safety.

To earn the coveted Safer Choice label, your product must pass rigorous standards for safer chemical ingredients and have its formulas verified by an EPA-approved third party. 

Now, as a green cleaning product manufacturer, there are a couple of things you need to keep in mind.

Ingredient disclosure for review: 

You are required to disclose all ingredients, including any fragrances and dyes, ensuring complete transparency. This information must be accessible either on the product label, product catalog, or a dedicated website.

Packaging requirements: 

Additionally, environmentally friendly packaging, like recyclable materials, is encouraged to reduce waste.

pH levels: 

Products labeled under Safer Choice must meet pH standards that reduce the risk of skin and eye irritation or injury.

Volatile Organic Compounds (VOCs): 

Safer Choice limits VOCs to lower indoor air pollution and related respiratory issues.

Ongoing compliance: 

Certification isn’t a one-time deal; you must regularly submit your products for review to maintain their Safer Choice status, ensuring ongoing environmental compliance and safety. 

Ingredient updates: 

Any ingredient changes also require a new application. Mislabeling is taken seriously and can lead to criminal prosecution for fraud.

Note: Chemical manufacturers are not legally required to list all ingredients on their containers or make them public. However, transparency is essential for informed consumer choices. Since April 2011, the EPA’s Safer Choice program mandates that all ingredients, including fragrances, must be listed for products bearing the Safer Choice label, either on the packaging or via an easily accessible website.

Now that you’re familiar with the Safer Choice Program, let’s move on to the other regulations surrounding green cleaning products that fall under the EPA.

Toxic Substances Control Act (TSCA)

The Toxic Substances Control Act (TSCA) is a U.S. federal law enacted in 1976. It gives the EPA the authority to regulate the production, importation, use, and disposal of chemicals. 

The TSCA is designed to ensure that chemicals used in commerce do not pose an unreasonable risk to human health or the environment. 

Below, we have listed some key provisions of the TSCA.

  • It requires you to provide the EPA with information on the chemicals you produce, which are then listed on the TSCA Inventory.
  • As manufacturers, you must submit a Pre-Manufacture Notice (PMN) to the EPA at least 90 days before producing or importing a new chemical substance or before manufacturing an existing chemical for a new use.
  • Furthermore, Significant New Use Rules (SNURs) require manufacturers to follow specific guidelines if you plan to use existing chemicals in new ways. 
  • It requires manufacturers, importers, and processors to maintain records and report information about the production and use of chemicals.

Note: The EPA evaluates the risks of new and existing chemicals and can impose restrictions or bans if a chemical is found to pose an unreasonable risk. These rules help the EPA track and manage the environmental and health impacts of chemical substances effectively.

Should a green cleaning product manufacturer worry about TSCA?

As a green cleaning product manufacturer, you should be concerned about TSCA compliance for several reasons:

Chemical ingredients: Even if a product is marketed as "green" or "environmentally friendly," it may still contain chemical substances regulated under TSCA. You need to ensure that all ingredients are listed on the TSCA Inventory and comply with TSCA regulations.

New chemical substances: If as a manufacturer, you introduce a new chemical ingredient that is not listed on the TSCA Inventory, you must submit a PMN and obtain EPA approval before commercial production.

Safety and risk assessments: Green cleaning products often rely on novel or less common chemicals. These substances must undergo EPA risk assessments to determine if they pose any risk to human health or the environment.

Recordkeeping and reporting: Green cleaning product manufacturers are subject to the same reporting and recordkeeping requirements as other chemical manufacturers. As a result, you must maintain accurate records and report any significant new uses or changes in production volume.

Compliance and enforcement: Non-compliance with TSCA can result in significant penalties, including fines and legal action. Ensuring that all chemical ingredients comply with TSCA helps avoid these risks.

By adhering to TSCA requirements, green cleaning product manufacturers can ensure that their products are safe, legally compliant, and environmentally responsible.

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)

FIFRA is a U.S. law that controls the registration, distribution, sale, and use of pesticides. Managed by the Environmental Protection Agency (EPA), this law requires that all pesticides used in the U.S. be registered with the EPA to make sure they meet safety standards that protect people and the environment.

Why green cleaning product manufacturers should be concerned about FIFRA

While not all green cleaning products fall under FIFRA, those that do make pesticidal or antimicrobial claims must adhere to its regulations. You should carefully evaluate your product claims and ingredients to determine if FIFRA compliance is necessary.

Pesticidal claims:

  • If a green cleaning product claims to kill, repel, or control pests (including bacteria, viruses, or fungi), it must comply with FIFRA regulations.
  • This includes products labeled as disinfectants, sanitizers, or any other term suggesting pest control.

Registration requirements:

  • Products that fall under FIFRA must be registered with the EPA before they can be sold or distributed.
  • The registration process includes submitting data on the product’s safety, efficacy, and environmental impact.

Labeling requirements:

  • FIFRA requires specific labeling standards to ensure that consumers are informed about the product's proper use and potential hazards.
  • This includes instructions for safe usage, precautionary statements, and active ingredient disclosure.

Exemptions:

  • Some green cleaning products may be exempt from FIFRA if they meet certain criteria, such as those defined under the Minimum Risk Exemption (40 CFR 152.25(f)). These products must use specific active and inert ingredients that are considered safe.

Labeling requirements for all registered pesticide products

Here's what must be clearly and prominently displayed on labels for all registered pesticide products:

  • Product name, brand, or trademark
  • Producer or registrant's name and address
  • Net contents (amount of product)
  • Registration number of the product
  • Establishment number of the producer
  • List of ingredients
  • Warning or precautionary statements
  • Directions for use
  • Classification of use

Voluntary cleaning label certifications

With limited government regulations on cleaning products, third-party organizations have stepped in to create certification standards that enhance ingredient transparency and highlight the impact on human and environmental health. These certifications cater to consumers' growing interest in eco-friendly cleaning products. 

Here are some popular certifications:

  • Organic: The USDA organic certification applies to cleaning products as well as food. To earn this label, products must meet stringent organic purity standards and cannot contain chlorine bleach, ammonia, or other synthetic chemicals.
  • Green Seal: This certification evaluates product performance and sustainability. To display the Green Seal, products must meet strict criteria, including low toxicity, limited VOCs, no carcinogens, and a reduced carbon footprint.
  • Safer Choice: Sponsored by the EPA, this program promotes transparency and safety. To use the Safer Choice logo, companies must meet toxicity standards for human and environmental health, fully disclose ingredients, and undergo manufacturing facility inspections.
  • EcoLogo: Managed by Underwriters Laboratories, EcoLogo certification requirements are similar to those of Green Seal, focusing on sustainability and low environmental impact.
  • Cruelty-Free: This certification indicates that a company vows not to test the product on animals. While there is no government-sanctioned cruelty-free label, the Leaping Bunny logo is a trusted third-party certification. 
  • Natural: Although the term "natural" is not highly regulated for cleaning products, the USDA offers a "Certified Biobased" seal. This seal indicates the percentage of biobased content, determined by the USDA and American Society for Testing and Materials. 

CARB and green cleaning products

The California Air Resources Board (CARB) is a state agency that regulates volatile organic compounds (VOCs) in consumer products, including cleaning products. VOCs are chemicals that can easily evaporate into the air and contribute to the formation of ground-level ozone and smog. 

CARB plays a significant role in implementing and enforcing regulations aimed at improving air quality in California. 

Key CARB regulations for green cleaning products

VOC limits: Green cleaning products sold in California must comply with CARB’s stringent limits on VOCs for various categories of consumer products, including general-purpose cleaners, glass cleaners, and air fresheners. This may involve using alternative ingredients or reformulating existing products to reduce VOC content.

Product labeling: Products must be labeled to accurately reflect their VOC content and to comply with CARB’s regulations. This means that manufacturers must ensure that the VOC levels stated on the label are within the allowable limits for that product category.

Regulatory compliance and reporting: Ongoing compliance with CARB regulations is necessary to avoid penalties. This includes regular testing, certification, and possibly adjusting formulations to meet updated standards. Additionally, companies must submit annual reports detailing their sales and the VOC content of their products, ensuring transparency and environmental compliance.

Innovative Products Exemption: If a product significantly reduces VOC emissions, manufacturers can apply for the Innovative Products Exemption, which can offer some regulatory relief while promoting environmental innovation.

Green claims and marketing: While CARB does not specifically regulate green claims, products marketed as environmentally friendly must still comply with all applicable VOC regulations. Manufacturers making such claims should also ensure they comply with FTC guidelines to avoid misleading consumers.

FDA's influence on green cleaning products

The FDA (Food and Drug Administration) primarily regulates food, drugs, cosmetics, and medical devices in the United States. When it comes to green cleaning home products, which fall under the category of household cleaning agents or detergents, the FDA's involvement is limited or indirect. 

Some green cleaning products may include ingredients that are also used in cosmetics (e.g., fragrances, surfactants). For these ingredients, the FDA regulates their safety and labeling requirements under the Federal Food, Drug, and Cosmetic Act (FD&C Act).

While the FDA does not directly regulate household cleaning products, including green cleaning products, its guidelines and regulations on ingredients and labeling can influence industry standards and consumer expectations.

What to include in your green cleaning label?

Label compliance for green cleaning products typically fall under EPA, CARB, and OSHA regulations. Manufacturers of green cleaning products need to include several key elements on their labels to meet these regulatory requirements. 

Here are the essential elements:

Product name description, and brand: They are the first things your customers will notice. Clearly state the cleaning product's name, its intended use, and display your brand logo prominently.

Ingredients: Transparency is key. List all ingredients in order of quantity, starting with the highest percentage.

Usage instructions: Explain how to use the product effectively. Include tips like mixing instructions, optimal surface contact time, and testing on small areas first.

Net quantity: Show the net quantity or volume of the cleaning product. 

Safety information: Include any necessary safety warnings, even if the product is generally considered safe. This might cover precautions for use, first aid instructions, and storage guidelines.

Certification logos: Display any third-party certification logos, such as Green Seal, EcoLogo, or EPA’s Safer Choice. These certifications indicate that the product has been independently verified as environmentally friendly and safe for use.

First aid: Provide first aid steps for accidental ingestion, eye contact, or persistent irritation. Include advice to call Poison Control if necessary.

Storage: Indicate storage instructions, such as keeping out of children’s reach, avoiding direct sunlight, or maintaining specific temperatures. Mention any risks related to puncturing the container.

Environmental claims: Clearly state any environmental benefits, such as “biodegradable,” “phosphate-free,” or “low VOC.” These claims should be backed by evidence and certification where applicable.

Disposal: Inform customers about proper disposal methods, including whether the container can be recycled or if special steps are needed. Warn against refilling spray bottles if it poses a risk.

Contact Information: Provide the manufacturer and distributor details, including an address and phone number for customer inquiries. Suggest visiting your website for additional information, such as coupons or cleaning tips.

Batch number and expiration date: Adding these details is key for quality control and traceability. This helps ensure that consumers are using safe products within their recommended shelf life.

Barcode or QR code: Adding a barcode or QR code to the label makes purchasing easier. It lets retailers and consumers quickly find more info about the product, like reviews, promotions, or sustainability efforts.

Do green cleaning products have to list all ingredients on their labels?

The Federal Hazardous Substances Act (FHSA) requires that any consumer product containing hazardous substances, including green cleaning products, must have appropriate warning labels. These labels must inform consumers of potential hazards, such as toxicity, flammability, or corrosiveness, regardless of whether the product is marketed as "green" or environmentally friendly.

However, while the FHSA mandates warning labels for hazardous ingredients, it doesn't require the full disclosure of all ingredients, including proprietary or trade secret formulations. So, green cleaning products, like all other cleaning products, must comply with FHSA regulations if they contain any hazardous substances but aren't obligated to list every ingredient unless other regulations or certification standards require it.

To address the demand for greater transparency, initiatives like the EPA’s Safer Choice Program encourage manufacturers to disclose more information about their ingredients. This program certifies products that meet stringent safety and environmental criteria. Products with the Safer Choice label have been evaluated for their environmental and health impacts, promoting greater consumer trust and transparency.

When can you add a fragrance-free label to your products?

The EPA has introduced a fragrance-free label option to help shoppers easily identify products without added fragrances, backed by trusted verification. This certification works alongside the Safer Choice label. If a product qualifies for the Safer Choice label and contains no fragrance materials, it can add a "fragrance-free" note to its label.

To earn the fragrance-free label, a product must first meet all Safer Choice Standard requirements and use safer ingredients. The EPA carefully reviews product ingredients to confirm the absence of fragrance materials.

Being fragrance-free means two things: Firstly, the product only contains ingredients listed on or eligible for the Safer Chemical Ingredients List (SCIL), which meets safer chemical criteria. Secondly, it does not include chemicals listed on the International Fragrances Association (IFRA) Transparency List, typically used to add or mask scents.

Chemicals that serve a dual purpose—like those used both as a solvent and a fragrance—may not qualify for fragrance-free certification. The EPA evaluates such cases individually in collaboration with manufacturers to determine eligibility.

This approach ensures clarity for consumers seeking fragrance-free options while promoting safer and transparent product choices.

Why bother with label compliance? 

Staying compliant isn’t just about avoiding fines or legal trouble; it’s about ensuring that green cleaning products genuinely live up to their promises. Environmental compliance ensures that your products are safe for both consumers and the environment, maintaining consumer trust and promoting a healthier planet. 

For manufacturers, adhering to these regulations can open up new market opportunities, as more and more consumers seek out products that align with their values. Plus, a certified product often enjoys a competitive edge in the market, appealing to the growing number of eco-conscious consumers.

Design 100% compliant green cleaning labels

To ensure your green cleaning products meet regulatory requirements and stand out on the market, staying compliant with labeling regulations is crucial. Imagine you're about to launch a new fragrance-free cleaning spray under your brand. You've carefully formulated it to meet the EPA's Safer Choice standards, and now you're excited to highlight its purity with a fragrance-free label.

Here’s where ComplyAI from Artwork Flow comes in handy. Using ComplyAI, you can upload your label design and set up rules to check ingredients. It helps you quickly identify if any fragrance-containing ingredients are listed on the label. If there are, ComplyAI alerts you so you can promptly make corrections, ensuring compliance and reducing the risk of mislabeling.

The ComplyAI feature helps with regulatory compliance, ensuring you effortlessly tick off all the regulatory boxes and giving you peace of mind as you launch into the market.

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