Will CA Transparency Law Spur Safer Cleaning Products?
9/16/2019 | Doug Gatlin
Growing public demand for ingredient transparency across the marketplace is prompting regulators to require manufacturers and retailers to publicly communicate the ingredients in everything from personal care and baby products to cosmetics and cleaning products.
Starting this January, cleaning product manufacturers for the first time will have to post their product ingredients online to comply with a new ingredient disclosure law in California. As the nation’s leading environmental certification organization, Green Seal has always required manufacturers to fully disclose their product ingredients to us to qualify for certification.
We believe that public disclosure of product ingredients can empower purchasers to choose healthier, safer products. But we also know that reading a long and complicated list of ingredients without context can be confusing or even misleading, defeating the purpose of ingredient transparency.
Formula Facts Make Disclosure Easier
To help both purchasers and companies get the most out of the new ingredient transparency law, we recently launched Formula Facts, an ingredient label program that makes it easier for leading manufacturers to provide clear, accurate and meaningful ingredient communications.
But will disclosure finally prompt companies to weed out the stew of toxic chemicals that lurk in most cleaning products? Here is what we have learned about the benefits and challenges of ingredient transparency over decades of working with the nation’s leading cleaning product manufacturers.
1. Manufacturers don’t know all their product ingredients.
Ingredient disclosure is made harder by the fact that cleaning product manufacturers often don’t have access to information about some of their ingredients. That’s because they buy their raw materials from other suppliers who keep their formulas confidential. Manufacturers know what the raw material will do in the cleaning product (for example: it’s a solvent), but they may not know the specific identity of the active ingredient or whether there are any additives.
Think of it like making homemade cookies with bakery-bought chocolate chips. You know that the chips will taste delicious in your cookie, but you don’t know where the chocolate was sourced or whether any ingredients were added to keep them tasting fresh.
When Green Seal evaluates a cleaning product for certification, we work with the company’s raw material suppliers to track down every ingredient in that product. Because so many of the ingredients in a finished cleaning product are contained within the raw materials and hidden from view to the manufacturer, it will be essential for manufacturers to convince their suppliers to disclose their ingredients -- even when they involve confidential business information. This will only help promote safer product formulations.
2. Some chemicals are hard to detect.
In addition to ingredients that are intentionally added, cleaning products can contain byproducts and other impurities 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 in cleaning products.
The state laws require manufacturers to identify certain byproducts and other impurities that are associated with harmful health and environmental impacts. But this information can be hard for manufacturers to find because there is no requirement for raw materials suppliers to disclose the byproducts and impurities in their products. These chemicals also tend to be present at much lower concentrations that are harder to detect.Green Seal always screens for byproducts and impurities when we evaluate a cleaning product for certification to fully understand the product’s composition. Often, this process alerts manufacturers to the presence of chemicals they weren’t aware were in their products.Identifying these chemicals is the first step to weeding them out – another win for ingredient disclosure.
Communicating product ingredients can help companies increase credibility and build trust with their customers. However, even the clearest ingredient labels can be difficult to decipher for anyone but a toxicologist.
3. “Chemicals of Concern” are constantly changing.
The ingredient labeling laws require companies to clearly communicate whether their products contain any “chemicals of concern,” which include known carcinogens, reproductive toxins, and other ingredients harmful to human health. But this task isn’t as straightforward as it sounds. There are dozens of different lists of chemicals of concern, including 22 referenced by the California law. What’s more, the lists are constantly updated as new studies and information become available about the potential health impacts of the chemicals available in the marketplace.
In order to comply with the laws, manufacturers will have to track ongoing changes to each of these lists and update their ingredient labels accordingly. In this way, the disclosure laws will force companies to pay close attention to new findings about the health risks of common chemicals.
4. Ingredients have aliases.
The laws require cleaning product producers to list ingredients in descending order of weight, but even 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 an estimated 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.
Companies will have to follow the states’ regulatory guidelines for choosing the most appropriate names for their ingredients. However, variations in naming conventions are likely to continue to cause confusion and uncertainty for consumers, who can’t be certain whether the ingredients they are screening for are hidden under aliases.
5. Communication won’t do the job of certification.
Communicating product ingredients can help companies increase credibility and build trust with their customers. However, even the clearest ingredient labels can be difficult to decipher for anyone but a toxicologist. Long lists of chemicals can be overwhelming and anxiety-inducing even when the chemicals are harmless. Consumers can’t be expected to know whether chemical combinations are producing harmful byproducts or whether an ingredient that is considered a carcinogen in aerosol form is benign in liquid form.
When reviewing a product for certification, Green Seal always starts with ingredient disclosure – but that by itself does not translate to safer, greener products. Disclosure precedes a scientific analysis of the formula information, and then the essential work of filtering out products that don’t meet strict health, safety and performance benchmarks.
Reputable ecolabel 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 often encourage manufacturers to move toward safer product formulations – in effect taking their first step towards environmental certification. With ingredient labels that consumers can access and understand, transparency will continue to spur innovation and guide the economy towards a healthier, cleaner future.
Editors Note: This article was originally published in GreenBiz.