What are the Label Requirements for Cleaning Products?
Anything that works well removing grease and lifting dirt probably isn’t the best for the human body. Because of this, label requirements for cleaning products are especially strict, falling under the jurisdiction of international, federal, and sometimes state laws. You need to make sure your cleaning product labels are compliant – but aren’t sure where to start. Don’t worry, we’re here to help you make sure your cleaning supplies have all the needed safety information.
What Qualifies as a Cleaning Product?
Cleaning products include anything primarily used for cleaning, whether they’re used in a home, commercial, or industrial environment. This includes air care products, disinfectants, detergents, restoring products, floor cleaners, and floor polishes. Like any product category, there are some edge cases and exceptions.
Drugs and cosmetics are not cleaning products. Most disinfectants can also be pesticides, so they’re categorized based on their consumer product marketing. It’s an insecticide if that’s the only use claimed on packaging and marketing materials. It’s a cleaning product if you advertise any other use.
Automotive detail products are cleaning products, unless they repair paint. This includes clay bars, leather conditioners, and plastic restorers.
FHSA Compliance for Household Cleaning Labels
Labeling requirements for household cleaning products fall under the Federal Hazardous Substances Act (FHSA.) This includes anything stored in a home or household structure, including garages, sheds, and carports.
Even if your products are only sold to professionals, there’s a good chance they’ll be used in these buildings. This makes FHSA labeling regulation compliance a given for any cleaning product used outside industrial settings. These products must include instructions for safe storage and use, as well as first aid procedures, in case there is an accident.
Products under this category include any chemical product that is toxic, corrosive, flammable, or combustible. It also includes products that are irritants, powerful sensitizers or generate pressure under any circumstance, including decomposition and heating. Warnings and instructions are required if the product may cause severe personal injury or illness due to “foreseeable handling.” Here are a few examples:
– The product accidentally gets on the user’s skin, in their eyes or in their mouth
– A child eats the product
– An aerosol can is placed next to something hot, like an engine or heater
– Pool chemicals decompose when heated by the sun, increasing pressure inside the container
– Long-term exposure leads to cancer, birth defects, neurotoxicity, or other health problems
Specifics on tests and labeling are covered by federal regulation 16 CFR 1500. To comply with FHSA regulations, cleaning product labels must include the following information:
– The name and contact information of the product manufacturer, packer, distributor, or seller
– The common chemical name of each hazardous ingredient
– Signal words
– “Danger” for corrosive and extremely flammable chemicals
– “Danger” and “Poison” for chemicals with high-toxicity
– “Caution” or “Warning” for all other hazards
– Affirmative hazard statements, as outlined by federal codes, including words and phrases like “Flammable”, “Harmful if Swallowed” and “Vapor Harmful”
– Precautionary statements telling users how they can protect themselves from hazards
– Instructions for first aid treatment
– Special handling instructions, as required
– The statement “Keep out of reach of children”
Complying with the OSHA Hazard Communication Standards for Workplace Chemicals
Cleaning products used professionally or in workplaces must include a Global Harmonized System (GHS) compliant label. Here’s a quick rundown of what is required for these cleaning product labels:
– The name, address and telephone number of the manufacturer, importer or distributor
– Product identifiers, including chemical names, code names and batch numbers, as needed
– A signal word, either “Danger” or “Warning,” depending on the severity
– A hazard statement
– A precautionary statement that outlines proper use of the product to avoid injury
– GHS hazard pictograms
To simplify labeling, OSHA allows the use of a Hazardous Materials Identification Safety (HMIS) label. This HMIS label design has space for everything required for GHS. A blank version can be added to containers filled by the end user, allowing them to write in information that brings the container into compliance.
GHS labels must meet the BS 5609 standard for durability. This requires materials and application methods that can withstand exposure to salt water, UV light and sand, in case the container is lost at sea. When you’re looking for a way to get these labels on your products, don’t forget we make machines to cover a range of containers, including industrial pails.
Additional Information Required for California’s Product Right to Know Act of 2017
After a gradual phase-in of CA SB 258, all cleaning products sold in California after the start of 2023 must meet additional labeling requirements outlined in this bill.
The product label must disclose each intentionally added ingredient that is included on 23 designated chemical lists. These lists include American, Canadian, and European Union chemical guidelines, as well as carcinogens covered by California’s Proposition 65.
Fragrance allergens greater than 100 ppm also need to be listed on the label. Manufacturers have the option of listing any other intentionally added ingredients unless they’re considered confidential business information. Ingredients must be listed in descending order by weight unless they make up less than 1% of the product. These minute quantity ingredients can go in any order at the end of the list. Compliant labels also need to list a toll-free phone number and website address for the product.
All products that qualify nationally as cleaning products must follow these guidelines, with one exception: disinfectants. The information about disinfectants is only required for the product website. For all other products, this information must be included on cleaning product labels and product websites. This law doesn’t apply to trial-size containers.
No Matter What You’re Labeling, We Can Help
Meeting legal requirements for cleaning product labels can be a hassle, but getting those labels on those products doesn’t have to be. Whether you need a new labeling system, or you want to upgrade your old equipment, contact CTM Labeling Systems. We have local distributors that will help you to create labeling stations that keep up with your production system while delivering the accuracy and reliability you need for your products. We make equipment for all shapes and sizes of containers, from small vials and beverage cans to industrial pails and shipping boxes.
