Does my cleaner need FHSA warning labels?

It needs them if the finished product is a "hazardous substance" under the Federal Hazardous Substances Act, and that takes two things at once: the product has at least one listed property (toxic, corrosive, irritant, strong sensitizer, flammable or combustible, or pressure-generating), and it may cause substantial injury or illness during customary or reasonably foreseeable handling, including a child swallowing it [1][2]. You make the classification yourself, from ingredient data, published information or tests, and nobody approves it in advance. This page gives the definitions with their numbers, the flash point bands, and a way to work through your own formula.

Two questions, and both must be yes

First: does the product have a listed hazard? The categories are set in 16 CFR 1500.3 and summarized by CPSC [1][2]. They are listed in the next section with their thresholds.

Second: can it cause substantial injury or illness in customary or reasonably foreseeable handling or use? The regulation counts more than the buyer using the product as directed. Foreseeable handling "includes the reasonably foreseeable accidental handling or use, not only by the purchaser or intended user," and extends to "all others in a household, especially children" [2]. A spray bottle under a kitchen sink will be reached by a toddler, and the classification has to assume it.

If both answers are yes, the label needs the FHSA cautionary statements set out on what a cleaning product label must say. If the product has no listed hazard, the FHSA does not require warnings, though the identity, net quantity and business name are still required on every package.

One exclusion matters here. Pesticides are outside the FHSA definition [1], so an EPA-registered disinfectant is labeled under FIFRA instead. A cleaner that makes no germ or pest claim stays outside FIFRA, which is why the FHSA governs its label.

The hazard categories and their numbers

A product that is highly toxic carries DANGER and POISON; corrosive and extremely flammable products carry DANGER; every other hazardous substance carries WARNING or CAUTION [2].

Flash point bands

The FHSA classifies liquids by flash point, the lowest temperature at which the liquid gives off enough vapor to ignite [1][2]:

Applied to a raw material: 91 percent isopropyl alcohol has a closed-cup flash point of 14 to 18°C (57 to 64°F) on its maker's safety data sheet [3], so neat rubbing alcohol is "flammable" under these bands. That classifies the raw material only. A glass cleaner with a small share of alcohol in water has its own, higher flash point, and the finished product is what you classify. Measure it, or have a lab measure it, rather than estimating from the ingredient list. CPSC lists the FHSA flash point test method among its regulations (16 CFR 1500.43a) [1]. The solvent figures for other common cleaner solvents are on solvents.

Shipping uses different flash point lines. The Postal Service, for example, treats a liquid with a flash point of not more than 140°F as flammable [4]. A product can be "combustible" on its FHSA label and "flammable" for the mail; see shipping cleaners.

Who decides, and on what evidence

You do. The FHSA works by self-classification: CPSC's guidance sets out definitions and label elements and describes no step in which the agency reviews a product or a label before it is sold [1]. The Commission's own decisions come in at the edges, for example designating strong sensitizers (16 CFR 1500.13) [1].

The evidence can come from several places, and the regulation ranks them:

1. Human experience. Where human data show a different result from animal tests, "the human data shall take precedence" [2]. A substance can be classed as highly toxic or toxic on human experience alone [2].
2. Published data on the ingredients. Your suppliers' safety data sheets give oral LD50 values, skin and eye classifications and flash points. These tell you which ingredients bring a hazard and at what concentration.
3. Tests on the finished product. The irritation and flash point methods are in 16 CFR 1500.41, 1500.42 and 1500.43a [1][2].

Animal testing is not required. CPSC says neither the FHSA nor its regulations require it to decide whether a hazard exists, that animal tests are one option, and that it favors methods that replace, reduce or refine animal use (16 CFR 1500.232) [1]. The regulation also says the Commission aims "to emphasize in vitro testing methods" [2].

A caution about safety data sheets: they classify under OSHA's version of the Globally Harmonized System (GHS), which is a different scheme from the FHSA. CPSC notes that other agencies' hazard data may not match FHSA classifications [1]. A GHS "Category 2" eye irritant on a raw material's SDS is a strong signal to look at irritancy, and you still apply the FHSA definitions to your finished product at its real concentration.

Working through your own formula

1. List every ingredient with its percentage in the finished product, from your batch sheet, not the recipe card.
2. Pull the hazard data for each from its SDS: sections 2 (hazard classification), 9 (flash point, pH) and 11 (toxicology, including oral LD50).
3. Mark each ingredient that brings a listed hazard and note its concentration. Water brings none; acids, alkalis, bleach, ammonia and solvents commonly carry skin or eye classifications on their sheets, and so do many surfactant concentrates.
4. Check the twelve POISON substances in 16 CFR 1500.129 against your concentrations [5]. Acetic acid at 20 percent or more, ammonia at 5 percent or more, sodium or potassium hydroxide at 10 percent or more, and hypochlorous acid yielding 10 percent or more available chlorine all require POISON in place of a signal word [5].
5. Get the finished product's flash point if it contains alcohol, glycol ethers, citrus terpenes or any other solvent.
6. Decide irritancy and corrosivity of the finished product. pH alone does not decide it; the pH page explains why. A dilute product may fall below the level at which an ingredient irritates, or may not. If you cannot support "not an irritant" with data on the finished product or a close published analogue, label for the hazard.
7. Apply the foreseeable-use test, including a child swallowing a mouthful or spraying it into an eye [2].
8. Write down the classification and its basis, and keep it with the formula. Repeat whenever the formula, a supplier or a concentration changes.

Two worked readings from published sheets show the range. Clorox Regular Bleach2, 5 to 10 percent sodium hypochlorite, is classified by its maker under GHS as skin corrosion Category 1B and serious eye damage Category 1, signal word Danger, "Causes severe skin burns and eye damage" [6]; that bottle is an EPA-registered pesticide [6], so it is labeled under FIFRA. A cleaner of your own that contains household bleach and makes no germ claim is an FHSA product, and its classification starts from that data at the diluted strength. Neat 91 percent isopropyl alcohol is flammable by the bands above [3]; a product made mostly of it would be too.

Signs that a product will need warnings

• It contains bleach, ammonia, a mineral acid, or any hydroxide.
• Its raw materials' SDSs carry Danger, or skin or eye classifications, at concentrations near yours.
• It contains a solvent and you have not measured the finished flash point.
• It is sold as a concentrate. The concentrate as sold is what you classify, whatever the diluted spray would be (concentrates).
• It is a powder or tablet that can be inhaled or swallowed whole.

If any applies, plan the label for a hazard and check child-resistant packaging next: the thresholds in 16 CFR 1700.14 are a separate test, set out on child-resistant closures.

From classification to label

Once you know the hazards, the signal word, hazard statement and the rest of the label follow. The elements, placement and type sizes are on what a cleaning product label must say. This is a summary of 16 CFR 1500.3 and CPSC guidance as read in October 2026; CPSC's Office of Compliance can answer questions about a specific product.

References

1. U.S. Consumer Product Safety Commission, FHSA Requirements, business guidance, undated, read October 22, 2026. https://cpsc.gov/Business--Manufacturing/Business-Education/Business-Guidance/FHSA-Requirements
2. Code of Federal Regulations, 16 CFR 1500.3, Definitions, via Cornell Legal Information Institute, read October 22, 2026. https://www.law.cornell.edu/cfr/text/16/1500.3
3. Alliance Chemical, Safety Data Sheet: Isopropyl Alcohol 91%, revised October 21, 2026. https://docs.alliancechemical.com/sds/isopropyl-alcohol-91
4. U.S. Postal Service, Publication 52, Hazardous, Restricted, and Perishable Mail, section 343, Flammable and Combustible Liquids (Hazard Class 3), read October 22, 2026. https://pe.usps.com/text/pub52/pub52c3_022.htm
5. Code of Federal Regulations, 16 CFR 1500.129, Substances named in the Federal Caustic Poison Act, via Cornell Legal Information Institute, read October 22, 2026. https://www.law.cornell.edu/cfr/text/16/1500.129
6. The Clorox Company, Safety Data Sheet: Clorox Regular Bleach2, revision 3, December 9, 2020. https://www.thecloroxcompany.com/wp-content/uploads/2020/12/US001153-Clorox-Regular-Bleach2_3.pdf