What counts as a claim

The line is not always obvious, and it is drawn around what the product is represented as doing rather than around any particular vocabulary.

The words that cross the line

Disinfects. Sanitizes. Sterilizes. All three are defined performance categories with efficacy requirements behind them.

Kills germs, kills bacteria, kills viruses, and any percentage attached to them.

Antibacterial, antimicrobial, antiviral, germicidal.

Eliminates mold and mildew, as distinct from removing mold stains.

Protects against a named organism or illness.

Each of those represents the product as controlling microorganisms, which is the statutory definition.

The words that do not

Cleans. Degreases. Removes dirt, grease, soap scum, limescale.

Cuts through grime. Leaves a streak-free finish.

Removes mold stains, which is a cleaning claim about appearance rather than a claim about killing anything.

Deodorizes, carefully: removing odor is a cleaning claim, and claiming to eliminate odor-causing bacteria is not.

These describe soil removal, which is what a cleaning product does.

Where a claim can live

Not only the label. Intended use is established by how the product is represented, which reaches the product page, the category you list it under, the sell sheet, the market sign, the social post and the answer you give a customer who asks.

A correctly labeled cleaner listed under "disinfectants" is making the claim through the listing.

And testimonials you choose to display are claims you have adopted.

Implied claims

The subtle ones, and the ones people fall into honestly.

Imagery: germs being destroyed, a shield, a hospital setting.

Context: marketing a cleaner for use during an outbreak, or as protection for a vulnerable person.

Ingredient names used as a benefit, where the ingredient is known as a biocide.

Comparison to a registered disinfectant.

The test is what the buyer would reasonably understand the product to do, not what the words literally say.

References