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What federal law requires on the label

Updated

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A cleaning product label carries more mandatory content than anything else in this estate, and it comes from three places at once.

Two federal layers, plus one state

Consumer commodity labeling: identity, net quantity, and who is responsible.

Cautionary labeling under the Federal Hazardous Substances Act, if the product contains a hazardous substance, which most effective cleaners do.

And California's ingredient disclosure, which has its own page because it also requires a website.

A fourth applies only if you have crossed into pesticide territory, in which case the EPA-approved label replaces this conversation entirely.

The consumer commodity items

Identity. What it is, on the principal display panel. "All-purpose cleaner", "glass cleaner".

Net quantity of contents, by volume for a liquid, with metric alongside.

Name and place of business of the manufacturer, packer or distributor.

Cautionary labeling under the FHSA

Where the product contains a hazardous substance, 16 CFR Part 1500 requires a defined set of elements:

A signal word, DANGER, WARNING or CAUTION, according to the degree of hazard.

A statement of the principal hazard.

Precautionary measures, telling the user what to do and not do.

First aid instructions where appropriate.

Keep out of the reach of children.

And the name and address of the responsible firm.

This is the layer small makers most often miss, because a home-made cleaner does not feel like a hazardous substance. Whether it is one depends on the formula, not on the scale.

What forces a reprint

A reformulation that changes the hazard classification or the ingredient list.

A new size, which changes the net quantity statement.

Crossing a child-resistant packaging threshold, which changes the closure and frequently the artwork.

Beginning to sell into California, which adds the ingredient disclosure.

And an address change, which is the ordinary one that catches everybody.

References

Federal Hazardous Substances Act and 16 CFR Part 1500, which require cautionary labeling on household products containing hazardous substances: the signal word, the hazard, precautionary measures, first aid and the instruction to keep out of reach of children. ecfr.gov
Poison Prevention Packaging Act, 16 CFR 1700.14, Substances requiring special packaging. Thresholds relevant to household cleaners include sodium and/or potassium hydroxide at 2 percent or more in liquid (10 percent dry), methyl alcohol at 4 percent, sulfuric acid at 10 percent, turpentine at 10 percent, and nonemulsion liquid furniture polish with 10 percent or more petroleum distillates below 100 SUS. ecfr.gov
California Cleaning Product Right to Know Act of 2017 (SB 258). Designated products — air care, automotive, general cleaning, and polish or floor maintenance products — must disclose ingredient information on the product website from January 1, 2020 and on the label from January 1, 2021. leginfo.ca.gov
Written from the federal regulation and agency guidance named on each page, not from a laboratory or a legal practice. Whether a particular product and a particular label make a cleaner or a pesticide is a determination about your product, and this is not that determination.