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Selling it

Ingredient disclosure, and the law that needs a website

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California's Cleaning Product Right to Know Act is the most unusual requirement in this estate: a state law that requires a maker to publish on the internet.

The only law here that requires a website

The Act requires a manufacturer of a designated product sold in the state to disclose ingredient information on the product website and on the product label.

The online requirement applied to products sold from January 1, 2020, and the on-label requirement from January 1, 2021.

Which means a maker with no website has a compliance problem that is solved by building one, and that is not a sentence that appears anywhere else in this estate.

What a designated product is

An air care product, an automotive product, a general cleaning product, or a polish or floor maintenance product, used primarily for janitorial, domestic or institutional purposes.

That definition covers almost everything a small cleaning-products maker would produce.

What has to be disclosed

Ingredient information as the Act specifies, with the online disclosure more complete than the label.

The label requirement has a practical accommodation built in: where a manufacturer cannot fit all the required information on the label, it must carry a statement directing the consumer to a web address or a toll-free number for the complete information, and electronic links such as a QR code are permitted.

Which is the mechanism most small products end up using, because a spray bottle label does not have room for a full ingredient disclosure alongside everything else it must carry.

Why it reaches everybody

It attaches to selling into California, not to being based there.

So an online seller anywhere in the country is inside it the moment a Californian buys a bottle, and most small makers discover that after they have started selling rather than before.

The practical position: comply nationally. Maintaining one compliant label and one compliant web page is far simpler than maintaining two product versions, and full ingredient disclosure is a commercial asset for a small maker anyway.

References

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.