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Selling it

What your state adds

Updated

On this page5

More state activity in this category than in most, and almost all of it attaches to selling into the state rather than to being based there.

Three kinds of state rule

Ingredient disclosure, which is the big one.

Restricted or reportable substances, which reach the formula.

Pesticide registration at state level, if you have gone down that road, which is a separate registration in most states with its own fee and annual renewal.

Ingredient disclosure

California's Cleaning Product Right to Know Act is the one with its own page here: online disclosure from January 1, 2020 and on-label from January 1, 2021, for designated products sold in the state.

Other states have moved in the same direction with their own schemes, and the practical answer is the same as it is for California: comply once, nationally, rather than maintaining product versions.

Restricted substances

Phosphate restrictions in several states, which have shaped the whole category's builder chemistry.

California's Proposition 65, which requires warning for exposure to listed chemicals and attaches to selling into the state. Fragrance components and some solvents are where this most often arises, and the supplier is the right place to ask.

VOC limits on consumer products in California and in states following its rules, which reach solvent content directly and can make a formula unsellable there.

That last one surprises people: a glass cleaner compliant federally can exceed a state VOC limit.

The ordinary business items

Business registration, sales tax, a local license.

Fire code where you store solvents or oxidizers in quantity, which is local and reaches the workspace.

And waste disposal rules, which are local and which matter more here than in any other property in this estate.

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
US Federal Trade Commission. Green Guides, 16 CFR Part 260, on environmental marketing claims including "non-toxic", "natural", "biodegradable" and unqualified general environmental benefit claims. ftc.gov
US Environmental Protection Agency. Pesticide Registration Manual, Chapter 4: Additional Considerations for Antimicrobial Products. What an antimicrobial pesticide is, and what registration requires. epa.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.