Buy a full case and the price per unit drops automaticallyRequest a sample
AccountCart0
All ContainersBottlesJarsCaps & ClosuresPumps & SprayersTubs & PailsJugsDroppersTinsTubesAccessories
Industries
Learn
Selling it

What you may legally call it

Updated

On this page5

Naming in this category is unusually constrained, because the most natural words are the regulated ones.

Three things a name can do

Say what it is for, which is free.

Say what it removes, which is free and is better copy.

Say what it kills, which is a pesticidal claim and needs a registration.

Naming the product

The identity on the label should say plainly what the product is: all-purpose cleaner, glass cleaner, bathroom cleaner, floor cleaner.

A brand name sits alongside that, not instead of it. "Meadowfresh" is a name; somewhere on the panel it has to say what the product is.

And a name that describes the room or the job is doing the job a shelf shopper needs, which is the commercial argument for the same thing.

Naming the performance

Safe territory: heavy duty, powerful, concentrated, streak-free, no-rinse, low-foam, unscented.

Those describe how the product behaves and none of them says anything about microorganisms.

"Deep clean", "professional strength" and similar are marketing language rather than defined terms, and they are unobjectionable as long as they do not imply a performance category you have not earned.

Where a name becomes a claim

A product called Sanitizing Spray is making a pesticidal claim in its name. So is Antibacterial Wipes, Germ Guard, Disinfecting Cleaner.

The name is part of the labeling, and a compliant body panel does not rescue a non-compliant name.

The same applies to a range name. A line called "Protect" invites the reading, and so does anything implying protection from illness.

And it applies to environmental names too: a name implying an environmental benefit is a claim the Green Guides reach, which is the other regime that looks at names.

References

US Environmental Protection Agency. Determining If a Cleaning Product Is a Pesticide Under FIFRA. A cleaner that claims to clean and degrease is not a pesticide; the same product claiming to kill germs is. The claim triggers it, not the chemistry. epa.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
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
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.