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Everything that has to be on the label

Updated

On this page6

Four lists. Which of them apply is decided by the formula and by what you say about it.

Work out which lists apply

Every product carries list one.

List two applies if the product contains a hazardous substance, which most effective cleaners do.

List three applies if it is sold into California, which for an online seller is effectively always.

List four replaces all of this if you have made a pesticidal claim.

Always

1 · Identity. What it is, on the principal display panel.

2 · Net quantity of contents, by volume, with metric alongside.

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

And not required but worth adding: a batch code, directions for use, and a storage instruction.

If it contains a hazardous substance

Cautionary labeling under the Federal Hazardous Substances Act:

4 · Signal word: DANGER, WARNING or CAUTION.

5 · Statement of the principal hazard.

6 · Precautionary measures.

7 · First aid instructions where appropriate.

8 · "Keep out of the reach of children."

And check separately whether the formula crosses a child-resistant packaging threshold, which is a closure requirement rather than a labeling one.

If it is sold into California

9 · Ingredient disclosure on the label, and fuller disclosure on the product website.

Where the label cannot carry it all, a statement directing the consumer to a web address or toll-free number, and a QR code or similar link is permitted.

If it is a pesticide

An EPA-approved label carrying the EPA registration number and establishment number, with the prescribed use directions, precautionary statements and storage and disposal instructions.

The label is part of the registration, and changing it is a regulatory act rather than a design decision.

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
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
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
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.