Frequently Asked Questions About Ingredient Disclosure
Q: What is the state of ingredient disclosure today in the U.S.?
A: Under the FD&C Act, companies are required to list ingredients on consumer cosmetic, personal care and food products in descending order of amount, with the caveat that flavor and fragrances can be declared under the summary description “flavor” or “fragrance”, and incidental ingredients at insignificant levels do not need to be declared. Cleaning products are not governed by the FD&C Act, hence those ingredient declaration requirements don’t apply to them.
Q: What is the state of fragrance ingredient disclosure today in Europe?
A: While fragrance ingredients in cleaning or personal care products are not required to be disclosed, the EU does require that certain fragrance components known to be allergenic are disclosed on cleaning product labels if they exceed a certain level (100 ppm for rinse-off products and 10 ppm for leave-on products).
Q: Don’t many companies voluntarily disclose their ingredients already? Why make it mandatory, and why push for on pack disclosure?
A: Some companies have made the decision to disclose all of their ingredients right on the product labels. In recent years, even large companies have started to disclose their products’ ingredients online, demonstrating that ingredient disclosure is feasible for cleaning product companies of all sizes. However, in many cases, companies will disclose all ingredients except specific fragrance components and state that the product could contain any one of roughly 3000 fragrance ingredients. And having the information on a website does not provide the information where consumers need it, on the package they are holding in a store.
Despite the progress we have seen in the marketplace, many cleaning product labels still do not give consumers sufficient ingredient information to make more informed decisions about which products contain chemicals of concern to them, and which have ingredients they can live with.
Q: What are the obstacles to putting ingredients on labels?
A: It can be somewhat more expensive, and manufacturers tend to prefer to use the limited space on the label for marketing. What companies should consider is that ingredient information is marketing.
Q: Why should consumers care what’s in their cleaning products?
A: Exposure to cleaning products can cause or exacerbate certain health conditions. Fumes from some cleaning products can induce asthma in otherwise healthy individuals and exacerbate asthma in people who already have the disease.
The California Department of Public Health (CDPH) “has found that nearly 10% of all work-related asthma cases are caused by exposure to cleaning products.”[i] CDPH is concerned that the use of some cleaning products in schools may contribute to asthma in students and workers.[ii]
About 8 percent of adults and children in California have asthma, with almost 200,000 new cases diagnosed each year.[iii] Asthma is much more prevalent in lower income communities.[iv]
Some ingredients found in cleaners are linked to cancer, reproductive and developmental toxicity, allergies and irritation, burns and poisonings.[v]
Children born to women who held cleaning jobs while pregnant have an elevated risk of birth defects, according to a 2010 study by the New York State Department of Health.[vi]
Q: Who is at most risk from these adverse effects? The general consumer, kids, or professionals like janitors?
A: Workers, children, and minorities are most at risk. Workers like janitors, maids, and housekeepers are most vulnerable to these products, being exposed for long hours every day.
About 6 percent of janitors experience a job-related injury from chemical exposure to cleaning products every year.[vii]
About half of the nation’s janitors, maids and housekeepers are Latino or African American.[viii]
Children born to women who held cleaning jobs while pregnant have an elevated risk of birth defects, according to a 2010 study by the New York State Department of Health.[ix]
The California Department of Public Health “has found that nearly 10% of all work-related asthma cases are caused by exposure to cleaning products.”[x]
According to the U.S. EPA, cleaning products contribute to concentrations of many common pollutants that are 2 to 5 times higher inside homes than outside.[xi]
Biomonitoring studies show that many toxicants invade our bodies—they have been found in blood, urine and breast milk, as well as in the umbilical cord blood of newborns. [xii],[xiii], [xiv]
Q: Why should consumers be concerned about fragrance?
A: The term “fragrance” refers to a mixture that may be composed of any of over 3,000 chemicals, including allergens and reproductive toxins. The Institute of Medicine equated fragrance to second-hand smoke in its potential to trigger asthma. According to the California Department of Public Health, fragrances in cleaning products are actually a combination of many chemicals, some of which contain ingredients that have been associated with dizziness, cancer, endocrine disruption, and asthma.
It’s really a crime of omission that many of the chemicals of concern found in consumer products are hiding in fragrance. Chemicals that can disrupt the endocrine system may be used in a fragrance, but consumers would never know because they’re not required to be listed in the ingredients.
Further, “unscented” does not necessarily mean a product is made without fragrance chemicals. This term can be misleading to consumers, particularly to those with an allergy related to fragrance. Natural fragrances can also cause sensitivities.
Q: Why force manufacturers to disclose substances that occur naturally for unintended ingredients, like arsenic from tap water?
A: The EPA sets strict limits on toxic substances in drinking water so such substances are not of concern in manufactured products made with tap or other purified water. We are currently working out language for this bill that would help manufacturers avoid having to list naturally occurring toxics in their products at the inconsequential levels found in drinking water. Additionally, most cleaning products advertise the use of distilled water for their products, which would remove most chemicals of concern from the water.
Q: Does ingredient disclosure violate protection of trade secrets?
A: No. Federal and state laws already require ingredient disclosure for food products, over-the-counter drugs, and cosmetics, without disastrous impacts to those industries. A few companies already disclose all of their ingredients, including fragrance components.
Manufacturers are allowed to protect trade secrets by not labeling the amount or concentration of ingredients or the manufacturing process, and ingredients that make up less than 1% of the product by weight may be listed in any order. AB 708 does not require disclosure of the amount of each ingredient in the product.
Q: Don’t ingredients take up valuable space on product labels that would cost companies?
A: Cleaning product labels tend to be larger than those of food products, over-the-counter drugs, and cosmetics, all of which are required to label ingredients. It is unreasonable to expect cleaning products to be disadvantaged if cosmetic, personal care, and food products are not.
Q: Why put ingredient information on a label? Will consumers really know what to do with it?
A: Consumers at the store can’t make informed purchasing decisions without accurate ingredient information on labels. A 2015 survey of 1,000 U.S. moms found that 73% of those surveyed, “often do research to understand the safety of ingredients to which their family is exposed.” Kids and workers with acute skin rashes and allergic reactions, or pregnant women counseled to avoid certain chemicals by their doctors, will be able to avoid cleaning products with ingredients they have reactions to. Union negotiations rely on ingredient information in order to negotiate for safer cleaning products in the workplace.
It comes down to consumer education and awareness. Think of food labels. While it was once a foreign concept to look at the ingredient labels of your food, it’s now commonplace and consumers are knowledgeable about certain ingredients they may choose to avoid.