While this plan is a step in the right direction, the industry plan falls short in a number of areas.

Over 40 organizations have signed onto a letter to leading cleaning product makers and the CSPA and SDA requesting greater ingredient disclosure.  Read the letter (.pdf)

Problem:
The plan doesn’t go into effect until January 1, 2010.

Solution:
Companies should make a good-faith effort to get consumers this information as soon as possible.  They can start by disclosing the ingredients on a website by July 1, 2009.  This allows them six months. Right now, companies that are selling products in the European Union are already required to disclose their ingredients on a website, so this is not an extra burden.

Problem:
The plan doesn't disclose all of the potentially harmful ingredients found in a product. Companies can list “preservatives”, “dyes”, and “fragrance” as such.

Listing “preservatives,” “dyes,” and “fragrances” as such does not disclose the chemicals make up the fragrance, dye, or preservative.  

For example, parabens are widely used as preservatives in cleaning products. Parabens have been associated with several health risks, including hormone disruption and breast cancer.  Phthalates are a common carrier for fragrances in cleaning products.  Phthalates have been linked to reproductive problems in men and asthma in children.

Solution:
Companies should disclose all ingredients used in their products, including the constituents of dyes, preservatives, and fragrances.

They should help consumers understand the purpose for the chemicals by revealing its functional name along with the scientific name.

In addition, companies should provide hazard warnings for any chemicals that are known or suspected carcinogens, reproductive toxins, or allergens.

Problem:
The plan only encourages companies to disclose intentionally-added ingredients. There are chemicals that can be created either by the mixture of ingredients, or during the manufacturing process of a product.  While these chemicals are not "intentionally added ingredients" they are detectable in the final product and consumers will be exposed to them.

Solution:
These chemicals  should be disclosed to the consumer so that they can be avoided. The manufacturer has a responsibility not only for disclosing the ingredients used, but also for disclosing the ingredients that are present in the final product used by the customer.

Problem:
The proposal gives companies the choice to disclose the ingredients on the company’s website, OR on the product label, OR through the company’s toll-free number, OR by other non-electronic means.  Consumers should have a consistent method of identifying the chemicals in the products they buy. Allowing companies to choose their method of identification does not allow consumers to easily and effectively compare products.  In addition, it creates confusion for the consumer.

Solution:
Companies should list the ingredients in their products on the product label to give consumers choices at the point of purchase AND on the company website to ensure that all consumers can access the information they desire.

Problem:
The proposal allows ingredients to be identified by any of the following naming systems: International Nomenclature of Cosmetic Ingredients (INCI) name, and/or International Union of Pure and Applied Chemistry (IUPAC) name, and/or Chemical Abstract Service (CAS) name, and/or Common chemical name.

Consumers need consistent names to make smart choices easily—when different companies use different chemical names, it puts up a barrier for consumers. Putting the ingredients on the label allows consumers to identify chemicals of concern before purchasing a product. Likewise, having the information on a website allows consumers to search for more information about the chemicals contained in that product.  In addition, companies should make the information available in both English and Spanish.

Solution:
Companies should aim for international consistency by following existing EU regulations (EU Detergent Directive).  Companies should always list ingredients by the INCI name or IUPAC name.  As a last result, if no other name is available, companies may list the common chemical name.  Companies should follow the chemical name with the functional name in parentheses to help consumer understand why a chemical is present in that product.  On the website, the company should list the CAS number as well.  This is a unique number and will ensure there is no confusion about what the chemical is.  With the CAS number, consumers can search for information about the chemicals.

Problem:
The proposal is only voluntary.  Companies don’t have to follow it, and there is no penalty if they don’t or encouragement to do so. Companies have the option to participate or not in the program.  This means consumers will not receive the information they need on all of their products.

Solution:
The CSPA should work to implement a mandatory labeling program through federal legislation.

Read about the program on the CSPA website
Download a fact sheet (.pdf) about the plan

Learn more about how WVE is working with companies to ensure safer products

Return to Safe Cleaning Products Initiative