CONSUMER SPECIALTY PRODUCTS ASSOCIATION

Sharing Information with Consumers about the Ingredients in our Products

Over the past 25 years, several states have enacted statutes requiring business to provide health, safety and environmental information to government and the public.  These measures, sometimes referred to as "right-to-know", include labeling, emergency response preparation, chemical or toxics use data, and other types of environmental, health and safety performance information.  More recently, proposals have been introduced in several states to mandate the disclosure of certain products’ ingredients by manufacturers on labels and/or Web sites. 

Member companies of the Consumer Specialty Products Association, working with other industry trade organizations, have developed a voluntary consumer product ingredient communications initiative for four consumer product categories—air care products, automotive care products, cleaning products, and polishes and floor maintenance products. This is an industry-led initiative that will help consumers make more informed choices about the products they use in and around their homes.

Participating companies list product ingredients on the product label; on the manufacturers’, distributors’, or importers’ website; via a toll-free telephone number; or through some other non-electronic means.

These products sold in the U.S. are regulated under the current system of risk evaluation and risk-based labeling through the Federal Hazardous Substances Act (FHSA) and administered by the U.S. Consumer Product Safety Commission. Through the FHSA regulations, the point of purchase label informs consumers about the potential hazards, product ingredients contributing to those hazards, appropriate handling and storage, applicable first aid information, and how to minimize risks to children.

Consumers recognize that the products made by our members provide numerous benefits, and there is a desire to have more information available to assist consumers with their purchasing decisions in these classes of products.

The U.S. Environmental Protection Agency’s Design for the Environment (DfE) program announced new criteria in September, 2012 for companies seeking the DfE logo for its products. The new criteria for DfE’s Standard for Safer Cleaning Products include elements of industry’s voluntary program as a way to provide greater transparency about ingredients in cleaning products. EPA's DfE program helps consumers, businesses, and institutional buyers identify cleaning and other products that perform well, are cost-effective, and are safer for the environment.

CSPA supports the adoption of federal legislation that would mirror industry’s voluntary program.  Further, CSPA supports the use of standardized sets of chemical names to identify ingredients, choosing among the International Nomenclature of Cosmetics Ingredients, International Union of Pure and Applied Chemistry, the Chemical Abstract Service name and number, a common chemical name or the CSPA Consumer Product Ingredients Dictionary.  Legitimate confidential business information must be protected under any disclosure legislation, including fragrance formula ingredients. Product manufacturers should have the option to identify only the presence of fragrances as such and to refer to the International Fragrance Association list or a subset of such list.

CSPA opposes right-to-know initiatives and legislation that will have the effect of creating state-specific labeling requirements as this would impose an undue burden or barrier to interstate commerce.

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