In just the last few years, the cleaning product industry has experienced a major boom in demand. Propelled by the increased need for cleaning supplies due to the Covid-19 pandemic, cleaning product manufacturers have been generating significantly more profit than in previous years.
Similar to the larger chemical manufacturing industry, the cleaning product industry faces strict federal regulations and distributor guidelines regarding what codes and labels must be included on product packaging. These requirements range from basic use instructions and allergy warnings to traceable variable data such as lot codes, serial numbers, barcodes, and more.
To those new to the industry, the labeling requirements for cleaning products may appear intimidating at first, especially when trying to figure out which agency governs your specific product that is being manufactured. Fortunately, once you understand the basic regulations and familiarize yourself with today’s industrial marking options, code compliance becomes within reach.
Here’s what you need to know.
Essential Labeling Requirements for Cleaning Products
When developing cleaning product labels, it’s important to be aware of the different regulations and labeling guidelines that apply to your specific goods. These regulations and labeling requirements vary depending on the intended use and ingredients in the product. Cleaning label requirements are largely shaped and enforced by the following entities:
- The Occupational Safety and Health Administration (OSHA)
- Environmental Protection Agency (EPA)
- State laws
- Distribution partners
If the product also meets the criteria to be considered a pesticide (e.g., it claims to remove allergens, kill pests, sanitize/sterilize surfaces, etc.), additional labeling requirements from the EPA will come into effect. See this article on the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) for more information.
In this article we are going to focus on the OSHA’s cleaning product labeling requirements as laid out in the Administration’s Hazard Communication Standard (HCS). According to this standard, all cleaning product labels must contain the following information:
- Contact Information of the Chemical Manufacturer/Importer/Responsible Party: This information must include a name, address, and phone number.
- Product Identifier: This information communicates the identity of the product to the consumer. The manufacturer/packager can identify the product by either its chemical name, code number, or batch number.
- Signal Word: This word communicates how severe of a hazard the product poses to the user. Only two words are used as signal words: “Warning” and “Danger.” “Warning” communicates that the chemical is potentially harmful to the user, while “Danger” communicates that the chemical poses an immediate hazard.
- Hazard Statements: These statements describe in detail the different hazards that the product poses to the user (e.g., “Contains Butoxypropanol which contains material that may cause adverse reproductive effects and may adversely affect the developing fetus based on animal data”, etc.).
- Precautionary Statements: These statements recommend measures that minimize or altogether prevent the hazardous issues associated with the product. Precautionary statements come in four categories:
- Prevention statements (i.e., recommendations to minimize exposure)
- Response statements (i.e., directions on how to respond to accidental spillage or exposure)
- Storage statements (i.e., storage best practices to guarantee user safety and a long product lifespan)
- Disposal statements (i.e., directions on how to dispose of the chemical to avoid damaging the environment and harming others)
- Pictograms: Pictograms are eye-catching icons that communicate the danger posed by the product. They are not mutually exclusive and come in nine categories.
In addition to these required label elements, OSHA includes guidance in the HCS regarding optional supplemental information such as expiration dates and fill dates.
While elements like expiration dates and fill dates are not required by OSHA, they are frequently required by state-level laws and distribution networks. For example, California’s Cleaning Product Right to Know Act of 2017 contains a number of label measures, including ingredient lists and manufacturing dates. Similarly, most distribution channels require variable data markings such as lot codes, fill/expiration dates, and serial numbers to appear on labels for traceability purposes.
While the label elements required in the HCS can easily be included in stock label designs, variable data marking by nature must be applied on a batch-by-batch basis. This requires the use of specialty marking equipment.