EPA Label Program Questioned by ACI

The American Cleaning Institute (ACI) is concerned with the approach taken by the EPA to develop the Safer Product Labeling Program and associated Standard. In contrast to tenets from organizations such as the American National Standards Institute (ANSI) and the International Organization for Standardization (ISO), EPA has disregarded a number of guidelines related to the process of developing standards, measuring their environmental effectiveness, and managing the standards programs, noted ACI.

As for measuring environmental effectiveness, the Standard does follow some of the principles of green chemistry but falls short in several areas such as measurability and significant measurable difference, identification of “hotspots,” and consideration of lifecycle stages, according to ACI.

Furthermore, in several sections, the term “fragrance” is used without definition, including the use of “fragrance-free” as a label option. ACI recommends defining the term “fragrance” with the input of industry experts or replace the term in the Standard with “fragrance material.”

According to ACI, the Standard wrongly prohibits dual functionality ingredients. Many materials with aromatic properties including solvents and surfactants are formulated into products for their cleaning functions. As these ingredients are evaluated against their functional class criteria and not the Safer Choice Interim Fragrances Criteria, their exclusion from a “fragrance-free” product is inappropriate. ACI recommends this criterion be deleted from the Standard.