The American Cleaning Institute (ACI) submitted comments to the New York State Department of Environmental Conservation (DEC) regarding the implementation of a law limiting the amount of 1,4-dioxane that can be present in household cleansing, personal care, and cosmetic products sold or offered for sale in-state.
1,4-dioxane is a byproduct of the manufacturing process for some surfactants contained in cleaning products and detergents and is not an intentionally added ingredient. Companies continue to work diligently to adjust manufacturing processes to remove the trace amounts that have been found in these products.
In comments focused on concentrated cleaning products, ACI:
• Highlights that the same level of 1,4-dioxane will be present (contained in a recommended dose) because more product is needed for the same cleaning task.
• Highlights the potential shift for manufacturers to return to non-concentrated products, which includes the elimination of some product categories, such as liquid laundry packets and refill concentrate products.
• Draws attention to the possible consequences of increased plastic consumption, water consumption and CO2 emissions during manufacturing, packaging and distribution.
Underlines the challenges suppliers could face including installing expensive systems and the potential need to develop new technology, costs that will ultimately be passed onto consumers.
In the letter, ACI wrote:
“There are significant differences between concentrated and refill concentrate products, which are intended to be diluted on site by the customer, and ready-to-use products, which are ready to use and require no further dilution. Concentrated and refill concentrate products contain less water in the formula, yielding environmental benefits. Some concentrated and refill concentrate products are sold in solid form with no water in the formula, yielding even further environmental benefits. As a result, the concentrations of ingredients as well as by-products in the formula are higher versus ready-to-use products. However, the amount of ingredients/chemicals that is used during product application on a single dose basis is still similar to ready-to-use products. This means the amount of chemicals that goes down the drain and eventually enters the environment is also similar.
Setting a uniform limit for 1,4-dioxane across all product forms penalizes concentrated and refill concentrate products and may prompt manufacturers to dilute such products with water as the easiest way to comply. However, this approach does not meet the spirit and intent of the statute because there is no reduction in the overall amount of 1,4-dioxane entering the environment, since consumers will use higher volumes of the diluted products to achieve desired results.”
“ACI supports DEC’s efforts to elicit comments on the implementation of the 1,4-dioxane statute and we look forward to continued engagement with the agency,” Kathleen Stanton, ACI associate vice president, technical and international affairs, said in a statement.
You can read the association’s complete comments here.