The Relationship Between California Ingredient Disclosure Requirements and Prop-65 Warnings; It’s Complicated.

Effective January 1, 2023, California’s Cleaning Product Right to Know Act (CPRTKA) requires intentionally added ingredients listed on Proposition 65 to be included in a designated product’s website and label disclosure. The Act allowed manufacturers to withhold from the label and website disclosure, such ingredients until January 1, 2023 (Note: website disclosure of nonfunctional constituents [...]

ARE YOU READY FOR IT? New VOC Limits Taking Effect in 2023

U.S. EPA and many states and territories have adopted more stringent limits for Volatile Organic Compounds (VOC) in consumer products.  While newer limits have already taken effect in some states (or for certain product categories), the effective date for others is quickly approaching. New VOC limits for specific product categories in California and New York [...]

SRC Summary of Changes in EPA Guidance for Products Adding Residual Efficacy Claims

On October 7th, EPA released its new Guidance for Products Adding Residual Efficacy Claims. After a thorough review including a comparative review of historical documents and all linked methods, and the Response to Comments document, Scientific & Regulatory Consultants, Inc. (SRC) has created the below summary of changes. Registrants are being given a 1-year implementation [...]

EPA Triggers Emerging Viral Pathogens Policy for Ebola Virus

Due to the ongoing Ebola outbreak in Uganda, the United States EPA has engaged its Emerging viral Pathogens Policy (EVP). The current outbreak of Ebola Virus Disease is caused by infection with Sudan ebolavirus. The first confirmed case was identified in a 25-year-old male in the Mubende District of Uganda on September 19th; though it [...]

California Consumer Product VOC Regulation Amendments Have Been Finalized

On August 1, 2022, proposed amendments to California’s Consumer Product Volatile Organic Compounds (VOC) Regulations were approved by the Office of Administrative Law and filed with the Secretary of State. These amendments are a result of the California Air Resources Board’s (CARB) efforts to reduce VOC emissions from consumer products, which CARB states are the [...]

CalEPA’s Office of Environmental Health Hazard Assessment (OEHHA) Proposes Rulemaking for Proposition 65 Short-Form Warnings

On January 8, 2021 OEHHA issued notice of proposed rulemaking to amend sections 25601, 25602, 25603, and 25607 of Article 6 of the Safe Drinking Water and Toxic Enforcement Act of 1986 in the California Health and Safety Code (Proposition 65 Clear and Reasonable Warnings). The proposed rulemaking would limit the use of and modify [...]

The Cleaning Product Right to Know Act of 2017

The Cleaning Product Right to Know Act of 2017 Online disclosure requirement is quickly approaching (January 1, 2020). Understanding SB-258 (Cleaning Product Right to Know Act of 2017) is vital for manufacturer compliance in the State of California. While no federal legislation exists for cleaning product disclosure to this degree of scrutiny, all companies manufacturing [...]