California Cleaning Product Right to Know Act: Disclosure and Labeling

The California Cleaning Product Right to Know Act of 2017 (SB 258) requires manufacturers of cleaning and related household products sold in California to disclose the chemical ingredients in those products, both on the physical label and, in fuller detail, on the manufacturer’s website. The law reaches beyond dish soap and spray cleaners to air care products, automotive cleaners, and floor polishes, and it covers not only ingredients added on purpose but also a defined set of contaminants and byproducts.

Products the Law Covers

The act applies to “designated products”: air care products, automotive products, general cleaning products, and polishes or floor maintenance products used for janitorial, domestic, or institutional cleaning.1California Legislative Information. California Health and Safety Code Division 104 Part 3 Chapter 13

Several categories fall outside the act:

  • Foods, drugs, and cosmetics, so personal care items like toothpaste, shampoo, and hand soap are not covered even though they contain chemicals.
  • Products manufactured exclusively for industrial settings such as oil and gas production, steel production, heavy manufacturing, industrial water treatment, and food and beverage processing.
  • Trial samples not packaged for individual sale or resale and labeled as not for sale.

The obligation runs to the “manufacturer,” meaning the company whose name appears on the label or the company the product is manufactured or distributed for as identified under the federal Fair Packaging and Labeling Act. A retailer selling a third-party product with the original manufacturer’s branding is not the party carrying the disclosure duty.1California Legislative Information. California Health and Safety Code Division 104 Part 3 Chapter 13

What Must Be Disclosed

Intentionally Added Ingredients

Any chemical a manufacturer deliberately puts into a product for a functional or technical purpose is an intentionally added ingredient. This includes the individual components of fragrance blends and colorants, not just the blend itself. These ingredients must appear on labels and online disclosures, subject to the trade secret exceptions below.1California Legislative Information. California Health and Safety Code Division 104 Part 3 Chapter 13

Nonfunctional Constituents

The act also reaches impurities, byproducts, and breakdown products that serve no functional purpose in the finished product. It names 34 specific chemicals that qualify, including formaldehyde, benzene, chloroform, 1,4-dioxane, and several phthalates and parabens.1California Legislative Information. California Health and Safety Code Division 104 Part 3 Chapter 13

For online disclosure, nonfunctional constituents must be listed when present at or above 0.01 percent (100 parts per million). A lower threshold applies to 1,4-dioxane, which must be disclosed at 0.001 percent (10 ppm). Any nonfunctional constituent known to the state to cause cancer or reproductive harm under Proposition 65 that triggers a product warning must be disclosed regardless of concentration.2California Legislative Information. California Health and Safety Code 108954.5

On-Product Label Requirements

Manufacturers choose between two label approaches. The first is a targeted list: disclose only those intentionally added ingredients that appear on a “designated list” (a set of government-maintained chemical watchlists), plus any fragrance allergens present at 100 ppm or above that are identified on the EU Cosmetics Regulation’s Annex III as required to be labeled under the EU Detergents Regulation.3California Legislative Information. SB-258 Cleaning Product Right to Know Act of 2017

The second option is full transparency on the label: list every intentionally added ingredient except those qualifying as confidential business information. Under this approach, fragrance ingredients and colorants can be listed generically as “fragrances” or “colorants,” and the label must include a statement reading “Contains fragrance allergen(s)” when any EU-listed fragrance allergen is present at 100 ppm or above.3California Legislative Information. SB-258 Cleaning Product Right to Know Act of 2017

Under either option, the total concentration of each fragrance allergen is determined by adding contributions from all fragrance ingredients and other ingredients in the product, including its presence in essential oils. Fragrance components cannot be treated in isolation to stay under the threshold.

Online Disclosure Requirements

The website disclosures go substantially further than the label. For each designated product, the manufacturer must post, in an electronically readable format:

  • Each intentionally added ingredient, listed in descending order by weight, with ingredients below one percent listed in any order after the others.
  • All nonfunctional constituents at or above 100 ppm, with the 10 ppm threshold for 1,4-dioxane and mandatory listing for Proposition 65 chemicals that trigger a product warning.
  • The Chemical Abstracts Service (CAS) number for every listed ingredient. If no CAS number exists, the manufacturer notes “not available.” If the ingredient is protected as confidential business information, the listing reads “withheld.”
  • The functional purpose of each ingredient. Fragrance ingredients and colorants can simply be labeled as such.
  • Electronic links, grouped in one location, for any ingredient that appears on a government-maintained designated list or the EU fragrance allergen list.
  • A link to the product’s hazard communication safety data sheet.
2California Legislative Information. California Health and Safety Code 108954.5

The label tells you what is in the bottle. The website tells you why each ingredient is there, its relative concentration, and whether any recognized authority considers it a concern.

Trade Secret Protections and Their Limits

The act does not require manufacturers to lay bare every proprietary formula detail. Manufacturers never have to disclose the weight or amount of any ingredient, and they can withhold the specific identity of ingredients that qualify for trade secret protection.4California Legislative Information. SB-258 Cleaning Product Right to Know Act of 2017 – Compare Versions

An ingredient qualifies as confidential business information if it appears on the federal Toxic Substances Control Act (TSCA) Confidential Inventory, or if the manufacturer or supplier claims protection under California’s Uniform Trade Secrets Act. When withholding a specific chemical name, the manufacturer substitutes a generic name from the TSCA Confidential Inventory. If the chemical is not on that inventory, the substitute name is only as generic as necessary to protect its identity.4California Legislative Information. SB-258 Cleaning Product Right to Know Act of 2017 – Compare Versions

The shield has hard limits. Manufacturers cannot claim confidential business information protection for any ingredient that appears on a government-designated chemical watchlist, for any nonfunctional constituent (the 34 listed contaminants), or for EU-listed fragrance allergens present at 100 ppm or above.4California Legislative Information. SB-258 Cleaning Product Right to Know Act of 2017 – Compare Versions

Compliance Deadlines

The act rolled out in phases. Online disclosures were required by January 1, 2020. On-product label compliance followed on January 1, 2021. A separate deadline of January 1, 2023 applied to labeling Proposition 65 chemicals on product packaging.3California Legislative Information. SB-258 Cleaning Product Right to Know Act of 2017

All deadlines have passed. Any designated product currently sold in California should have both a compliant label and a complete online disclosure.

Enforcement

The California Attorney General has enforcement authority. The office can investigate potential violations by reviewing product labels, online disclosures, and related documentation. Available remedies include injunctions to compel manufacturers to update their disclosures and civil actions for non-compliance. A manufacturer that omits a Proposition 65 chemical from its disclosure also faces potential liability under Proposition 65 itself.

How the Act Fits With Federal Labeling Rules

SB 258 operates alongside federal labeling rules rather than replacing them. The federal Hazard Communication Standard (HCS) administered by OSHA requires containers of hazardous chemicals to carry a product identifier, signal word, hazard statements, precautionary statements, pictograms, and manufacturer contact information, and it requires a 16-section Safety Data Sheet to accompany hazardous chemicals.5Occupational Safety and Health Administration. Hazard Communication Standard: Labels and Pictograms

The two systems address different questions. The HCS focuses on hazard: is this chemical flammable, corrosive, or toxic? SB 258 focuses on identity: what is in the product, and at what relative concentration? A product can be fully HCS-compliant and still violate SB 258 if it does not separately disclose its ingredient list, CAS numbers, and functional purposes. Manufacturers selling into California need to satisfy both. The SB 258 requirement to link to the product’s safety data sheet online bridges the two, so consumers reach ingredient identity and hazard information in one place.

Worker Access to Ingredient Information

The statute’s stated purpose extends beyond consumers to workers, and includes “requiring specified employers to provide that information to their employees.”6California Legislative Information. California Health and Safety Code 108950

Janitorial staff, housekeepers, and commercial cleaners regularly handle designated products in enclosed spaces with limited ventilation. The detailed online disclosures, including CAS numbers and links to safety data sheets, give workers and their employers the information needed to assess chemical exposure and comply with workplace safety requirements.