California SB 258: Labels, Online Disclosure, and Deadlines

California’s cleaning product disclosure requirements come from SB 258, the Cleaning Product Right to Know Act of 2017, which forces manufacturers to name hazardous ingredients and fragrance allergens on the physical label and to post a fuller ingredient breakdown, complete with chemical identifiers and links to hazard lists, on their websites.¹ All disclosure deadlines have passed, so any covered product on a California shelf should already comply.

Which Products Fall Under the Law

SB 258 covers four categories of finished consumer cleaning goods, which it calls “designated products”:

Air care products such as air fresheners and deodorizers
Automotive products such as car wash soaps, tire cleaners, and interior cleaners
General cleaning products, including all-purpose cleaners, glass cleaners, bathroom and kitchen cleaners, and disinfectants
Polishes and floor maintenance products used for janitorial, domestic, or institutional cleaning

Personal care items are outside the law. Toothpaste, shampoo, and hand soap are not covered, and neither are foods, drugs, or cosmetics. Industrial products made exclusively for oil and gas production, steel manufacturing, heavy industry, industrial water treatment, and food processing are also exempt, along with trial samples not packaged for retail sale.¹

What You’ll See on the Label

Manufacturers pick between two label options. The first is a shorter list: only the intentionally added ingredients that appear on one of the law’s “designated lists” of hazard chemicals, plus any fragrance allergens from Annex III of the EU Cosmetics Regulation present at or above 0.01 percent of the finished product. The second option is a full list of every intentionally added ingredient, with fragrance ingredients and colorants allowed to be grouped under generic terms like “fragrances” or “colorants.”¹

One point worth clarifying, because it’s often misstated: there is no universal 0.01 percent cutoff for intentionally added ingredients on the label. The 0.01 percent figure applies to fragrance allergens on the label and to contaminants and byproducts in the online disclosure. For intentionally added ingredients, what triggers label disclosure is either the ingredient’s presence on a designated hazard list or the manufacturer’s choice to list everything.

Every label must also carry the manufacturer’s toll-free phone number and website address, giving shoppers a route to the fuller disclosure.

What You’ll Find Online

The website disclosure goes considerably further than the label. For each designated product sold in California, the manufacturer must post, in an electronically readable format:

Every intentionally added ingredient, in descending order by weight, though ingredients below one percent can appear in any order at the end of the list
Nonfunctional constituents, meaning contaminants, byproducts, and impurities present at or above 0.01 percent (100 ppm), with a stricter 0.001 percent (10 ppm) threshold for 1,4-dioxane
The Chemical Abstracts Service (CAS) registry number for each ingredient or constituent, or “not available” if none exists
The functional purpose of each ingredient, such as surfactant, solvent, or preservative
Electronic links to any designated hazard lists on which listed chemicals appear, grouped in one location on the page

The label handles the store aisle, and the website handles deeper research. Someone comparing products at home can pull up the full ingredient breakdown with chemical identifiers and hazard-list references.²

The Hazard Lists That Trigger Extra Disclosure

SB 258 borrows its definitions of hazard chemicals from existing scientific and regulatory sources rather than creating its own. A chemical is subject to heightened disclosure if it appears on any of these designated lists:

California’s Proposition 65 list of chemicals known to cause cancer or reproductive harm
The European Union’s classifications for carcinogens, mutagens, or reproductive toxicants in Category 1A or 1B
The EU Candidate List of Substances of Very High Concern for endocrine-disrupting properties
Chemicals on the EU list for persistent, bioaccumulative, and toxic (PBT) or very persistent and very bioaccumulative (vPvB) properties
Chemicals with EPA reference doses or reference concentrations based on neurotoxicity in the federal Integrated Risk Information System
Chemicals classified as carcinogenic or likely carcinogenic in the EPA’s Integrated Risk Information System

These lists change over time, and SB 258 automatically incorporates future revisions when the relevant authority adopts them. A manufacturer can’t compile a one-time snapshot and rely on it.³

Fragrance Allergens Get Special Treatment

Fragrances often contain dozens of individual compounds, and some are known allergens. SB 258 uses Annex III of the EU Cosmetics Regulation to identify the specific fragrance allergens that must be disclosed when present at or above 0.01 percent (100 ppm) of the finished product.

Manufacturers calculate each allergen’s total concentration by adding contributions from every ingredient that carries it, essential oils included. In the online disclosure, fragrance ingredients must be listed individually by name and CAS number, and any appearance on a designated hazard list must be flagged and linked. Fragrance allergens can’t be hidden behind trade-secret claims.¹

When Manufacturers Can Withhold an Ingredient

Trade-secret protection is available under SB 258 but tightly bounded. A manufacturer can claim confidentiality only if the ingredient has been approved by the federal EPA for inclusion on the Toxic Substances Control Act Confidential Inventory, or the manufacturer or its supplier claims protection under California’s Uniform Trade Secrets Act.

Three categories can never be withheld, regardless of competitive concerns:

Any ingredient that appears on a designated hazard list
Nonfunctional constituents (contaminants and byproducts)
Fragrance allergens from EU Annex III present at or above 0.01 percent

When an ingredient is properly withheld, the manufacturer must use the word “withheld” in place of the CAS number so consumers can see that something has been redacted rather than simply omitted.²

Workplace Access for Employees

SB 258 also added Section 6398.5 to the California Labor Code. Employers who already maintain safety data sheets for cleaning products used in the workplace must make the online disclosure information for those products just as readily available to employees as the safety data sheets themselves.¹

This matters most for janitorial and housekeeping workers. Safety data sheets required under Cal/OSHA often use technical language and don’t list every ingredient. The SB 258 disclosure provides a full ingredient list with plain-language functional descriptions.

How the Law Is Enforced

SB 258 doesn’t hand enforcement to a single California agency. Violations are pursued through California’s Unfair Competition Law. The Attorney General, district attorneys, and qualifying city attorneys can bring civil actions against noncompliant manufacturers. Private individuals can also sue, seeking court orders to stop the noncompliance, restitution under the UCL, and attorney’s fees under California’s private attorney general statute.

Civil penalties reach up to $2,500 per violation. Courts weigh how serious the violation was, how many products were affected, how long it lasted, and whether the conduct was willful.⁴ Because penalties run per violation, a manufacturer with several noncompliant products across many retailers can accumulate significant exposure.

Deadlines Already in Effect

The law rolled out in stages. Online ingredient disclosures became mandatory on January 1, 2020. Physical label disclosure requirements took effect on January 1, 2021. A delayed deadline for chemicals on California’s Proposition 65 list required their appearance on labels beginning January 1, 2023.¹ Every one of those dates has passed, so a covered product sold in California today should meet both the label and online requirements in full.

1
California Legislative Information. California Senate Bill 258 – Cleaning Product Right to Know Act of 2017
2
California Legislative Information. California Health and Safety Code 108954.5
3
California Legislative Information. California Code HSC 108952
4
California Legislative Information. California Business and Professions Code 17206