ingredient disclosure for fifra regulated products

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Ingredient Disclosure for FIFRA- Regulated Products Presentation to National Pesticide Safety Education Center August 21, 2018 Komal K. Jain, CBC Jim Jones, HCPA Background FIFRA protects against the disclosure of commercial or financial

  1. Ingredient Disclosure for FIFRA- Regulated Products Presentation to National Pesticide Safety Education Center August 21, 2018 Komal K. Jain, CBC Jim Jones, HCPA

  2. Background FIFRA protects against the disclosure of commercial or financial information on registered pesticides Some retailers and one state (CA –SB 258) require product manufacturers to include ingredients traditionally treated as confidential on product labels and/or their websites 2

  3. Ingredient Listing Initiatives SB 258 Scope: • Cleaners Yes Yes • FIFRA Antimicrobials Anti + Pest • Personal Care No Yes Timing • On-Line Jan 2020 Start Jan 2015 • On-Label Jan 2021 (N/A for FIFRA) Start Jan 2018 3

  4. State Ingredient Disclosure Initiatives States consider bills mimicking CA SB 258 • Maryland legislation failed in committee during 2018 Session • Additional legislation expected in 2019 Legislative Sessions New York • Governor-driven initiative finalized in June 2018 requires online disclosure of ingredients in cleaning products • exempts FIFRA-regulated products CA Prop 65 • New regulations expand Prop 65 warning requirements • CA and EPA still evaluating how to add Prop 65 warnings to pesticide labels 4

  5. Retailer Initiatives Walmart Sustainable Chemistry Policy Scope : formulated consumable products – including “Aisle 13” household chemicals Ø Includes some household pest control products and antimicrobial cleaning products • 2013 - Require suppliers to disclose product formulations through WERCSmart platform Ø Disclose ingredients above and beyond information required for regulatory compliance • 2014 - Require suppliers to phase-out “Walmart High Priority Chemicals” • 2015 - Require suppliers to begin providing full on-line disclosure of ingredients • 2018 - Expect suppliers to begin providing on-pack disclosure Target Chemicals Policy & Goals Scope : Target’s own and national brand baby care, personal care and household cleaning products • Does NOT require on-line or on-pack disclosure • Require suppliers to provide information ( via the UL-WERCSmart platform) about product ingredients including chemical names and CAS #s by Dec. 31, 2018 • Set goals to achieve transparency to all ingredients including generics such as “fragrance,” in beauty, baby care, personal care and household cleaning formulated products by 2020 • Set goals to remove “unwanted chemicals” by 2020 5

  6. Walmart On-Pack Disclosure • Walmart expected companies to begin providing on-pack disclosure by January 1, 2018 ‒ Disclose all intentionally added ingredients on either the Walmart Priority Chemicals List or the California SB 258 designated list ‒ Provide on-pack disclosure for FIFRA-registered products only as registrants update labels • Industry needs EPA and state agreement on outstanding issues before labels can be submitted for EPA review 6

  7. Outstanding Issues Registration submission pathway: Are registrants obligated to submit ingredient(s) in advance of registrant-initiated label changes? If so then how? Location/font size on label: Since ingredient labeling outside the ingredient statement is voluntary, will EPA allow registrants discretion in location and size? Nomenclature for ingredients: Flexibility is needed to protect commercial information per FIFRA Section 10. Scope of ingredient disclosure: Registrants need discretion to choose partial or full disclosure to protect commercial information. 7

  8. Location on Label/Font Size Location of the list of ingredients and font size should be at company’s discretion: • Label real estate is at a premium • Issue: Is on-label listing of inert ingredients in response to retailer/states subject to FIFRA labeling requirements (40 CFR Part 156)? Ingredient disclosure outside of FIFRA elements 8 Ethanol, Water, Butane, Propane, Ethanolamine, Isobutane, Alkyl (50% C14, 40% C12, 10% C16) dimethyl benzyl ammonium saccharinate, t-Butyl Alcohol, Fragrance/Parfum, Dipropylene Glycol, MEA-Borate, MIPA-Borate, Ammonium Hydroxide

  9. Nomenclature for Ingredients For consumer understanding and transparency, and protection of commercial information, companies need flexibility in nomenclature for public-facing disclosure and CSFs Nomenclature used should not be subject to misbranding EPA or state enforcement Use of CA SB 258 options (“hierarchy”) as the model Registrant has ability to use any of the following options: • Household & Commercial Products Association Consumer Product Ingredients Dictionary (HCPA Dictionary); OR • International Nomenclature of Cosmetic Ingredients (INCI); OR • International Union of Pure and Applied Chemistry nomenclature (IUPAC); OR • Chemical Abstracts Index name; OR • Common Chemical Name 9

  10. Scope of Ingredient Disclosure? The choice to disclose all ingredients or only priority chemicals identified by Walmart or future retailers should be up to registrants: • Full disclosure may not be practical due to label real estate • No binding regulation that registrants must list all inerts if one ingredient is disclosed 10

  11. Options: Chemicals of Concern or Full Disclosure Partial Full ingredient Disclosure only disclosure per of chemicals CA SB 258 on CA SB 258 requirements designated lists 11

  12. Our Asks Utilize State/EPA and State/EPA/Industry Work Groups to find a • resolution by Fall 2018 • Assess state agency resources: Ø There are thousands of labels that can be impacted. Ø How will these be processed in an efficient manner? 12


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