California SB 258: Cleaning Product Labels and Online Disclosure

California’s SB 258, the Cleaning Product Right to Know Act of 2017, requires manufacturers of cleaning products sold in California to disclose chemical ingredients in two places: a shorter list on the physical product label and a fuller ingredient breakdown on the company’s website. The disclosure rules cover air care products, automotive cleaners, general household and institutional cleaners, and polishes and floor maintenance products, and all deadlines are now in effect.¹

Which Products Are Covered

SB 258 applies to “designated products,” a defined set of finished consumer cleaning goods in four categories:

Air care products, including air fresheners and deodorizers
Automotive products, including 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

Several categories fall outside the law. Foods, drugs, and cosmetics are excluded, as are personal care items like toothpaste, shampoo, and hand soap. Products made exclusively for oil and gas production, steel manufacturing, heavy industry, industrial water treatment, and food processing are exempt. Trial samples not packaged for retail sale are also outside the law.¹

What Has To Appear On The Label

Manufacturers choose between two label formats. Under the first option, the label lists only intentionally added ingredients that appear on one of the law’s designated hazard lists, plus any fragrance allergens from the EU Cosmetics Regulation (Annex III) present at or above 0.01 percent of the finished product. Under the second option, the label lists every intentionally added ingredient, with the option to group fragrance ingredients under “fragrances” and colorants under “colorants.”¹

Every label must also carry the manufacturer’s toll-free phone number and website address, which point the consumer to the fuller online disclosure.

What Has To Appear Online

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

All intentionally added ingredients, listed in descending order by weight, except that ingredients below one percent of the product can appear in any order at the end of the list
Nonfunctional constituents (contaminants, byproducts, and impurities) present at or above 0.01 percent, with a stricter 0.001 percent threshold for 1,4-dioxane
The Chemical Abstracts Service (CAS) number for each listed ingredient or constituent, or “not available” if no CAS number exists
The functional purpose of each ingredient (surfactant, solvent, preservative, and so on)
Electronic links to any applicable designated hazard lists, grouped together in one location on the page

The label gives a shopper the essentials in the aisle; the online disclosure gives anyone researching a product the chemical identifiers and hazard references needed to look things up.²

Which Chemicals Trigger Disclosure

SB 258 does not maintain its own list of hazardous chemicals. It pulls from existing scientific and regulatory sources. A chemical is a “designated-list” chemical, triggering extra disclosure, if it appears on any of the following:

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
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 source lists change over time, and SB 258 automatically picks up revisions as they are adopted by the relevant authority.³

Fragrance Allergens

Fragrance chemicals have their own rules because a single “fragrance” can combine dozens of compounds, some of them known allergens. SB 258 uses the EU Cosmetics Regulation’s Annex III as its reference list of fragrance allergens that must be disclosed when present at or above 0.01 percent of the finished product. Manufacturers calculate total concentration by adding contributions from every ingredient in the product, including essential oils.

On the online disclosure, fragrance ingredients must be listed individually by name and CAS number, with any designated-list hits flagged and linked. Fragrance allergens cannot be hidden behind a trade-secret claim.¹

What Can Be Withheld As A Trade Secret

Manufacturers can hold back some ingredient information as confidential business information, but only within limits. A trade-secret claim is available 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, no matter how competitively sensitive:

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

When an ingredient is withheld, the manufacturer must enter “withheld” in place of the CAS number, so a reader can see that something was redacted rather than simply left out.²

Workplace Access For Employees

SB 258 added Section 6398.5 to the California Labor Code. Employers who are already required to maintain safety data sheets must also make the SB 258 online disclosure information for any designated cleaning product used in the workplace readily accessible to employees, in the same manner safety data sheets are made available.¹

That reaches janitorial workers, housekeeping staff, and anyone else who handles cleaning products on the job. Safety data sheets use technical language and don’t always list every ingredient; the SB 258 disclosure provides a full ingredient list with plain-language functional descriptions alongside it.

How The Law Is Enforced

SB 258 does not assign a specific California agency to monitor compliance or conduct inspections. Violations are enforced 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 halt the noncompliance and restitution under the UCL, along with attorney’s fees under California’s private attorney general statute.

Civil penalties can reach $2,500 for each violation. Courts weigh how serious the violation was, how many products were affected, how long the noncompliance lasted, and whether the manufacturer acted willfully.⁴ Because penalties are assessed per violation, a manufacturer selling multiple noncompliant products across many retail locations can accumulate substantial exposure.

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