New York Delays New Cleaning Product Labeling Enforcement Until October

The New York State Department of Environmental Conservation (“NYS DEC”) has announced that it will not enforce the first required disclosure milestone under the Household Cleansing Product Information Disclosure Program (the “Program”) until October 2, 2019. The Program requires manufacturers of covered cleansing products to identify all ingredients and impurities in their products and their content by weight and to post this information on their websites in accordance with several disclosure deadlines. Manufacturers employing more than 100 people were to disclose the following ingredients by July 1, 2019: intentionally added ingredients other than fragrance ingredients; and nonfunctional ingredients present above trace quantities. An “intentionally added ingredient” is a chemical the manufacturer has intentionally added to a product covered by the Program that has a functional or technical effect in the finished product, including intentionally added fragrances, colorants, and breakdown products that have a functional or technical effect on the finished product. NYS DEC will not enforce the July 1, 2019 disclosure requirement for a period running from July 1, 2019, to October 1, 2019. NYS DEC will begin enforcing any violations of the required disclosures as of October 2, 2019. A list of cleansing products covered by the Program can be found in this guidance document published by NYS DEC. For more information about the Program’s required disclosures or enforcement of violations, contact Steve O’Day or Vickie Rusek.

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