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January 25, 2019

Bloomberg Environment Features Comments By Lynn L. Bergeson Regarding A Delayed Deadline for New York’s Ingredient Disclosure Requirements

The ACTA Group

On January 25, 2019, Bloomberg Environment spoke with Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. (B&C®), for the article “New York Pushes Back Cleaning Products’ Disclosure Deadline.”

Cleaning product manufacturers and their suppliers are hard put to comply with both New York’s and California’s ingredient disclosure requirements because they are dissimilar, said Lynn Bergeson, managing partner of Bergeson and Campbell PC, a Washington, D.C.-based firm specializing in chemical policies.

New York’s program set the first-in-the-nation deadline for disclosing chemical ingredients in cleaning products. California’s Cleaning Products Right-to-Know Act gave manufacturers until Jan. 1, 2020, to post their ingredients online and until Jan. 1, 2021, to include them on printed labels.

Guidance that New York released in June 2018 to implement its regulation sets lower chemical thresholds than California for when disclosure requirements are triggered. Specifically, New York requires concentrations above 0.1 percent of intentionally added chemicals to be disclosed and concentrations above 0.5 percent of unintentional impurities or other chemicals.

California requires disclosure of up to 34 chemicals if they are present at a concentration of 100 parts per million or higher.

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