White Paper: The Importance of the Safer Choice Mark for Cleaning Products

August 26, 2021

To earn consumer trust by being recognized as a Safer Choice product, a cleaning product must first demonstrate it meets the Safer Choice Standard.

The global market for sustainable cleaning products is expected to reach $111.2 billion (USD) by 2026.¹ To put that figure in context, the projected total market value for all cleaning products in 2026 is $207.3 billion (USD). This estimate falls in line with prevailing consumer attitudes toward green products, especially in North America. According to a recent study by IBM and the National Retail Federation, almost 70% of U.S. and Canadian consumers favor sustainable or eco-friendly brands.²

To capitalize on the demand for greener alternatives, more companies have been using language such as “eco-friendly,” “all-natural” and “sustainable” on their products and in their advertising. These phrases are not regulated in the U.S., encouraging a sizable amount of greenwashing among cleaning products. Greenwashing is a marketing tactic that tries to convince consumers a product is environmentally sound without any substantiation. In light of this practice, ecolabels have become of great value to consumers.

The U.S. EPA defines ecolabels as “marks placed on product packaging that help consumers identify products that meet specific environmental performance criteria and are therefore deemed ‘environmentally preferable.’” To receive an ecolabel, products must go through an established science-based vetting process. Some of the more recognizable ecolabels include USDA Organic, NON-GMO Project Verified and WaterSense. Of the programs familiar to consumers, Safer Choice is particularly important to the cleaning products market.

Becoming the Safer Choice for Consumers

Safer Choice is a voluntary partnership program managed by the EPA. The Safer Choice label on a product indicates that the program considers it a quality product that “contains only those ingredients that pose the least concern among chemicals in their class.” Safer Choice recognition occurs in renewable three-year cycles and includes a listing in the program’s database.

2000+ Products currently bear the Safer Choice label.

To achieve Safer Choice recognition, a product and its ingredients must meet the requirements of the Safer Choice Standard. Every review is performed by a qualified third-party profiler—such as NSF—that acts on behalf of the EPA. There are a few, unique exceptions to this rule, e.g. a private label product whose manufacturer has already had the original product reviewed by a third-party profiler. It should also be noted that to protect program partners, all trade secrets and proprietary formulation information are kept confidential by third-party profilers and the EPA.

Initial Recognition

If a product is new to the Safer Choice program, the first step in gaining recognition involves an initial toxicological review of the product and its ingredients. If everything in the review is found acceptable, the cleaning product company then enters into a three-year partnership agreement with the EPA.

Ingredient-Level Requirements

Per the Safer Choice Standard, every ingredient must meet strict safety criteria for both human health and the environment. The cleaning product formulator must disclose every intentionally added ingredient and all known residuals in the product, regardless of their percentage in the product. Information about impurities and byproducts are also taken into consideration during the review. In addition, the formulator must provide a copy of each ingredient’s Safety Data Sheet (SDS) from primary and alternate suppliers. Once this information has been received, all ingredients and their chemical components are reviewed against the Safer Choice Master Criteria for Safer Chemical Ingredients (i.e. Master Criteria).

The human health and environmental toxicological endpoints covered by the Master Criteria are:

Carcinogenicity
Reproductive and developmental toxicity
Mutagenicity
Repeated dose toxicity
Acute toxicity
Skin sensitization
Toxicity to aquatic life and persistence in the environment

If an ingredient falls under a specific functional class of chemicals, the ingredient is reviewed against tailored functional-class criteria in addition to the Master Criteria. This enables “formulators to use those ingredients with the lowest hazard in their functional class, while still formulating high-performing products.” Based on their role in how they help make a product work, ingredients are grouped into one of the following functional classes:

Enzymes and enzyme stabilizers
Surfactants
Solvents
Chelating and sequestering agents
Colorants, polymers, preservatives and related chemicals
Fragrances
Oxidants and oxidant stabilizers
Defoamers
Processing aids and additives

Product-Level Requirements

To minimize the potential for dermal and eye irritation or injury, the cleaning product must have a pH value greater than or equal to 2 but less than or equal to 11.5. Products whose pH values fall outside this range can still be considered for recognition if: 1) in vivo testing proves the product is not corrosive to skin or eyes, or 2) the product is used in a closed dilution system.

In regard to flammability, a cleaning product’s flashpoint must be at or above 60° C (140° F). Products must also meet Volatile Organic Compound (VOC) restrictions as prescribed by the Ozone Transport Commission and California Air Resources Board (CARB). Furthermore, performance testing is done to assess if a cleaning product performs as well or even better than conventional (i.e. non-green) national brands.

When it comes to product packaging and marketing, Safer Choice requires three things from the product formulator:

A product’s primary packaging must meet specific sustainability requirements (e.g. be made of recyclable plastic) and has to be free of phthalates, BPAs and heavy metals.
The packaging label must disclose to consumers all ingredients in the product. If this information is not on the label, it must be made publicly available online or via a toll-free phone number. In addition, the formulator must provide Safer Choice or the third-party profiler a draft of how they would use the Safer Choice logo on the packaging.
The product formulator must provide consumers a statement saying that Safer Choice recognition doesn’t constitute an endorsement of the product by the EPA. The company must disclose to whoever is conducting their review where this statement would exist. In most cases, it is placed online.

The Recognition Cycle

The three-year recognition cycle of the EPA’s partnership agreement includes an on-site audit, desk audit and toxicological renewal review.

An on-site audit must occur at the manufacturing facility once during the three-year recognition cycle. This audit reviews production operations and covers good manufacturing practices (GMPs), authorized formulation and production records, complaint files, written processes and other facility records. If the Safer Choice partner has multiple manufacturing facilities, two sites would be audited once per three-year recognition cycle.

All recognized and private label products must also undergo an off-site desk audit once during the three-year cycle. Similar to the on-site audit, the desk audit verifies that recognized products are being manufactured according to their approved formula. In addition, this audit reviews print and electronic materials pertaining to marketing, end user education and labeling. Both audit types rely heavily on batch record documentation and supplier confirmation of purchases and ingredients.

In the final year of the partnership with the EPA, a toxicological renewal review is completed for each recognized product. Much like the initial toxicological review, a third-party profiler evaluates formulations against product and ingredient level criteria. This ensures the product has maintained conformance with the Safer Choice Standard and Master Criteria. If the intent is to continue with the program, the Safer Choice partner must renew its partnership agreement before the recognition cycle expires. Once renewed, the three-year recognition cycle would begin again after the current cycle’s expiration date.

CleanGredients

To help streamline the Safer Choice ingredients review process, cleaning product formulators can use chemical ingredients approved for listing in the CleanGredients database.

Developed and managed by an environmental nonprofit organization called GreenBlue, CleanGredients is an online database of proprietary ingredients that have been evaluated against the Safer Choice Master Criteria and functional-class criteria, as well as pre-approved for use in Safer Choice products. If the ingredient is approved, it is listed in the CleanGredients database. The listing includes the ingredient’s trade name, manufacturer’s name, Chemical Abstracts Service (CAS) Registry Number, functional class, Safer Choice status and approval date. CleanGredients listings are valid for three years.

To become part of the database, a proprietary ingredient manufacturer must subscribe as a supplier to CleanGredients and choose a third-party profiler to perform their toxicological reviews. Most manufacturers use NSF as their profiler because both the CleanGredients and Safer Choice programs already approve NSF as a qualified profiler for reviews.

800+ Proprietary ingredients are listed with CleanGredients.

Without a listing, an ingredient manufacturer may have to work with different third-party profilers every time a cleaning product formulator is going through a Safer Choice review. With a listing, the manufacturer only has to work with one profiler once every three years. From the product formulator’s perspective, using CleanGredients is an effective way to source ingredients that can help their products achieve Safer Choice recognition. Some formulators even request the ingredients they use to become listed in the CleanGredients database.

Conclusion

Safer Choice is a voluntary program managed by the EPA but driven by consumers demanding greater accountability and transparency from cleaning product manufacturers. To determine if a product meets the Safer Choice standard, the program evaluates formulations, ingredients, facilities, packaging, labeling and consumer-facing literature. Product formulators can also make the review process more manageable by using ingredients verified as CleanGredients. Safer Choice recognition ultimately benefits both the formulator and consumer because, according to the program, “the Safer Choice label offers a readily identifiable way to know that a product is as safe as possible for people and the environment.”