- American Cleaning Institute Urges Science-Based, Harmonized Approach to Safer Consumer Products Regulation
The American Cleaning Institute (ACI) submitted formal comments to the California Department of Toxic Substances Control (DTSC) regarding the agency’s proposal to list manual dish detergents and shampoos containing 1,4-dioxane at concentrations greater than 1 part per million (ppm) as Priority Products under California’s Safer Consumer Products (SCP) regulations.
ACI expressed appreciation for DTSC’s stakeholder engagement and the agency’s efforts to ground its proposal in available science. The Institute’s comments provide targeted recommendations to strengthen clarity, ensure enforceability and maintain regulatory alignment across states, including existing requirements in New York.
ACI’s comments highlight the following priorities:
- Support the proposed 1 ppm concentration limit for ready-to-use products.
ACI agrees the 1 ppm threshold is appropriate for ready-to-use products as technically feasible, measurable and consistent with existing state requirements. Industry innovation has significantly reduced 1,4-dioxane levels in finished cleaning products. - Allow dilution calculations for concentrated products.
Concentrated and refill products offer environmental benefits, including reduced packaging, water use and transportation emissions. ACI recommends allowing manufacturers to demonstrate compliance based on the concentration of 1,4-dioxane in products as diluted for intended consumer use. - Clarify and separate hazard traits and toxicological endpoints.
ACI urges DTSC to distinguish hazard traits from environmental and toxicological endpoints in regulatory text, consistent with prior listings. The Institute also recommends specifying the species for toxicological endpoints and aligning descriptions of respiratory and other effects with available scientific evidence. - Strengthen and clarify analytical testing guidance.
ACI recommends updates to the Analytical Method Performance Guidelines to ensure accurate references and include key definitions. Clear, standardized measurement approaches are essential for enforceable and science-based regulation. - Provide transparency in compliance and audit procedures.
ACI requests clarification on how measurement discrepancies would be reconciled under Article 8 of the SCP regulations to ensure predictable and fair enforcement.
Commitment to Science-Based Regulation
1,4-Dioxane is not intentionally added to cleaning products and serves no functional purpose. It may occur at trace levels as a byproduct of manufacturing certain surfactants. ACI members have invested significant resources to minimize its presence and support science-based regulatory approaches that protect public health and the environment.
“The cleaning products industry shares DTSC’s goal of minimizing avoidable contaminants while ensuring safe and effective products remain available to consumers,” said Marie Gargas, ACI Associate Vice President, Regulatory and International Affairs. “With targeted improvements and clear compliance pathways, this proposal can achieve strong public health protections alongside regulatory certainty.”
ACI looks forward to continued engagement with DTSC as the rulemaking process moves forward.
The American Cleaning Institute® (ACI – www.cleaninginstitute.org) is the Home of the U.S. Cleaning Products Industry® and represents the $60 billion U.S. cleaning product supply chain. ACI members include the manufacturers and formulators of soaps, detergents, and general cleaning products used in household, commercial, industrial and institutional settings; companies that supply ingredients and finished packaging for these products; and chemical distributors. ACI serves the growth and innovation of the U.S. cleaning products industry by advancing the health and quality of life of people and protecting our planet. ACI achieves this through a continuous commitment to sound science and being a credible voice for the cleaning products industry.