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October 24, 2017

New York Household Cleansing Product Information Disclosure Program Could Target Nanomaterials

Lynn L. Bergeson Carla N. Hutton

As reported in our October 20, 2017, memorandum, “California and New York Require Manufacturers to Disclose Ingredients in Cleaning Products,” on April 25, 2017, New York Governor Andrew Cuomo (D) announced the Household Cleansing Product Information Disclosure Program.  The Program will require manufacturers of household cleansing products sold in New York to disclose the chemical ingredients on their websites.  Under the draft 2017 Household Cleansing Product Information Disclosure Program Certification Form and Guidance Document, information regarding certain ingredients, including nanomaterials, would have to be disclosed.  The draft Guidance states:  “For each ingredient that is a nanomaterial, a term describing the nanomaterial should be disclosed.  For example, if the nanomaterial is carbon, the disclosure should use the term ‘nano’ carbon.”  Comments on the draft Guidance were due July 14, 2017.  Final Guidance is expected soon.