Design for the Environment (DfE)- Brochure

DfE Safer Product Labeling Program: Starting the Process & FAQs Starting the DfE Process As part of preparing for a DfE submission, please assemble the following items: ? Final Formulation of Product (i.e., all intentionally added ingredients, including tradenames, supplier names, CAS #, and functional use) ? MSDS for Individual Ingredients, including alternate ingredient suppliers ? Packaging Template, filled out by the primary packaging supplier ? Performance Testing Report ? Product Labels, including the DfE logo mock-up, so that we can verify correct use ? Ingredient Disclosure The first two items on the list are required for a cost quote from a third-party profiler, as the cost is dependent upon the number and type of ingredients and CAS numbers. Please take the time to read to the DfE Standard for Safer Products (accessed via DfE weblink, below. Frequently Asked Questions (FAQs) about DfE ? Where can I find ingredients already approved for use in DfE products? You can find ingredients that may be acceptable for use in DfE recognized products on the DfE Safer Chemical Ingredients List (SCIL) (http://www.epa.gov/dfe/saferingredients.htm), or on CleanGredients (http://www.cleangredients.org/home). Both list ingredients by their functional class. ? Who may I contact at ToxServices for more information or to obtain a DfE quote? Please contact the ToxServices’ DfE Coordinator, Erica Harriman at 202-429-8789 or eharriman@toxservices.com ? What is acceptable performance testing? Acceptable performance testing methods can be found in Section 4.2.1 of the DfE Standard (see link below). If the product is a concentrate, performance testing should be done at the most dilute level of product recommended for consumer use. If a product type is not listed in the standard with recommended performance testing, then the performance testing should demonstrate that the product is as effective as a nationally recognized brand, of similar use. ? How and where should the ingredients be disclosed? For DfE recognition, ingredients may be disclosed on the product label, at a 24 hour toll-free number, or on the product website. If listed at a toll-free number or on the website, the consumer should be directed to either the URL or the toll-free number from the product label. All intentionally added ingredients should be listed in descending order, except for ingredients present at less than 1%, which may be listed in any order, at the end of the Page 2 of 2 ingredient listing. Additional ingredient listing information can be found at: http://www.epa.gov/dfe/pubs/projects/gfcp/ingredient_disclosure_guidance.pdf ? How do I meet the packaging criteria, and what is primary packaging? Primary packaging is the inner container or the material that comes in contact with the product ingredients. The packaging criteria, addressed in section 4.2.6 of the DfE Standard, states that the primary packaging should meet one of the following packaging goals, or a combination of the following, at a total level of 25%. o Is sourced, manufactured, transported, and recycled using renewable energy o Optimizes the use of renewable or recycled source materials o Is manufactured using clean production technologies and best practices o Is made from materials healthful in all probable end-of-life scenarios o Is physically designed to optimize materials and energy o Is effectively recovered and used in biological and/or industrial closed-loop cycles Additionally, the primary packaging should not contain heavy metals, BPA, or the following phthalates (dibutyl phthalate (DBP), diisobutyl phthalate (DIBP), butyl benzyl phthalate (BBP), di-n-pentyl phthalate (DnPP), di (2-ethylhexyl) phthalate (DEHP), di-n-octyl phthalate (DnOP), diisononyl phthalate (DINP), and diisodecyl phthalate (DIDP)). The third-party profiler can provide you with a template for your packaging supplier to document this information. Packaging guidance can be found at: http://www.epa.gov/dfe/pubs/projects/gfcp/packaging_guidance.pdf ? What is the threshold for DfE ingredient reviews? All intentionally added ingredients must be reviewed for functional class compliance, regardless of percent composition. Additionally, residuals and by products at or above 0.01% in the product as sold must be reviewed as well. ? How are CleanGredients and the DfE SCIL different? The DfE Safer Chemical Ingredients List (SCIL) contains CAS numbers that have been previously reviewed and approved for use in DfE recognized products. These CAS numbers have associated symbols next to them, whose definitions can be found at the top of the website page, and warn formulators against possible use restrictions of some ingredients. These CAS numbers are not an automatic pass, because there are variations between manufacturers, and some variations of the same chemical could contain residuals or additional intentionally added ingredients that are not acceptable. CleanGredients is a trade name specific database. The trade names listed on CleanGredients, associated with a specific supplier, have been reviewed by a third-party profiler and have been found to be acceptable for use in DfE recognized products. Relevant Websites U.S. EPA DfE Safer Product Labeling Program: www.epa.gov/dfe/pubs/projects/gfcp/index.htm CleanGredients: www.cleangredients.org