In response to the announcement from the New York Department of Environmental Conservation (DEC) on the release of their rule on ingredient disclosure, the Household & Commercial Products Association released the following statement:

The members of the Household & Commercial Products Association are clearly disappointed and quite frankly perplexed by the New York State Department of Environmental Conservation’s (NYSDEC) decision to finalize its rule on chemical reporting and disclosure entitled, “Household Cleansing Product Information Disclosure Program.”

Despite HCPA’s diligent efforts to work proactively and collaboratively with NGO’s and the NYSDEC, the rule still has many unworkable, costly and unscientific provisions. This program as currently outlined will ultimately cost existing and future jobs, while stifling cleaner and greener product innovation that consumers and workers are increasingly looking for.

Consumers and workers should be able to feel confident that regulations are developed based on the best available science through a transparent process that encourages public participation. The NYSDEC’s decision to move forward unilaterally goes against this principle, is premature and leaves industry no choice but to consider all options, including litigation, to address the significant issues with this flawed guidance.

HCPA prides itself on working with legislators in a bipartisan manner, not-for-profit NGO’s, and regulatory agencies at all levels of government to provide the right information to consumers and workers that will better inform their product decisions. A very recent example of this approach was successful in California where the Cleaning Product Right to Know Act of 2017 was passed into law as a direct result of industry working in good faith negotiations with the bill’s author, Senator Ricardo Lara (D-Bell Gardens) and NGO’s.

By refusing to work collaboratively with all stakeholders, including state legislators, the NYSDEC has chosen to derail the opportunity for a consistent national model and obscure what consumers and workers really need to know. The NYSDEC has deliberately cultivated a complicated and increasingly contradictory set of disclosure rules at the behest of Governor Andrew M. Cuomo, prompted by his desire to outdo California. This is in stark contrast to the comprehensive and transparent effort undertaken by the California legislature to hear and consider all views to reach a broad consensus between public health advocates and industry.

This approach by the NYSDEC will only serve to confuse consumers and adversely affect the manufacturers of familiar and highly-respected brand names found in almost every home across New York and the U.S. We respectfully urge the Department to retract this unfeasible and politically-motivated decision and to work with all stakeholders towards our shared goal of safeguarding consumers and workers with responsible and understandable ingredient communication solutions.


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