EPA's DfE
Criteria for Safer Cleaning Products (CSCP)
in the Form of a Standard
June 2009
This document was developed with the purpose of making DfE criteria for
recognition under the EPA Formuiator Program more transparent and accessible.
A group convened under the Green Chemistry and Commerce Council provided
guidance to DfE for the development of this document to ensure that it would
communicate well to its intended audience.
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Contents
Foreword iv
1 Purpose, scope, and normative references 1
1.1 Purpose 1
1.2 Scope 1
1.3 Normative references 1
2 Reference section 2
2.1 Definitions 2
2.2 Abbreviations 6
3 General requirements 7
3.1 General 7
3.2 Information and formulation requirements 7
3.3 Renewals 8
3.4 End-user education 8
3.5 Compliance 8
4 Product-level requirements 8
4.1 Scope 8
4.2 Criteria for all products 8
4.3 Cleaning systems 10
5 Component-specific requirements 11
5.1 Scope 11
5.2 General requirements 11
5.3 Surfactants 11
5.4 Direct release ingredients 11
5.5 Solvents 11
5.6 Fragrances 12
5.7 Builders 12
5.8 Polymers 12
5.9 Bacteria (spores & vegetative) 12
5.10 Toxic elements 12
5.11 Enzyme stabilizers 12
5.12 Disposable wipes 13
5.13 Residuals 13
5.14 Other ingredients 13
6 Use of the mark 14
6.1 Terms of use 14
6.2 Examples of appropriate use of the EPA/DfE certification mark 14
7 Profiler requirements 15
7.1 Elements of technical competence 15
7.2 Elements of credibility and good standing 17
7.3 Pilot review requirements 17
Annex A A1
A.1 Statement of purpose A1
A.2 Statement of context and challenge A1
A.3 «Company_Name»'s improved cleaning chemistries A2
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A.4 «Company_Name»'s commitment to formulate for the environment A2
A.5 Continuous environmental improvement A3
A.6 Formulator right to know A3
A.7 User benefits A4
A.8 EPA recognition and support A4
A.9 Limitations A5
A.10 Measures of success A5
A.11 Confidentiality A6
A.12 Amendments to the agreement A6
A.13 Termination or renewal of the agreement A6
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Foreword
EPA Design for the Environment (DfE) Program
DfE partners to advance environmental protection. The Design for the Environment (DfE) Program is
one of the Environmental Protection Agency's (EPA's) most valued partnership programs. The DfE
Program works in partnership with a broad range of stakeholders to reduce risk to people and the
environment by preventing pollution. DfE focuses on industries that combine the potential for chemical
risk reduction and improvements in energy efficiency with a strong motivation to make lasting, positive
changes. DfE convenes partners, including industry representatives and environmental groups, to
develop goals and guide the work of the partnership. Partnership projects evaluate the human health and
environmental characteristics, performance, and cost of traditional and alternative technologies,
materials, and processes. As incentives for participation and driving change, DfE offers unique technical
tools, methodologies, expertise, and the potential for product recognition.
DfE enables the selection of safer alternatives through informed substitution. Located in the Office
of Pollution Prevention and Toxics, the DfE Program promotes safer product design and green chemistry
alternatives through "informed substitution," the considered transition from a chemical of particular con-
cern to safer chemicals or non-chemical alternatives. The goals of informed substitution are to minimize
the likelihood of unintended consequences, which can result from a precautionary switch away from a
chemical of concern without fully understanding the profile of potential alternatives, and to enable a
course of action based on the best information—on the environment and human health—that is available
or can be estimated. To be considered safer choices, potential alternatives should exhibit as many of the
following characteristics as possible: they should be technically feasible; deliver the same or better value
in cost and performance; provide an improved profile for health and the environment; account for eco-
nomic and social considerations; and have the potential to result in lasting change.
DfE's Formulator Program
DfE applies informed substitution to cleaning products. The DfE Program applies informed substitu-
tion to critical areas of environmental and human health protection. In the cleaning industry, the DfE Pro-
gram partners with product manufacturers orformulators, environmentalists, and others, exchanging in-
formation and collaborating on the development of safer products. Formulators have been invaluable in
helping DfE understand the critical elements of product functionality and how to optimize product and
health/environmental performance. Environmentalists have provided important insight on chemical char-
acteristics, especially on defining the green end of the health/environmental spectrum, as well as ways to
ensure confidence in partnership environmental results.
To inform substitution, DfE considers each ingredient in a product within its distinct functional class (e.g.,
surfactants, solvents, chelating agents, etc.) and compares the toxicity and fate profiles to identify the
safest ingredients. DfE recognition is based on using the safest possible ingredients to make a high-
performing, cost-effective product. DfE considers whole product characteristics, like possible negative
synergies between ingredients and pH level, as well as lifecycle factors, like energy efficiency and water
savings.
DfE's functional class approach screens for safer ingredients. Each ingredient in a formulation has a
role to play in making a product work. Whether it is to aid in cleaning by reducing surface tension
(surfactants), dissolve or suspend materials (solvents), reduce water hardness (chelating agents), or
provide a scent (fragrances), each ingredient type has a function. Within these "functional classes," many
ingredients share similar toxicological and environmental fate characteristics. As a result, DfE focuses its
review of formulation ingredients on the key environmental and human health characteristics of concern
within a functional class. This approach allows formulators to use those ingredients with the lowest
hazard in their functional class, while still formulating high-performing products.
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DfE has used the technical expertise of its workgroup of EPA scientists to compare ingredients in the
same functional class and thereby identify those ingredients with the lowest hazard profile. The program
is now developing DfE Screens for safer chemical ingredients to share this expertise and make it easier
to formulate safer products. These screens are used to identify safer chemical ingredients, particularly for
use in cleaning products.
A DfE-labeled product contains the safest possible ingredients. The DfE logo offers a readily
identified way to know that a product is as safe as possible for people and the environment. When you
see the DfE logo on a product it means that the DfE scientific review team has screened each ingredient
for potential human health and environmental effects and that—based on the best available information,
EPA predictive models, and expert judgment—the product contains only those ingredients that pose the
least concern among chemicals in their class. For example, if a DfE-recognized product contains a
surfactant, then that surfactant will not be toxic to humans and it will biodegrade readily to non-polluting
degradation products; many surfactants in conventional products biodegrade slowly or biodegrade to
more toxic and persistent chemicals, which threaten aquatic life.
Product formulators or manufacturers who become DfE partners, and earn the right to display the DfE
logo on recognized products, have invested heavily in research, development and reformulation, to
ensure that their ingredients and finished product align at the green end of the health and environmental
spectrum, while maintaining or improving product performance.
DfE uses a rigorous, in-depth approach to review products. By focusing at the ingredient level and
on inherent characteristics, DfE is able to carefully scrutinize formulations and make meaningful calls on
potential concerns. DfE starts its product reviews with information that scientists already know about each
chemical ingredient, such as how it works in a detergent and how it affects living things. When that
information doesn't tell the full story, EPA looks at an ingredient's chemical structure—its components and
shape—to understand how it could impact the environment and people.
A chemical's structure can tell a lot about how the chemical will behave and what types of effects it may
have when it comes in contact with people or the environment. DfE uses the special skills of the scientists
at EPA who are expert in chemical analysis, hazard and risk assessment, and green chemistry.
DfE review is especially discriminating and protective. The DfE Program is unique because of two
defining characteristics: its assessment methodology and its technical review team. The DfE technical
review team has many years of experience and is highly skilled at assessing chemical hazards, applying
predictive tools, and identifying safer substitutes for chemicals of concern. The review team applies the
DfE assessment methodology by carefully reviewing every product ingredient. (The review includes all
chemicals, including those in proprietary raw material blends, which supplier companies share with DfE in
confidentiality).
DfE reviews provide an extra measure of protection. DfE uncovers chemicals of concern that can
be masked by raw material blends or by dilution in water. By focusing at the ingredient level and
on inherent characteristics, DfE is able to carefully scrutinize formulations and make meaningful
calls on potential concerns. For example, a surfactant that is acutely toxic to aquatic organisms
and environmentally persistent can appear to pose a low concern when blended with other less
toxic and less persistent surfactants. Similarly, water, typically the largest percentage ingredient
even in concentrates, can mask the toxicity of a hazardous chemical.
DfE uses its expert knowledge and predictive tools to supplement lists of chemicals of concern.
Few chemicals in commerce have been completely characterized, especially for chronic effects,
like cancer and developmental toxicity. For this reason, lists of chemicals with these effects can
only be considered a work in progress. DfE uses its knowledge of the structural similarities be-
tween chemicals and its predictive models to flag ingredients with similar potential effects.
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DfE spots negative synergies between product components. These potentially dangerous
chemical combinations, which occur with surprising frequency in cleaning products, pose
concerns for both acute and longer-term effects. For example, mixing nitro-containing compounds
with amines will create nitrosamines, potent carcinogens.
DfE screens all ingredients for chemicals that may present serious health or environmental
effects. This screening includes ingredients used in small percentages, like fragrances and dyes.
Some of the chemicals of most potential concern in cleaning products are those used in small
concentrations. Chemicals of concern include sensitizers, carcinogens, and environmentally toxic
and persistent compounds. Small quantities don't necessarily mean small hazards: a person,
once sensitized to a chemical, can have an allergic response even if exposed at minute levels.
DfE recommends safer substitutes for chemicals of concern. Movement toward sustainability
requires innovation and continuous improvement. The DfE program works directly with EPA's
Green Chemistry specialists to identify and recommend safer chemicals to its partners,
continuously raising the bar and redefining the meaning of environmentally preferable products.
DfE helps partners by sharing information and guiding the development of safer products. This is
a win for industry, families and the environment.
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DfE Criteria for Cleaning Products
1 Purpose, scope, and normative references
1.1 Purpose
This document, the Design for the Environment ("DfE") Criteria for Cleaning Products (the " DfE Criteria"),
establishes minimum requirements for identifying cleaning products that meet the U.S. Environmental
Protection Agency's DfE Safer Product Recognition (also know as the Formulator Partnership) Program
criteria.
1.2 Scope
The DfE Criteria are intended to cover cleaning products, including, but not limited to, glass cleaners,
general purpose cleaners, washroom cleaners, carpet cleaners, floor care products, laundry detergents,
graffiti removers, marine cleaning products, and drain cleaners. While this document includes the review
criteria for both the whole product and each product component, the DfE recognition applies only to the
finished cleaning product.
1.3 Normative references
The following documents are referenced in this text.
AATCC Test Method 171-1995.
AOEC List of Occupational Asthmagens
ASTM D4488 - 95(2001)e1 Standard Guide for Testing Cleaning Performance of Products Intended for
Use on Resilient Flooring and Washable Walls.
ASTM D5343 - 06 Standard Guide for Evaluating Cleaning Performance of Ceramic Tile Cleaners.
ASTM D6094 - 97 Standard Guide to Assess the Compostability of Environmentally Degradable Non-
woven Fabrics.
ASTM G122 - 96(2002) Standard Test Method for Evaluating the Effectiveness of Cleaning Agents.
California's Proposition 65 - Safe Drinking Water and Toxic Enforcement Act of 1986.
CSPA DCC-03 - Performance Test Methods and Guidelines - Rug Shampoo.
CSPA DCC-09 - Performance Test Methods and Guidelines - Glass Cleaners.
CSPA DCC-09A - Performance Test Methods and Guidelines - Standard Guide for Evaluating the Film-
ing and Streaking of Glass Cleaners.
CSPA DCC-10 - Performance Test Methods and Guidelines - Foam Stability of Hand Dishwashing De-
tergents.
CSPA DCC-11 - Performance Test Methods and Guidelines - Home Laundering Pre-Wash Spotter Stain
Removal.
CSPA DCC-12 - Performance Test Methods and Guidelines - Guidelines for Screening the Efficacy of
Oven Cleaners.
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CSPA DCC-13 - Performance Test Methods and Guidelines - Fabric Softeners.
CSPA DCC-14 - Guidelines for Anti-Redeposition Properties of Laundry Products.
CSPA DCC-16 - Guidelines for Evaluating the Efficacy of Bathroom Cleaners.
CSPA DCC-17 - Greasy Soil Test Method for Evaluating Spray-and-Wipe Cleaners Used on Hard, Non-
Glossy Surfaces.
CAN/CGSB 2-GP-11, Method 20.3.
DfE General Screen for Safer Ingredients - See http://www.epa.gov/dfe/pubs/projects/gfcp/index.htm.
DfE Screen for Safer Surfactants - See http://www.epa.gov/dfe/pubs/projects/gfcp/index.htm.
DfE Supplemental Environmental Screen for Direct Release Ingredients - See
http://www.epa.gov/dfe/pubs/projects/gfcp/index.htm.
DfE Screen for Safer Solvents - See http://www.epa.gov/dfe/pubs/projects/gfcp/index.htm.
DfE Screen for Fragrances - See http://www.epa.gov/dfe/pubs/projects/gfcp/index.htm (forthcoming).
DfE Partnership Agreement - Annex A.
European Commission list of substances prioritized for testing for endocrine disruption
Globally Harmonized System of Classification and Labeling of Chemicals (GHS)
http://www.unece.org/trans/danger/publi/ghs/ghs_rev02/02files_e.html.
2 Reference section
2.1 Definitions
Terms used in the DfE Criteria document that have a specific technical meaning are defined here.
2.1.1 absorbent: A material with the tendency to take up another substance into the bulk of the material.
2.1.2 adsorbent: A substance that attracts other substances to its surface, often for odor control pur-
poses.
2.1.3 allergen: An antigenic substance capable of producing immediate-type hypersensitivity. (See also
skin and respiratory sensitizer)
2.1.4 amine: An organic compound containing a basic (alkaline) nitrogen atom. Amines may be primary
(R-NH2), secondary (R2NH) or tertiary (R3N).
2.1.5 analog: Closely related chemical structures. (Reference: Analog Information Model)
2.1.6 antifoamer: A material that prevents or minimizes the formation of foam.
2.1.7 antioxidant: A chemical compound or substance that inhibits oxidation.
2.1.8 antiredeposition agent: An ingredient used in detergents to help prevent loosened soil from reset-
tling after it has been removed during washing. (SDA glossary)
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2.1.9 Association of Occupational and Environmental Clinics (AOEC) list of occupational asthma-
gens: A list of respiratory sensitizers and irritants found in occupational settings. For more information,
please see http://www.aoec.org/
2.1.10 asthma: A chronic disorder of the airways that is complex and characterized by variable and re-
curring symptoms, airflow obstruction, bronchial hyperresponsiveness (bronchospasm), and an underly-
ing inflammation. Asthma symptoms may be induced by a sensitizer (allergen) or an irritant.
2.1.11 asthmagen: An agent that causes asthma.
2.1.12 bacteria, spore: A retractile body formed within bacteria, especially genera of the family Bacilla-
ceae, which is regarded as a resting stage during the life history of the cell, and is characterized by its
resistance to environmental changes.
2.1.13 bacteria, vegetative: Single-celled organisms belonging to Kingdom Monera that possess a pro-
karyotictype of cell structure, which means their cells are noncompartmentalized, and their DNA is found
throughout the cytoplasm rather than within a membrane-bound nucleus. Vegetative bacteria are in
growth phase or reproductive phase; nutrients are not limited and the bacteria are not in spore form.
2.1.14 bioaccumulation: The progressive increase in the amount of a substance in an organism or part
of an organism which occurs because the rate of intake exceeds the organism's ability to remove the
substance from the body.
2.1.15 biodegradability: The capability of organic matter to be decomposed by biological processes.
Both the rate and the completeness of decomposition are factors in biodegradability.
2.1.16 bleaching agent: A chemical that acts by oxidizing stains to break them down and remove color.
2.1.17 builder: A broad category of materials that enhance or maintain the cleaning efficiency of the sur-
factant. Several types of compounds, with different performance capabilities, are used. Builders have a
number of functions, principally to inactivate water hardness and to supply alkalinity. This is accom-
plished either by sequestration, i.e. holding hardness minerals in solution, by precipitation, or by ion ex-
change. Other functions of builders are to supply alkalinity to assist cleaning, especially of acid soils, to
provide buffering so that alkalinity is maintained at an effective level, to aid in keeping removed soil from
redepositing during washing. Builders for the purposes of this document include chelators, alkalinity
boosters, pH Adjusters, and buffering agents.
2.1.18 California Proposition 65: A California law that regulates substances the state lists as causing
cancer, birth defects, or other reproductive harm. For more information, see
http://www.oehha.org/prop65.html
2.1.19 chelating agent: An organic chemical that forms two or more coordination bonds with a central
metal ion. Heterocyclic rings are formed with the central metal ion as part of each ring. Chelating agents
can change the properties of metal ions, help to transport metal ions, and prevent scale formation.
2.1.20 coalescing agent: A chemical that lowers the minimum film formation temperature of a polymer
(typically in a floor finish) so that it will form a uniform film at normal indoor temperatures. These chemi-
cals are typically solvents.
2.1.21 colorant: Any substance, natural or synthetic, whose primary use is to color various materials.
2.1.22 component: A chemical as identified by its Chemical Abstract Service (CAS) number.
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2.1.23 compostable: Capable of undergoing biological decomposition in a compost site as part of an
available program, such that the material is not visually distinguishable and breaks down into carbon diox-
ide, water, inorganic compounds, and biomass, at a rate consistent with known compostable materials.
2.1.24 corrosion inhibitor: Prevents the disintegration of a material into its constituent atoms.
2.1.25 cross-linker: A material that forms covalent bonds between polymer chains, either within or
across chains.
2.1.26 defoamer: Agent used to reduce foam.
2.1.27 denaturation: 1. To render unfit to eat or drink without destroying usefulness in other applications,
for example to add methanol or a bittering agent to ethyl alcohol. 2. Change in molecular structure of
proteins so that they cannot function normally, often caused by splitting of hydrogen bonds following
exposure to reactive substances or heat.
2.1.28 direct release products: Products that are intended for use in applications that result in their im-
mediate release to the environment, so that they bypass sewage treatment or septic systems, shortening
the time for degradation prior to entering sensitive environments. Home car washes, boat cleaners and
graffiti removers are examples of direct-release products.
2.1.29 dispersing agent: A material that increases the stability of particles in a liquid formulation.
2.1.30 enzyme: A protein that acts as a catalyst in biochemical reactions. Each enzyme is specific to a
particular reaction or group of similar reactions.
2.1.31 enzyme stabilizer: A chemical that maintains the activity of enzymes in the formulation by pre-
venting degradation and denaturation prior to use.
2.1.32 endocrine disruption list: European Commission list of substances prioritized for testing for en-
docrine disruption as identified in the June 2000 BKH report, "Towards the establishment of a priority list
of substances for further evaluation of their role in endocrine disruption" and its subsequent revisions.
2.1.33 foam booster: An additive used in detergents to increase suds production and stabilize lather.
2.1.34 formulator: A company that designs and makes chemical choices for the manufacture of prod-
ucts. DfE partners with formulator companies. Formulators may private label or license their DfE-
recognized formulas and thereby extend DfE recognition to their licensees or private label customers.
Key in DfE's decision to extend recognition to private label or licensed products is a demonstration that
the partner retains full control of the recognized formulation.
2.1.35 fluorescent whitening agent: (optical brightener) Complex, organic molecules that adhere to fab-
rics as though they were dyes. Ultraviolet (UV) energy is absorbed, converted, and emitted as visible blue
light to enhance fabric appearance and maintain whiteness or brightness.
2.1.36 fluorosurfactant: Any organic substance which contains fluorine-based functional groups and has
surface-active properties.
2.1.37 fragrance: A raw material or a mixture of fragrance raw materials for use in a cleaning product for
the primary purpose of imparting a scent and/or masking base odor.
2.1.38 fragrance raw material: Any basic substance, obtained by chemical synthesis or derived from a
natural source, present in a fragrance at greater than 0.01% by weight. Fragrance raw materials include
aroma chemicals, fragrant extracts (essential oils), and all auxiliary materials, including-but not limited to-
-solvents, surfactants/solubilizers, UV inhibitors, antioxidants, stabilizers, preservatives, and fixatives.
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2.1.39 hydrotrope: A substance that increases the solubility in water of another material, which is only
partially soluble.
2.1.40 irritant: An agent that induces inflammation. Respiratory irritants may produce Reactive Airway
Dysfunction Syndrome (RADS), also called irritant induced asthma.
2.1.41 ingredient: One component or a blend of components that are intentionally added to make up a
finished product. All ingredients are subject to this standard, regardless of percentage in the formulation.
See Section 5.13 for information on residuals.
2.1.42 licensee: A company that sells a product that consists of an unchanged currently-DfE-recognized-
product formulation under a different trade name and company name. Licencees may use the DfE Logo
on the licenced product with the permission of the original DfE Partner and DfE.
2.1.43 manufacturer: A company that manufactures a finished product formulation. DfE may partner with
product manufacturers.
2.1.44 mesophilic: A descriptive term for a phase in the composting process that occurs between tem-
peratures of 20 to 45°C (68 to 113°F) and is characterized by the presence and activity of organisms ca-
pable of thriving at these temperatures.
2.1.45 optical brightener: An alternate name for fluorescent whitening agent. (FWA]
2.1.46 persistence: The length of time the chemical can exist in the environment before being destroyed
(i.e., transformed) by natural processes.
2.1.47 pH adjuster: Acids or bases that decrease or increase pH as needed in a formula.
2.1.48 photosensitizer: A chemical which causes a photoallergy. Photoallergy is a form of allergic
reaction due to a metabolite formed by the influence of light. The second and subsequent exposures pro-
duce photoallergy skin conditions, which are often eczematous.
2.1.49 plasticizer: Plasticizers are additives that give hard plastics the desired flexibility, durability or
other functional characteristics.
2.1.50 polymer: A chemical substance consisting of molecules characterized by the sequence of one or
more types of monomer units and comprising a simple weight majority of molecules containing at least
three monomer units which are covalently bound to at least one other monomer unit or other reactant and
which consists of less than a simple weight majority of molecules of the same molecular weight.
2.1.51 preservative: A substance that protects against the natural effects of aging, such as decay, dis-
coloration, oxidation, and bacterial degradation.
2.1.52 private label: Brand sponsored by a wholesaler, retailer, dealer, or merchant, as distinguished
from a brand bearing the name of a manufacturer or producer; also called private brand. Manufacturers
use either their own name, that of a middleman, or a combination of both when they are marketing their
products. Private labeling occurs when middlemen, usually large retailers or wholesalers, develop their
own brand.
2.1.53 protease: An enzyme, also called a peptidase, that catalyzes the cleavage of internal peptide
bonds in a polypeptide or protein.
2.1.54 residual: Trace amounts of chemicals that are incidental to manufacturing. Residuals are not part
of the intended chemical product, but are present because of factors such as the nature of the synthesis
and engineering pathways used to produce the chemical. Residuals include: unintended by-products of
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chemical reactions that occur in product formulation and chemical synthesis, impurities in an ingredient
that may arise from starting materials, incompletely reacted components, and degradation products.
2.1.55 residual of concern: A residual that fails to meet the criteria in the General Screen for carcino-
genicity, mutagenicity, reproductive toxicity and other human health effects, or fails to meet the criteria for
persistence, bioaccumulation and toxicity, as defined by the Final PB&T Rule. See Section 5.13 for more
information.
2.1.56 rheology modifier: A chemical that modifies the viscosity of a formulation.
2.1.57 sensitization: The progressive amplification of a response following repeated administrations of a
stimulus.
2.1.58 sensitizer, respiratory: A substance that will lead to hypersensitivity of the airways and resultant
effects following inhalation.
2.1.59 sensitizer, skin: A substance that will induce an allergic response following skin contact.
2.1.60 solubility enhancer: A chemical additive that prevents chemicals or materials from separating or
falling out of solution. Solubility enhancers are often used in concentrated formulations. Solubility enhan-
cers consist of subcategories such as hydrotropes and small amines.
2.1.61 solvent: A liquid that has the ability to dissolve, suspend, or extract other materials without caus-
ing chemical change to the material or solution.
2.1.62 supplier: A manufacturer of a chemical component or ingredient, which is not an end-use prod-
uct. A supplier furnishes raw materials to formulators.
2.1.63 surfactant: Any organic substance and/or preparation which has surface-active properties and
which consists of one or more hydrophilic and one or more hydrophobic groups of such a nature and size
that it is capable of reducing the surface tension of water, and of forming spreading or adsorption
monolayers at the water-air interface, and of forming emulsions and/or microemulsions and/or micelles,
and of adsorption at water-solid interfaces. Surfactants may also be used for purposes other than deter-
gents such as emulsifiers, foaming agents, wetting agents, and stabilizers for dispersions.
2.1.64 terpenes: Unsaturated hydrocarbons occurring in most essential oils and oleoresins of plants.
Their structures are based on isoprene units, and may be cyclic or linear.
2.1.65 vapor: The gaseous form of a substance or mixture released from its liquid or solid state.
2.2 Abbreviations
AATCC - American Association of Textile Chemists and Colorists
ANSI - American National Standards Institute
AOEC - Association of Occupational and Environmental Clinics
ASTM - American Society for Testing and Materials
CAS - Chemical Abstract Service
CSPA - Consumer Specialty Products Association
DfE - Design for the Environment
DOT - Department of Transportation
EPA - US Environmental Protection Agency
FDA - Food and Drug Administration
FIFRA- Federal Insecticide, Fungicide, Rodenticide Act
GHS - Globally Harmonized System of Classification and Labeling of Chemicals
HAP - Hazardous Air Pollutant
IARC - International Agency for Research on Cancer
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ISO - International Standards Organization
IUPAC - International Union of Pure and Applied Chemistry
MSDS - Material Safety Data Sheet
NTP - National Toxicology Program
OECD - Organisation for Economic Co-operation and Development
OSHA - Occupational Health and Safety Administration
PBT - Persistent, Bioaccumulative and Toxic
SIDS - Screening Information Data Set
TRI - Toxic Release Inventory
TSCA - Toxic Substances Control Act
VOC - Volatile Organic Compound
3 General requirements
3.1 General
3.1.1 Product and material information described in Section 3.2 shall be used to determine the specific
section under which a product and its ingredients shall be evaluated.
3.1.2 Products or ingredients whose intended uses fall under more than one section of the DfE Criteria
document shall be evaluated under the section having the most rigorous evaluation criteria.
3.1.3 To obtain DfE recognition for a product, the applicant must comply with the information require-
ments in Section 3.2 et seq. and must enter into a partnership agreement with EPA. The partnership
agreement governs the relationship between EPA/DfE and its partner, the product formulator or manufac-
turer. It contains, among other elements, provisions covering the following: full ingredient disclosure; noti-
fication of changes in formula and the need for prior DfE approval; the partner's commitment to continu-
ous product improvement; limitations and responsibilities regarding use of the DfE recognition and logo;
and partnership sunset and opportunity for renewal. A sample partnership agreement, containing all re-
quired elements, appears in Annex A.
3.2 Information and formulation requirements
3.2.1 The applicant shall submit, at a minimum, the complete product formulation information. All in-
gredients shall be reviewed to ensure that the potential environmental and human health effects of prod-
ucts and ingredients are accurately and adequately identified. Applicants must report all ingredients in-
tentionally added to the formulation, regardless of percentage. Known residuals must be reported if pre-
sent at greater than 0.01 percent; see the discussion of residuals in Section 5.13. Applicants must report:
- The intended function or end use of the product or the material;
- The composition of the formulation, including the percent or percent range of each ingredient
in the formulation and its corresponding function;
- A Chemical Abstract Service (CAS) number, functional name, trade designation, and supplier
for each chemical present in the formulation;
- A Material Safety Data Sheet (MSDS) for the product and each ingredient, when available;
- The pH of the finished product, if applicable;
- Effective use concentrations;
- The expected yearly production volume of the end-use product;
- Product performance data;
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- Information on environmental considerations in packaging;
- When available, a list of published and unpublished toxicological studies relevant to the
chemicals and impurities present in the product, component, or material; and
- Any other available supplemental product or ingredient environmental health and safety
information, including biodegradation tests on individual ingredients; acute aquatic toxicity tests
on product as a whole or individual ingredients; and human health and safety tests.
3.2.2 By reviewing the formulation information provided by the applicant, DfE or its designate shall
determine any formulation-dependent contaminants to be evaluated in addition to the product-specific
analytes identified in each product section.
3.3 Renewals
As described in Section A.13 of the Partnership Agreement, DfE partners must renegotiate and renew the
partnership prior to its expiration date (i.e., three years from the date of initiation). As part of the renego-
tiation, DfE will consider the partner's performance under the partnership, including, but not limited to, its
achievement of any continuous improvement targets specified in the agreement. Discussion of green
chemistry innovations and opportunities for formulation improvements will be part of the renegotiations.
3.4 End-user education
Formulators of DfE-recognized products shall provide their end-user(s) with information on environmental,
consumer, and worker safety matters. DfE encourages partners to provide customers with a 16-section
format MSDS as established by the American National Standards Institute (ANSI) standard for prepara-
tion of MSDSs (Z400.1). The partner or its distributor shall offer training on the proper use of the product
(instructions on how to dilute, use and dispose of the product). OSHA, DOT, and other authorities require
manufacturers to provide handling and other worker safety information.
3.5 Compliance
As described in Section A.10 of the Partnership Agreement, partners agree to make available to the
EPA/DfE, on a confidential basis, formulation bills of material (e.g., batch tickets) to confirm that the rec-
ognized products contain the ingredients as described in the Partnership Agreement.
4 Product-level requirements
4.1 Scope
The requirements in this section apply to finished cleaning products, including those in the following
categories: hard surface, glass, degreasers, biological-based cleaning and maintenance, hand soaps,
floor care, carpet care, laundry, dish detergents, marine cleaning, graffiti removers and odor abatement.
4.2 Criteria for all products
4.2.1 Performance
To ensure a baseline measure of performance, the applicant shall make a good faith demonstration that
their products perform effectively. Applicants may submit appropriate test results as specified below or
provide equivalent performance tests agreed upon by DfE.
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Performance testing requirements are product-category specific; any valid and scientifically sound
method of demonstrating product performance shall be accepted. Examples of performance require-
ments that are acceptable to DfE include but are not limited to:
4.2.1.1 Glass cleaners
The product shall meet user requirements for cleaning, streaking and smearing when tested according to
CSPA method DCC-09 or equivalent method agreed upon by EPA DfE.
4.2.1.2 General purpose cleaners
The product shall meet user requirements for soil removal on relevant substrates when tested according
to ASTM method D4488-95, ASTM G122, CAN/CGSB 2-GP-11, Method 20.3 or an equivalent method
agreed upon by EPA DfE.
4.2.1.3 Carpet cleaners/spot cleaners
The product shall meet user requirements when tested according to CSPA DCC-03 and AATCC Test
Method 171-1995 or equivalent method agreed upon by EPA DfE.
4.2.1.4 Washroom cleaners
The product shall meet user requirements for soil removal using ASTM D5343, CSPA DCC-16 or equiva-
lent method agreed upon by EPA DfE.
4.2.1.5 Degreasers
The product shall meet user requirements for soil removal on relevant substrates when tested according
to ASTM method D4488-95, ASTM method G122, CAN/CGSB 2-GP-11, Method 20.3, CSPA DCC-17 or
an equivalent method agreed upon by EPA DfE.
4.2.1.6 Laundry and related products
A consumer pre-wash spotter stain remover shall meet user requirements in CSPA DCC-11 or an equiva-
lent method agreed upon by DfE.
A fabric softener shall meet user requirements in CSPA DCC-13 or an equivalent method agreed upon by
DfE.
A laundry detergent shall meet user requirements in CSPA DCC-14 or an equivalent method agreed upon
by DfE.
4.2.1.7 Oven cleaners
An over cleaner shall meet user requirements in CSPA DCC-12 or an equivalent method agreed upon by
DfE.
4.2.1.8 Hand dish soaps
An hand dish soap shall meet user requirements in CSPA DCC-10 or an equivalent method agreed upon
by DfE.
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4.2.2 pH
To minimize potential for dermal and eye irritation or injury, product pH shall be > 2 and <11.5. Products
with pH < 2 or > 11.5 may be considered for recognition if in vivo assays prove the product is not corro-
sive to the skin or to the eyes.
4.2.3 Life-cycle considerations
4.2.3.1 Energy
DfE encourages the use of energy-saving technologies including the use of concentrates and detergents
that work in cold water. DfE considers energy efficiency by comparing product efficiency to that typical of
the class, recognizing the importance of reducing energy use and generation of Greenhouse Gases. DfE
expects that energy-efficient products would continue to meet the hazard criteria in Section 5.
4.2.3.2 Ozone depleting compounds
DfE-recognized products shall not contain ozone-depleting compounds as defined by the Montreal Proto-
col. (1987) (http://www.epa.gov/ozone/science/ods/index.html)
4.2.5 Labeling requirements
The DfE partner shall provide its customers with information on environmental, consumer, and worker
safety matters. The DfE partner shall also meet OSHA, DOT, and any other authority's requirements to
provide safe handling and other worker safety information, as applicable.
4.2.6 Packaging
DfE encourages the use of environmentally friendlier packaging, and asks partners to describe their ef-
forts in this regard. Use of the tools provided by the Sustainable Packaging Coalition to revamp packag-
ing would be considered a significant effort.
4.2.7 Volatile organic compounds (VOCs), hazardous air pollutants (HAPs), and EPA's Toxic Re-
lease Inventory (TRI)
DfE seeks to minimize the VOC content of partnership products. At a minimum, DfE limits product VOC
content as prescribed by EPA's Office of Air and Radiation, as applicable (see 40 CFR 59, Subpart C).
TRI-listed chemicals or HAPs are not allowed in DfE products.
4.2.8 Flammability
DfE takes note of product flashpoint, as appropriate, and seeks to ensure low concerns for combustibility.
Flashpoint is generally not a concern when dealing with water-based mixtures. Products shall meet the
regulations for flammable liquids, which include:
- 49CFR173.120 (a) (5) - Flammable Liquid Definition
- 49CFR173.150 (e) - Aqueous Solutions of Alcohol
- 40CFR261.21 (a) (1) - Characteristic of Ignitability
4.3 Cleaning systems
A cleaning system, such as a laundry system, is not eligible for recognition unless every component
meets the DfE Criteria. The DfE logo may be used to indicate recognition for the cleaning system, but not
on individual components in the system unless they have independent, end-use applications.
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5 Component-specific requirements
5.1 Scope
The requirements of this section apply to the components of a finished cleaning product. The general
requirements outlined in Section 5.2 will apply to all chemicals unless noted differently in the functional-
class-specific criteria.
5.2 General requirements
The general requirements listed in the DfE General Screen for Safer Ingredients
(http://www.epa.gov/dfe/pubs/projects/gfcp/index.htm), as applied by experts in the DfE Program, are
intended to be a minimum set of criteria all ingredients must meet to be acceptable for use in a DfE-
recognized product. The subsequent sections are additional requirements or exceptions to the general
requirements for specific functional-use ingredient categories.
For every chemical, ingredient data are required for each endpoint to confirm that the ingredient meets
the DfE criteria. Established lists from authoritative bodies, such as the IARC and NTP carcinogen lists,
may be used to screen ingredients, where available and as noted in the criteria below. When an
ingredient is not found on a list, raw data for each endpoint are preferred. Appropriate analog data,
applied via models and expert judgment, may also be used to fill data gaps.
5.2.1 Supplemental Requirements for Components that Appear on Certain Lists of Chemicals of
Potential Concern
If a component appears on one of the following lists of chemicals of potential concern, it will be screened
as described in section 5.2: the California Proposition 65 list, which includes substances the state lists as
causing cancer, birth defects, or other reproductive harm; the list of substances prioritized for testing for
endocrine disruption by the European Commission; and the list of potential sensitizers published by the
Association of Occupational and Environmental Clinics.
5.3 Surfactants
Surfactants shall meet the criteria described in detail in the DfE Screen for Safer Surfactants
(http://www.epa.gov/dfe/pubs/projects/gfcp/index.htm).
5.4 Direct release ingredients
Ingredients that are used in products that are intended for use in applications that result in their immedi-
ate discharge to the environment, so that they bypass sewage treatment or septic systems shall meet the
criteria in the DfE Supplemental Environmental Screen for Safer Direct Release Ingredients.
(http://www.epa.gov/dfe/pubs/projects/gfcp/index.htm)
5.5 Solvents
Solvents shall meet the general requirements in Section 5.2 unless otherwise noted below.
5.5.1 Alcohols, esters, ethylene glycol ethers, and propylene glycol ethers
Solvents classified as alcohols, esters, ethylene glycol ethers, or propylene glycol ethers shall meet the
Solvent Screen criteria described in detail in the DfE Screen for Safer Solvents (phase I).
http://www.epa.gov/dfe/pubs/projects/gfcp/index.htm
5.5.2 d-Limonene
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D-limonene may be used in a DfE-recognized product in concentrations at which the potential oxidation
products may be present at 20 millimoles per liter (mmol/L) or less (corresponding to a limonene concen-
tration of 1.36% or less) in an overall formulation.
5.6 Fragrances
Fragrances shall be evaluated according to the requirements of the DfE Screen for Fragrances (DRAFT).
(http://www.epa.gov/dfe/pubs/projects/gfcp/index.htm)
5.7 Builders
Builders shall meet the general requirements in Section 5.2 unless otherwise noted below.
5.7.1 Chelators
Chelators shall meet the general requirements in Section 5.2. In addition, DfE-recognized products shall
not contain inorganic phosphates that contribute to the process of eutrophication, or NTA, a potential car-
cinogen. Chelators that have MW above 1000 shall be evaluated under the polymer criteria.
5.7.2 Alkalinity boosters, pH adjusters & buffering agents.
Alkalinity boosters, pH adjusters & buffering agents shall meet the general requirements in Section 5.2. In
addition, see the pH restrictions for the formulated product under Section 4.2.2.
5.8 Polymers
Polymers shall meet the general requirements in Section 5.2.
In addition, the following information is required for all polymers:
- molecular weight;
- ratio of each monomer in the polymer, if applicable;
- percent residual monomer;
- percent of polymer with a molecular weight of <1000; and
- percent of polymer with a molecular weight of <500.
Polymers shall not consist of monomers known to cause occupational asthma (for example, diisocy-
anates are used in isocyanate-based polyurethanes).
5.9 Bacteria (spores & vegetative)
Bacteria (spores & vegetative) strains shall be evaluated using complete human health and environ-
mental risk assessments. These risk assessments shall include hazard assessments and exposure to
workers, users and the environment during product use and end-of-life.
5.10 Toxic elements
DfE-recognized products shall not contain toxic elements such as heavy metals. Unavoidable, de minimis
levels may be present, e.g., from inorganic materials mined from the earth.
5.11 Enzyme stabilizers
Enzyme stabilizers shall meet the general requirements in Section 5.2.
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Products containing protease enzymes may conditionally use boric acid as an enzyme-stabilizing mate-
rial.
5.12 Disposable wipes
Disposable wipes shall be demonstrated to be compostable or flushable as formulated.
DfE considers wipe composition and ability to decompose under mesophilic conditions (20-45°C) as key
characteristcs for disposable cleaning wipes when they are the intended method of application for a
cleaning formulation. At a minimum, wipes shall be made entirely of compostable material (ASTM D5338-
98).
As an alternative to testing, companies may have their suppliers submit a certificate of analysis, showing
that the wipe is made of natural, compostable materials.
To be flushable, a disposable wipe must pass through the toilet and drainline system, be transported in
wastewater conveyance systems, and be compatible with wastewater treatment systems where they ex-
ist, or in some regions, discharges of untreated wastewater. An example of an acceptable test protocol is
the Guidance Document for Assessing the Flushability of Nonwoven Consumer Products, published by
INDA, the U.S.-based association of nonwoven fabrics industry and EDANA, the European-based inter-
national association serving the nonwovens and related industries.
5.13 Residuals
Residuals of concern shall be limited to less than 0.01% (by weight) or 100ppm in the formulation. For
ingredients known to contain residuals of concern, DfE's goal will be to limit those residuals to the lowest
practicable levels. Dilution will not be considered in calculating the percentage of residuals in concen-
trates. Formulators should understand that residuals may be present and should encourage chemical
manufacturers to carefully monitor and control processes to limit residuals of concern. [Note: DfE is work-
ing to ascertain whether the state of green chemistry can support the restrictions imposed by this section.]
5.14 Other ingredients
The following ingredients shall meet the general requirements in Section 5.2.
Cross-Linkers
Solubility enhancers
¦ Hydrotropes
¦ Small Amines
Bleaching agents
Preservatives/Antioxidant
Rheology Modifiers
Plasticizers
Foam Boosters, Defoamers and Antifoamers
Denatu rants
Absorbents and Adsorbents
Corrosion inhibitors
Antiredisposition agent
Dispersing agent
Coalescing agent
Dyes & Optical Brighteners
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6 Use of the mark
6.1 Terms of use
6.1.1 The partner may use the DfE logo, shown below, on containers or container packaging of Qualify-
ing Products or on advertising related solely to these products, provided that EPA/DfE has reviewed and
approved the intended use of the logo. The partner shall not use the logo or describe EPA/DfE's recogni-
tion on any general company materials, non-Qualifying Products or associated literature, or advertising
not related to the Qualifying Products. The partner is not permitted to use the EPA official seal or logo at
any time.
6.1.2 Use of the DfE logo must be accompanied by the following informational tagline, in close prox-
imity to the logo: "Recognized for Safer Chemistry." The tagline should also include the EPA Web ad-
dress, www.epa.gov/dfe, as shown below. Additionally, the partner shall include in advertising of the
Qualifying Products an endorsement disclaimer and various educational information for the consumer
regarding the DfE partnership. The partner and EPA/DfE shall work to find an appropriate place (e.g.
company Web site) connected with advertising for the Qualifying Products to include the following lan-
guage along with educational information:
EPA/DfE recognition does not constitute endorsement of this product. The Design for the Environment
logo signifies that the formula for this product, as «Company_Name»
has represented it to the EPA, contains ingredients with more positive health and envi-
ronmental characteristics than conventional cleaners. EPA/DfE relies solely on
«Company_Name», its integrity and good faith, for information on the composition, ingre-
dients, and attributes of this product. EPA/DfE has not independently identified, i.e., via
chemical analysis, the ingredients in the product formula, nor evaluated any of
«Company_Name»'s non-ingredient claims. EPA/DfE expresses its judgment and pro-
fessional opinion only as to the environmental and human health characteristics of the
product, based on currently available information and scientific understanding.
6.1.3 The partner and EPA/DfE acknowledge that under 5 C.F.R. §2635.702(c), EPA may not endorse
the purchase or sale of commercial products and services provided by the partner. The Parties agree to
ensure that promotional materials describing or resulting from this Agreement do not contain statements
implying that EPA/DfE endorses the purchase or sale of commercial products. This includes statements
to the public in news releases, publications, on web sites or any other media.
6.1.4 The partner shall make available to EPA/DfE for review and approval any materials, including
press releases, promotional materials and advertisements that the partner develops in connection with
the partnership, and especially information that describes or characterizes the DfE Formulator Program or
EPA/DfE's position on issues related to the cleaning product sector.
6.1.5 The partner shall discontinue use of the DfE logo or any other form of EPA/DfE recognition, within
30 days, under the following circumstances: If the partner stops formulating the Qualifying Products us-
ing the agreed-upon ingredients; upon the termination of this Agreement; or, if so notified by EPA in writ-
ing.
6.2 Examples of appropriate use of the EPA/DfE certification mark
Example 1:
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U.S. EPA
Recognized for Safer Chemistry
www.epa.gov/dfe
Example 2:
Recognized for Safer Chemistry
www.epa.gov/dfe
U.S. EPA
7 Profiler requirements
Candidates for DfE recognition must use the services of a qualified third party profiler to prepare product
recognition applications. To become a qualified third party profiler the candidate must submit a paper
application to provide evidence of competency against the requirements in Sections 7.1 and 7.2, and un-
dergo the pilot review described in Section 7.3.
7.1 Elements of technical competence
The profiler shall have the skills, experience, and resources to perform chemical hazard assessments.
7.1.1 Staff
A profiler shall have the appropriate personnel to perform hazard assessments. Staff shall include chem-
ists, biologists, toxicologists, or others with science/technical backgrounds.
7.1.2 Assessment and interpretation abilities
A profiler shall establish the ability to assess and interpret diverse toxicological and other health and envi
ronmental information. This shall include maintaining appropriate staffing; a track record as a data re-
viewer; experience as a standards developer, or certifier to standards or criteria. The profiler shall meet
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the criteria of International Standards Organization (ISO) 65 to demonstrate a commitment to maintaining
these capabilities.
7.1.3 Access and management of hazard information
A profiler shall establish the ability to access and manage chemical, health and environmental hazard
information, including fluency with chemicals at the structural level. This shall be indicated by appropriate
staffing, with chemical and information technology expertise; protocol and equipment for data searching,
storage and retrieval; relevant experience and work products.
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7.1.4 Use of estimation models and software
A profiler shall demonstrate skill at using EPA and other physical-chemical and environmental estimation
models and software. This shall be indicated by involvement with EPA's Sustainable Futures Program;
submission of Sustainable Futures Premanufacture Notices; relevant experience and work products.
7.1.5 Secure handling of proprietary business information
A profiler shall have the appropriate systems and procedures in place to ensure the protection of all pro-
prietary business information obtained through the review process for this program.
7.2 Elements of credibility and good standing
The profiling organization must be able to establish neutrality, trustworthiness, and reliability.
7.2.1 A profiler shall demonstrate a commitment to objectivity and due process approach by meeting
the criteria of ISO 65.
7.2.3 A profiler shall demonstrate familiarity with DfE Formulator review process and assessment
methodology by having training and interacting with DfE and companies interested in DfE recognition.
7.2.4 A profiler shall demonstrate a track record of high performance. This shall be supported by testi-
monials from clients and others in a position to evaluate performance.
7.3 Pilot review requirements
7.3.1 As the final step in the process the profiler shall demonstrate competency through a review of a
formulation(s) judged by DfE to be representative of those recognized by the program. DfE will review
the results against the criteria in this section and determine whether the applicant has demonstrated
competence.
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Annex A
Partnership Agreement
PARTNERSHIP AGREEMENT
BETWEEN
«COMPANY»
AND
U.S. ENVIRONMENTAL PROTECTION AGENCY
DESIGN FOR THE ENVIRONMENT PROGRAM
A.1 Statement of purpose
The purpose of this Partnership Agreement ("Agreement") is to set forth the basis, terms, and goals of
the Design for the Environment ("DfE") voluntary partnership between «Company» ("«Company_Name»")
of «City_State_Zip_» and the U.S. Environmental Protection Agency ("EPA"). The partnership is part of
the DfE safer chemical use initiative for commercial formulators. The basic goal of the initiative is to seek
and promote innovative chemical products, technologies, and practices that benefit human health and the
environment.
A key purpose of the partnership program is to recognize and encourage the formulation of products
with environmentally preferable chemistry. For the purpose of this Agreement, these products include the
following «Company_Name» products: «Trade_Names» (the "Qualifying Products"). The partnership will
strive to promote and advance the environmental, technological, and efficiency benefits of these and fu-
ture Qualifying Products.
This Agreement describes in general terms how «Company_Name» formulates the Qualifying Prod-
ucts, their environmental and human health benefits, and how «Company_Name» and EPA/DfE will work
together to continually improve the health and environmental profile of the Qualifying Products and edu-
cate the consumer on these improvements and the DfE Program.
A.2 Statement of context and challenge
Each year, commercial formulators use billions of pounds of chemical ingredients to make a wide va-
riety of general purpose and specialized cleaning products. EPA is concerned about the effect certain
chemicals might have on environmental quality and on the health and safety of workers and the public
who use cleaning products or may come in contact with them.
EPA believes that cleaning product formulators can improve the environmental and health profile of
their products by using ingredients that are inherently less toxic, less environmentally persistent, less bio-
accumulative, and that degrade to substances with similar desirable characteristics when compared to
ingredients in some conventional formulations. Additional benefits can be derived through environmen-
tally oriented reformulation. Energy efficiency, resource conservation, and sound management practices
offer important additional components for measurable and sustainable improvement in cleaning products
and programs.
EPA believes that conventional cleaning formulations, especially those for industrial/institutional ("l/l")
use, may rely on certain ingredients whose environmental and human health profiles can be improved.
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A.3 «Company_Name»'s improved cleaning chemistries
In conjunction with the DfE review process, «Company_Name» has reformulated a set of cleaning
products for l/l cleaning and maintenance that, according to «Company_Name», meet EPA/DfE's rec-
ommendations and offer improved health and environmental characteristics. These Qualifying Products
contain no (e.g. inorganic phosphates, hazardous solvents, or environmentally harmful surfactants). In-
stead, they use a proprietary blend of (e.g. surfactants, solvents, pH adjustors, and other ingredients),
which exhibit more positive environmental and human health characteristics than conventional cleaning
formulations.
In addition, these Qualifying Products only use surfactants that biodegrade readily to non-polluting
substances, which helps relieve stress on the environment, especially threats to aquatic life. By not in-
cluding environmentally harmful builders or extreme pH in these formulations, the environment-friendly
profile and safety characteristics of these products is further enhanced. For example, an inorganic phos-
phate-free formula may promote a better balance of nutrients in the environment and healthier fresh water
bodies. Safer sequestrants biodegrade readily to non-hazardous compounds and protect against envi-
ronmental loading of metals. Mild pH formulas help protect workers, the environment, and building infra-
structure. (For more information on the attributes and benefits of these products, see Section 7.)
Please Note: EPA/DfE relies solely on «Company_Name», its integrity and good faith, for information
on the composition, ingredients, and attributes of its Qualifying Products. EPA/DfE has not independently
identified, i.e., via chemical analysis, the ingredients in the submitted formulas, nor evaluated any of
«Company_Name»'s non-ingredient claims. EPA/DfE expresses its judgment and professional opinion
only as to the environmental and human health characteristics of the Qualifying Products, based on cur-
rently available information and scientific understanding. «Company_Name»'s obligations under any
federal, state, or local regulations governing the company or these products are in no way altered by its
partnership with EPA/DfE.
A.4 «Company_Name»'s commitment to formulate for the environment
As part of the «Company_Name»-EPA/DfE partnership, «Company_Name» agrees to formulate and
produce the Qualifying Products using agreed upon ingredients which have a more positive health and
environmental profile than conventional formulations. To preserve the non-confidential nature of this
document, a generic description of the ingredients in the Qualifying Products and their key characteristics
appears below.
As documentation of the Qualifying Products at the time of this Agreement, and to set a baseline for
future improvements and formula changes, «Company_Name» has provided to EPA/DfE the specific and
complete chemical composition for these products. This section's ingredient-by-ingredient descriptions
are intended to serve as surrogates for the actual formulas. «Company_Name» reserves the right, how-
ever, to change ingredients, provided that their health/environmental profile is equal to or better than
those in the current formulations and that any substitution occurs in consultation and agreement with
EPA/DfE (see Section 11).
If any change is made to the agreed formulation, «Company_Name» agrees to notify EPA/DfE of the
change and provide the new formulation. EPA/DfE agrees to notify «Company_Name» of the need for
ingredient profiling and will make recommendations for changes to the formulation as needed in order to
remain a Qualifying Product.
The following is a non-confidential representation of the ingredients in the Qualifying Products, with
their key characteristic (including green chemistry status or areas identified for future improvement), as
evaluated by EPA/DfE:
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Ingredient Key Evaluation Characteristic
«Product_Name»
e.g. Surfactant Readily biodegradable, low concerns for byproducts. Meets DfE
Screen for Surfactants.
Solvent Low health and environmental concerns.
Builder Low health and environmental concerns.
Colorant Could be improved (see sec. 5)
Adoption and use of the formulations described in this Agreement does not preclude, nor should it
impede, «Company_Name» in its efforts to further improve the health and environmental profile of the
Qualifying Products. In fact, a main element of the «Company_Name»-EPA/DfE partnership is to provide
«Company_Name» the opportunity to work with EPA chemists, environmental scientists, and risk reduc-
tion staff in investigating materials to further improve the health and environmental profile of its Qualifying
Products.
A.5 Continuous environmental improvement
«Company_Name» agrees to make continuous environmental improvement an important element of
its research and development activities related to its Qualifying Products. In addition to the environmen-
tally oriented formulations set forth in Section 4, «Company_Name» agrees to investigate the feasibility of
making additional improvements in the environmental and health profile of the Qualifying Products. Spe-
cifically, «Company_Name» agrees to consider use of an alternative preservative and colorants, as rec-
ommended by EPA/DfE. «Company_Name» agrees to undertake this formulation review during the pe-
riod of the Agreement
«Company_Name» may consult with EPA/DfE about other products and, following EPA/DfE review
and assessment, may request that one or more new Qualifying Products be added to this Agreement.
With EPA/DfE's approval, this Agreement may be amended as set forth in Section 11 to include new
Qualifying Products.
«Company_Name» and EPA/DfE agree to discuss on a yearly basis the status of
«Company_Name»'s reformulation research and continuous improvement activities related to the Qualify-
ing Products. «Company_Name» may, at any time, request consultation and technical assistance from
EPA in determining which chemical ingredients possess more positive health/environmental characteris-
tics. «Company_Name» may use informational materials from DfE's website, for example, the DfE For-
mulator Program: A Discriminating and Protective Approach to Cleaning Product Review and Recognition
(http://www.epa.gov/dfe/pubs/formulat/formulator_review1 .pdf), as general guides to environmentally de-
sirable attributes for cleaning products.
A.6 Formulator right to know
Cleaning product formulators have a right to know the properties and potential risks - to their em-
ployees, customers, and communities - of the chemicals they use. Manufacturers of raw materials for
detergents and other cleaning products should ascertain and communicate the properties and potential
toxicity of their products, especially those made and sold in large quantities.
As part of its partnership with EPA/DfE, «Company_Name» agrees to ask its raw material suppliers
for test data on the chemicals they sell and that «Company_Name» uses in its products. If the raw mate-
rial suppliers do not have test data on their chemicals, «Company_Name» agrees to encourage them to
perform basic physico-chemical and toxicity testing. Upon request by EPA/DfE, «Company_Name»
agrees to share with EPA/DfE any available chemistry or toxicity information on its ingredients that it ob-
tains from its suppliers.
To help ensure that any new testing serves to enhance the profile and general understanding of a
particular chemical, all prospective studies should be considered in the context of the guidance offered in
EPA's High Production Volume Challenge Program (http://www.epa.gov/chemrtk/volchall.htm) and the
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Screening Information Data Set (SIDS) Program of the Organization for Economic Co-operation and De-
velopment (OEDC) (to learn more, visit http://www.epa.gov/oppt/chemtest/oecdsids.htm and the SIDS
Test Guidelines at http:www.epa.gov/chemrtk/sidsappb.htm).
A.7 User benefits
«Company_Name»'s Qualifying Products offer users the following set of benefits:
Environmental protection
The Qualifying Products are formulated with the environment and human health strongly in mind and use
the following types of ingredients: biodegradable surfactants, with byproducts that are less toxic than the
parent compound; solvents that are not hazardous air pollutants and pose no threat to the Earth's ozone
layer; fragrances that have been screened for potential hazardous and persistent ingredients; and other
components with a more positive environmental profile than in conventional cleaning products.
Worker/consumer safety
The Qualifying Products are also formulated to help ensure a safer workplace. Users of these products
benefit from ingredients that include no components that pose serious hazards. This benefit is amplified
for janitors, maintenance staff, housekeepers, and others who must use cleaning chemicals in confined
spaces on a daily basis. Importantly, a safer health profile especially benefits children, who spend a large
part of their day in indoor environments and can be particularly sensitive to the chemicals in some clean-
ing products. Also, the mild pH, low volatility, and low potential to catch fire enhance the safety profile of
these products.
Resource conservation
The Qualifying Products also have certain attributes that may significantly reduce wear and tear on sub-
strates, fabrics, and other surfaces with which the products come in contact, thereby extending their us-
able life.
Customer education
«Company_Name» acts as a product steward by providing its customers information on environmental
and worker safety matters and trains its sales force on the benefits of formulations with improved envi-
ronmental and health characteristics.
«Company_Name» agrees to inform customers of Qualifying Products about the «Company_Name»-
EPA/DfE partnership, the meaning of the DfE logo, and the DfE Program's role in helping to protect hu-
man health and the environment. «Company_Name» agrees to make available to its customers an
EPA/DfE contact to who they may direct questions or comments on the partnership.
A.8 EPA recognition and support
«Company_Name» may use the Design for the Environment (DfE) logo, shown on Attachment A to
this Agreement, on containers or container packaging of Qualifying Products or on advertising related
solely to these products, provided that EPA/DfE has reviewed and approved the intended use of the logo.
«Company_Name» agrees to not use the logo or describe EPA/DfE's recognition on any general
«Company_Name» materials, non-Qualifying Products or associated literature, or advertising not related
to the Qualifying Products. «Company_Name» is not permitted to use the EPA official seal or logo at
any time.
Use of the DfE logo must be accompanied by the following informational tagline, in close prox-
imity to the logo: "Recognized for Safer Chemistry." The tagline should also include the EPA web ad-
dress, www.epa.gov/dfe, as shown on Attachment A. Additionally, «Company_Name» agrees to include
in advertising of the Qualifying Products an endorsement disclaimer and various educational information
for the consumer regarding the DfE partnership. «Company_Name» and EPA/DfE agree to work to find
an appropriate place (e.g. company website) connected with advertising for the Qualifying Products to
include the following language along with educational information:
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EPA/DfE recognition does not constitute endorsement of this product. The Design for the
Environment logo signifies that the formula for this product, as «Company_Name» has
represented it to the EPA, contains ingredients with more positive health and environ-
mental characteristics than conventional cleaners. EPA/DfE relies solely on
«Company_Name», its integrity and good faith, for information on the composition, ingre-
dients, and attributes of this product. EPA/DfE has not independently identified, i.e., via
chemical analysis, the ingredients in the product formula, nor evaluated any of
«Company_Name»'s non-ingredient claims. EPA/DfE expresses its judgment and pro-
fessional opinion only as to the environmental and human health characteristics of the
product, based on currently available information and scientific understanding.
The Parties acknowledge that under 5 C.F.R. §2635.702(c), EPA may not endorse the purchase
or sale of commercial products and services provided by «Company_Name». The Parties agree to en-
sure that promotional materials describing or resulting from this Agreement do not contain statements
implying that EPA/DfE endorses the purchase or sale of commercial products. This includes statements
to the public in news releases, publications, on web sites or any other media.
«Company_Name» agrees to make available to EPA/DfE for review and approval any materials, in-
cluding press releases, promotional materials and advertisements that «Company_Name» develops in
connection with the partnership, and especially information that describes or characterizes the DfE For-
mulator Program or EPA/DfE's position on issues related to the cleaning product sector.
«Company_Name» agrees to discontinue use of the DfE logo or any other form of EPA/DfE recogni-
tion, within 30 days, under the following circumstances: If «Company_Name» stops formulating the
Qualifying Products using the agreed upon ingredients; upon the termination of this Agreement; or, if so
notified by EPA in writing.
A.9 Limitations
All commitments made by EPA in this Agreement are subject to the availability of appropriated
funds and budget priorities. Nothing in this Agreement, in and of itself, obligates EPA to expend appro-
priations or to enter into any contract, assistance agreement, interagency agreement, or incur other finan-
cial obligations. This Agreement does not exempt «Company_Name» or any other organization from
EPA policies for competition for financial assistance agreements or procurement contracts.
«Company_Name» agrees not to submit a claim for compensation for services rendered to EPA in con-
nection with any activities it carries out in furtherance of this Agreement. Any endeavor involving reim-
bursement or contribution of funds between the parties to this Agreement will be handled in accordance
with applicable laws, regulations, and procedures, and will be subject to separate agreements.
This Agreement does not create any right or benefit, substantive or procedural, enforceable by
law or equity against «Company_Name» or EPA/DfE, their officers or employees, or any other person.
This Agreement does not direct or apply to any persons outside «Company_Name» or EPA.
A.10 Measures of success
On an annual basis, «Company_Name» agrees to provide to EPA/DfE its best estimate of the pro-
duction volume of the Qualifying Products (if possible, both in aggregate pounds or gallons and broken
out by ingredient class).
At EPA's request, «Company_Name» agrees to make available to EPA/DfE, on a confidential basis,
formulation bills of materials that confirm that the Qualifying Products contain the ingredients agreed to in
this Agreement or have been modified in accordance with its terms.
«Company_Name» agrees to make reasonable attempts to monitor the cleaning product market and
agrees to inform EPA/DfE about the Qualifying Products' influence on the market, including growth in
sales and number of new customers, as well as the perceived value in DfE recognition.
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«Company_Name» agrees to report on customer acceptance of and satisfaction with these products
when this information is available.
As discussed in Section 5, «Company_Name» agrees to furnish periodic updates to EPA on the con-
tinuous improvement component of its research and development activities and on its ongoing efforts to
improve the health/environmental profile of the Qualifying Products. As a condition of partnership,
«Company_Name» has demonstrated to EPA/DfE the performance of its Qualifying Products according
to the guidelines provided by DfE (http://www.epa.gov/dfe/pubs/formulat/formulator_review1.pdf).
«Company_Name» agrees to also share with EPA/DfE the results of any additional performance testing
or verification when that information becomes available.
A.11 Confidentiality
In matters relating to this DfE partnership and Agreement, EPA agrees to handle all information
claimed by «Company_Name» as confidential business information in accordance with EPA confidential-
ity procedures (see 40 CFR part 2, subpart B). EPA and «Company_Name» agree that information sup-
plied to EPA by «Company_Name» on the formulas of any «Company_Name» products is covered by the
foregoing sentence.
EPA/DfE agrees to only use the information provided by «Company_Name» for purposes related to
the «Company_Name»-EPA/DfE partnership and disclose the information only to EPA employees and
EPA contractors cleared for confidential information with a specific need to know.
A.12 Amendments to the agreement
As discussed in the Continuous Environmental Improvement section, «Company_Name» may re-
quest that EPA/DfE add new Qualifying Products to this Agreement when reformulated. If EPA agrees to
the addition, «Company_Name» may amend the Agreement by submitting a letter that addresses the es-
sential elements from Sections 3, 4, 5 and 7 of the current Agreement. «Company_Name» and EPA/DfE
agree to collaborate in developing the specific language for the amendment, which must be signed by an
appropriate official for both parties. All other provisions of the Agreement shall be incorporated by refer-
ence.
A.13 Termination or renewal of the agreement
Either party may, upon written notification, terminate this Agreement. In any event, the terms and
provisions in the Agreement will sunset three years from the date of signature, unless the parties renego-
tiate and renew a partnership agreement prior to the expiration date.
We agree to these terms and provisions:
For «Company» For the U.S. Environmental Protection Agency
Signatory Robert E. Lee II
Title Director, Economics, Exposure, and
Technology Division
Date Date
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