What Is California SB 258? A Guide to Cleaning Product Ingredient Disclosure
By Angela WheelerPublished
California SB 258, the Cleaning Product Right to Know Act of 2017, is the state law that requires manufacturers of cleaning products sold in California to disclose what their products contain — in full on a public website, and in part on the product label. Its requirements were added to the California Health and Safety Code starting at section 108950, the online disclosure has applied since January 1, 2020 and the label disclosure since January 1, 2021, and both reach any company whose products are sold in California, wherever that company is based.
Three things to take from it:
- SB 258 is a transparency law, not a hazard communication law. It sits alongside OSHA HazCom and California's Proposition 65, it replaces neither, and a Safety Data Sheet does not satisfy it.
- It creates two separate obligations — an online disclosure and a label disclosure — with different content rules and different effective dates. Meeting one does not meet the other.
- The 0.01 percent (100 ppm) threshold is narrower than most people assume. It governs nonfunctional constituents and fragrance allergens, not intentionally added ingredients in general.
What Is California SB 258?
SB 258, formally the Cleaning Product Right to Know Act of 2017, requires manufacturers of certain cleaning products to publicly disclose the ingredients those products contain. It was signed into law on October 15, 2017, and made California the first state to enact a law requiring ingredient disclosure for cleaning products. Nearly a decade later, it remains one of the most detailed ingredient transparency laws a US manufacturer will encounter.
Unlike a Safety Data Sheet, which is built around workplace hazard communication under OSHA HazCom (29 CFR 1910.1200), SB 258 is a consumer- and worker-facing transparency law. It exists because, at the federal level, there is still no requirement that cleaning product manufacturers disclose every intentionally added ingredient on a label — which is why the law continues to catch companies that assume federal HazCom compliance is enough.
Who Has to Comply With SB 258?
SB 258 applies to manufacturers of "designated products" sold in California. Under the law, the manufacturer is the entity whose name appears on the product label, or the entity the product is manufactured for or distributed by under the federal Fair Packaging and Labeling Act.
A designated product is a finished product in one of these categories:
- Air care products
- Automotive products
- General cleaning products
- Polishes and floor maintenance products used primarily for janitorial, domestic or institutional purposes
If your product falls into one of these categories and is sold in California, SB 258 applies to it — regardless of where your company is headquartered. Our cleaning products page covers the SDS side of the same product portfolio.
SB 258's Two Disclosure Requirements
SB 258 sets out two separate obligations, with two separate effective dates and two separate sets of rules. Manufacturers frequently satisfy one and miss the other.
Online Disclosure (Required Since January 1, 2020)
For each covered product, the manufacturer's website must carry:
- Every intentionally added ingredient, listed in descending order of predominance by weight. Ingredients below 1 percent by weight may follow the others in any order.
- Nonfunctional constituents present at or above 0.01 percent (100 ppm). These are incidental components, breakdown products or manufacturing byproducts rather than ingredients added on purpose, and the statute limits the term to a specific set of named substances. 1,4-dioxane has a lower threshold of 0.001 percent (10 ppm), and a nonfunctional constituent that is Proposition 65-listed and triggers a Proposition 65 warning must also be listed.
- Fragrance allergens listed in Annex III of EU Cosmetics Regulation 1223/2009 that are present at or above 0.01 percent, along with fragrance ingredients that appear on a designated list.
- The CAS (Chemical Abstracts Service) number for each listed ingredient and constituent, or "not available" where none exists and "withheld" where the ingredient is confidential business information.
- The functional purpose of each intentionally added ingredient.
- Electronic links to the designated lists, grouped together in a single location, for any listed ingredient, constituent or fragrance allergen that appears on one.
- A link to the product's Safety Data Sheet.
Ingredient names are not free-form, either. SB 258 sets a naming hierarchy that starts with the CSPA Consumer Product Ingredients Dictionary or INCI and falls back to IUPAC nomenclature and other systems in a fixed order.
Label Disclosure (Required Since January 1, 2021)
Product labels must carry ingredient information too, but manufacturers can choose between two compliance paths:
- Option A: List the intentionally added ingredients that appear on one of the law's designated lists — more than 20 state, federal and international hazard lists — plus any EU Annex III fragrance allergens present at or above 0.01 percent.
- Option B: List every intentionally added ingredient in the product. Under this option, fragrance ingredients and colorants can be grouped under generic terms such as "fragrance" or "colorant" rather than named individually.
If the label does not have room for full ingredient information, manufacturers can direct consumers to a website or toll-free number, or use a QR code or other electronic link, instead.
Does SB 258 Require Disclosure of Every Ingredient Above 0.01 Percent?
No, and the misconception runs in both directions. The 0.01 percent threshold applies to two things specifically: nonfunctional constituents in the online disclosure, and fragrance allergens. It is not a general cutoff for intentionally added ingredients.
Intentionally added ingredients follow different rules in each place. Online, there is no concentration threshold at all — every intentionally added ingredient must be disclosed unless it qualifies as confidential business information. On the label, which intentionally added ingredients appear depends on the path chosen: designated-list ingredients under Option A, or all of them under Option B.
What Are SB 258's Designated Lists?
SB 258 does not invent its own hazard classification system. Instead, it references more than 20 existing lists — sometimes called the "list of lists" — including California's Proposition 65 list of chemicals known to cause cancer or reproductive toxicity, the California Priority Chemicals list, and international references such as the Oslo-Paris Convention's list of Chemicals for Priority Action. An intentionally added ingredient on any of these lists triggers disclosure requirements and cannot be withheld as confidential.
Proposition 65-listed ingredients had a later compliance runway: intentionally added ingredients on that list did not have to be disclosed on the label or online until January 1, 2023. If that is relevant to your formulation, check that your Proposition 65 warning label and your SB 258 disclosure are aligned.
Can Ingredients Be Withheld as Confidential Business Information?
Some can, within limits. SB 258 allows an intentionally added ingredient to be withheld as confidential business information when it qualifies — for example, where EPA has approved a claim for it on the TSCA Confidential Inventory, or where it is protected as a trade secret. A withheld ingredient still appears in the online disclosure, with "withheld" in place of its CAS number, so the redaction is visible.
Confidentiality is not available for an ingredient on a designated list, for a nonfunctional constituent, or for an EU Annex III fragrance allergen present at or above 0.01 percent. For the ingredients most likely to draw attention, withholding is not an option.
How SB 258 Connects to Workplace SDS Obligations
SB 258 also amended California Labor Code Section 6398.5. Employers already required to keep Safety Data Sheets readily accessible to employees must now also make the manufacturer's online ingredient disclosure available in the workplace.
The link runs the other way too: the online disclosure itself must link to the product's SDS. If you already maintain an SDS library for HazCom compliance, the SB 258 workplace requirement is a natural extension of it rather than a separate system.
How SB 258 Differs From HazCom, Proposition 65, FHSA and SB 312
SB 258 is easy to confuse with the other rules that apply to the same product. Each occupies its own lane:
- OSHA HazCom (29 CFR 1910.1200) governs workplace hazard communication through Safety Data Sheets and workplace labels. An SDS is built around hazardous ingredients and is not a full ingredient list, which is the gap SB 258 fills.
- Proposition 65 is a warning law. It requires a warning where exposure to a listed chemical occurs; SB 258 requires the listed ingredient itself to be disclosed. The two need to agree.
- FHSA (16 CFR 1500) is the federal law governing cautionary labeling on hazardous household products. A cleaning product sold at retail in California can need FHSA cautionary labeling and SB 258 ingredient disclosure on the same package.
- SB 312, the Cosmetic Fragrance and Flavor Ingredient Right to Know Act of 2020, covers fragrance and flavor ingredient reporting for cosmetic products specifically. If your portfolio spans cleaning and cosmetic product lines, you are managing two distinct disclosure obligations, not one.
SB 258 Compliance Checklist
- Confirm whether each product falls within the designated product categories.
- Build and maintain a public ingredient disclosure page for each product, covering intentionally added ingredients, nonfunctional constituents at or above 0.01 percent (0.001 percent for 1,4-dioxane), fragrance allergens, CAS numbers and functional purpose.
- Add grouped links to the relevant designated lists and a link to each product's SDS on the disclosure page.
- Choose a label compliance path — designated-list ingredients plus fragrance allergens, or the full intentionally added ingredient list — and apply it consistently.
- Review any confidential business information claims against the ingredients that cannot be withheld.
- Cross-check Proposition 65-listed ingredients against your existing warning labels.
- Confirm that your SDS accessibility process also covers the SB 258 workplace disclosure requirement.
- If you sell both cleaning and cosmetic products in California, verify SB 312 obligations separately.
Frequently Asked Questions
Does a Safety Data Sheet satisfy SB 258?
No. A Safety Data Sheet is a workplace hazard communication document under OSHA HazCom, built around the hazardous ingredients an employer and employee need to know about. SB 258 is a transparency law that requires every intentionally added ingredient to be disclosed online, along with CAS numbers, functional purpose and certain nonfunctional constituents. The two are connected — the SB 258 online disclosure must link to the product's SDS — but neither document substitutes for the other.
Does SB 258 apply if our company is not based in California?
Yes. SB 258 applies to designated products sold in California, not to companies located there. If your air care, automotive, general cleaning, polish or floor maintenance product is sold in California, the online and label disclosure requirements apply to it, wherever your company is headquartered.
When did SB 258's requirements take effect?
SB 258 was signed on October 15, 2017. The online disclosure requirements apply to designated products sold in California on or after January 1, 2020, and the label disclosure requirements apply on or after January 1, 2021. Intentionally added ingredients on the Proposition 65 list had a later date, January 1, 2023. All of these dates have now passed, so every covered product on the California market is expected to comply in full.
What is a nonfunctional constituent under SB 258?
A nonfunctional constituent is an incidental component of an intentionally added ingredient, a breakdown product of one, or a byproduct of the manufacturing process that has no functional or technical effect on the product. SB 258 limits the term to a specific set of substances named in the statute. Those substances must be disclosed online when present at or above 0.01 percent (100 ppm), with a lower threshold of 0.001 percent (10 ppm) for 1,4-dioxane.
Is SB 258 the same as SB 312?
No. SB 258, the Cleaning Product Right to Know Act of 2017, covers cleaning and related products and requires public disclosure online and on the label. SB 312, the Cosmetic Fragrance and Flavor Ingredient Right to Know Act of 2020, covers cosmetic products and requires reporting of certain fragrance and flavor ingredients to the state. A company selling both product types in California manages two separate obligations.
Getting SB 258 disclosure right
SB 258 compliance is not a one-time task. Every reformulation, supplier change or new product can change what the online disclosure and the label have to say, which makes it an ongoing coordination job between your formulation data, your SDS authoring process and your public-facing web content.
The disclosures stay current when they are generated from the same ingredient and classification data as the Safety Data Sheet — and drift out of date when each is maintained on its own. Getting the underlying ingredient and hazard classification data right at the source makes both far easier to keep accurate.
Quantum SDS has authored Safety Data Sheets since 1985 — for manufacturers, importers and distributors across North America. Contact our SDS authoring services for help with your safety data sheet writing.
This article is general information, not legal or compliance advice. Its regulatory references were verified in September 2026; always consult the current text of the Cleaning Product Right to Know Act for complete requirements.
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