Changes to the Standard to Implement the Safer Choice Label

2/10/15

Implementation of a New Label for the DfE Safer Product Labeling Program and Supporting 

Modifications to the DfE Standard for Safer Products, now to be known as the “Safer Choice 

Standard,” including the Designation of a Fragrance-Free Label

This document explains several important changes to EPA’s Safer Product Labeling Program 

(SPLP), as well as a number of conforming changes to the program’s Standard for Safer 

Products, including: a new label1and name for the EPA SPLP; an associated fragrance-free 

label; and related changes to the standard that qualifies products for the label. With this 

document EPA is finalizing the new label for immediate use. While effective immediately, the 

Agency is requesting comment on the other changes described in this document, including a

new, optional fragrance-free certification.

Redesigned Label

The EPA Design for the Environment (DfE) Safer Product Labeling Program has redesigned its 

label to better communicate the program’s human health and environmental protection goals,

increase consumer and institutional/industrial purchaser understanding and recognition of 

products bearing the label, and encourage innovation and the development of safer chemicals and 

chemical-based products. The label’s new name “Safer Choice,” with the accompanying 

wording (or “tagline”) “Meets U.S. EPA Safer Product Standards” (which is part of the label),

and design were developed over many months based on input and feedback from a diverse set of 

stakeholders and the general public. 

This input and feedback included more than 1700 comments on EPA’s website, six consumer 

focus group sessions in three geographic markets, and a national online survey. EPA gave 

considerable weight to consumer and stakeholder feedback in tailoring and selecting the new 

label, to ensure that the Agency achieved, and continues to achieve, its redesign goals. 

(Summaries of the focus group sessions and online survey results are available at 

www.epa.gov/saferchoice/ [insert full link].)

As part of the newly named Safer Choice Program, the new label will be implemented through 

a small family of labels, with very similar content, design and color, but tailored for partnership 

types and product end-users. Presented here are: the primary label, intended for use on consumer 

products; the label for industrial and institutional products; and the new fragrance-free label. 

 

1 Because many stakeholders use the terms “label” and “logo” interchangeably, for the purposes 

of this document, EPA will use these two terms as synonyms. The DfE label means the 

certification provided to product manufacturers under the program’s standard and might refer to 

any of the three new logos described in this document. 
2

Please note that EPA is not making any changes to the requirements that must be met to qualify 

for partnership and use of the new Safer Choice label.

For consumer products (primary mark):

For institutional and industrial products: 

For fragrance-free products:

 

The Fragrance-free Label. 

Health and environmental stakeholders have expressed the need for products that are certified to 

be fragrance-free products for individuals with fragrance allergies or sensitization concerns. In 

response to these needs, EPA developed an option for a fragrance-free label that would allow 

purchasers to identify fragrance-free products and know that the claim has been verified by a 

trusted source. When presented with a fragrance-free concept in the Agency’s focus group 

sessions on the label redesign, consumers clearly felt a fragrance-free label would be useful and 

thought it filled an important need in the marketplace. Product manufacturers also responded 

favorably, stating that it would help them serve a small but significant subset of consumers. 
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Manufacturers of fragrances indicated that fragrance-free products could serve those individuals

with concerns for fragrances.

With this document, EPA is introducing a fragrance-free certification as a companion to the new 

Safer Choice label. EPA recognizes that consumers, institutional purchasers and product 

manufacturers care about the use of fragrances in cleaning, personal care and other products. At 

the same time, we know that many fragrance materials may be associated with sensitization and 

allergenic responses and lack toxicological data. Note that the term “fragrance” refers to a 

formulated product that contains multiple scent and other chemicals (e.g., carriers, stabilizers and 

preservatives), while “fragrance materials” are solely the scent and masking components in the 

fragrance. 

If a product qualifies for the Safer Choice label and does not use any fragrance materials, as 

defined below, the program will allow the manufacturer to add a “fragrance-free” notation to the 

Safer Choice label. In the world of non-fragranced products, two descriptive terms are 

commonly used on labels: “Unscented” and “Fragrance-free.” Unscented generally means that, 

while fragrance materials are not used to impart a scent, a product may contain chemicals that 

neutralize or mask the odors of other ingredients. Fragrance-free means that neither fragrance 

materials nor masking scents are used in the product. EPA is using the broader “fragrance-free” 

designation with its Safer Choice label to help ensure that consumers and purchasers seeking to 

avoid exposure to fragrance chemicals can identify and select such products.

Fragrance-free certification. To qualify for the program’s fragrance-free label, a product must 

first meet all requirements in the Safer Choice Standard and safer ingredient criteria. EPA will 

review the product ingredients to ensure that the product contains no fragrance materials. The 

fragrance-free certification will mean that: 1) the product only contains ingredients on or eligible 

for the Safer Chemical Ingredients List (SCIL)—the program’s list of ingredients that meet our

safer chemical criteria and are generally acceptable for use in Safer Choice labeled products—

and 2) the product does not contain chemicals on the International Fragrances Association 

(IFRA) Transparency List of fragrance chemicals intended to impart or mask a scent2. Product 

manufacturers and fragrance professionals regard the IFRA Transparency List as the 

comprehensive list of materials used by perfumers and the fragrance industry. 

It is important to note that products that qualify for the DfE fragrance-free certification may still 

have an odor and not be on the IFRA Transparency List. Some product ingredients, such as 

surfactants or solvents, carry an odor. Only chemicals recognized as having dual functionality—

e.g., that are intentionally used as a solvent and/or as a fragrance—would be ineligible for use in 

products seeking the fragrance-free certification. EPA will work with manufacturers on a caseby-case basis to determine whether a chemical has “dual functionality.” 

Submission of Comments. If you have comments on the changes described in this 

document, please submit them to the EPA docket: EPA-HQ-OPPT-2015-0047. While your 

 

2 EPA is developing a list of fragrance chemicals that are acceptable for use in Safer Choice 

labeled products (that would not be certified as fragrance-free). The list will be a subset of the 

IFRA Transparency List.
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comments are welcome on any aspect of the program addressed in this document, we ask 

that you especially consider commenting on the new fragrance-free label. All changes 

described in this document are effective immediately, but we will consider additional 

changes to the program based on your comments, as appropriate.

__________________

The Safer Choice Standard. As a result of the label redesign and recent program developments

EPA is making a number of changes to the Standard, described below.

Changes to the Safer Choice Standard

Title page: To reflect the program’s new label, the title of the standards document will change 

from “EPA’s DfE Standard for Safer Products (DfE Standard)” to “EPA’s Safer Choice

Standard” (formerly, the ‘DfE Standard for Safer Products’

3

).

Sec. 2.1 Definitions

To align the Standards with the Interim Fragrances Criteria4, the definition of “Fragrance 2.1.37”

and “Fragrance raw material 2.1.38” will be deleted and replaced by a new definition for 

“Fragrance Materials 2.1.37.” The original definitions, dating from the first iteration of the 

Standard (2009), were overly broad. Since then, EPA has worked extensively on fragrances and 

with the fragrance industry to enhance its understanding of this industry. The revised definition

will read as follows:

Sec. 2.1.37 Fragrance materials: Discrete substances obtained by chemical synthesis or derived

from a natural source and present in a fragrance at any level. Fragrance materials are materials 

whose function is to impart or mask a scent and may include chemicals with dual functionality—

scent and another function. (This definition does not include auxiliary materials such as solvents 

and preservatives that do not function as a fragrance or to mask a scent.)

 

3

For the purposes of institutional procurement requirements, state green purchasing specifications, etc., the Safer 

Choice label is equivalent to the DfE Safer Product label. Note that the logo for institutional products includes 

“DfE” in the web address to provide continuity with the previous name.

4 DfE’s Interim Fragrances Criteria (PDF) clarify which fragrance chemicals may be used in DfE products and 

provide a level and consistent set of requirements for DfE Formulator Partners and manufacturers of 

fragrances. Under the interim criteria, listed carcinogens, mutagens, or reproductive/developmental 

toxicants (CMRs); listed persistent, bioaccumulative, and toxic compounds (PBTs); and listed respiratory 

sensitizers are not allowed. To advance transparency, product manufacturers must disclose dermal 

sensitizers. Non-fragrance materials present in fragrance formulations will be evaluated under their 

appropriate DfE functional class criteria (e.g., solvents).
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Sec. 3 General Requirements: 

A new section entitled “Fragrance-free Label” is being added, to read as follows:

Sec. 3.9 Fragrance-free Label

For products that qualify for the Safer Choice label, manufacturers may request an additional 

certification—the Fragrance-free label—to indicate that a product contains no fragrance

materials. To qualify as fragrance-free, a product must only contain ingredients on or eligible for 

the Agency’s Safer Chemical Ingredients List (SCIL)—the list of ingredients that meet the Safer 

Choice safer chemical criteria and are acceptable for use in labeled products. The ingredients 

must not include fragrances materials. Fragrance materials with dual functionality, including use 

as a fragrance, are not allowed in fragrance-free products.

Sec. 4.2.2.1 Concentrates in closed dilution-controlled systems

The program allows labeling of concentrated products that exceed the normal pH limits (2 to 

11.5) if they otherwise comply with the Standard, are used in closed dilution-controlled systems,

and meet the other safeguards in this provision. Without the dilution-controlled system and other 

safeguards, these products would represent a corrosivity and handling hazard. Using the safer 

choice label on the package of such products would be inappropriate and might confuse users 

regarding the proper handling practices. Consequently, a new subsection e) will be added to

address label use, to read as follows: 

e) the label is not used on the product (or packaging) when it is a concentrate (but may be used 

in promotional materials). 

Sec. 4.5 Products Designed for Dermal Contact

Some products that meet EPA’s Safer Product Standard may also be subject to other agencies’

statutes and laws, such as those products designed for dermal contact. Two sentences, therefore,

will be added to the end of the first paragraph to underscore the applicability of existing laws, to 

read as follows:

... It is important to note that compliance with the terms of this section does not alter a company’s 

obligations under the Federal Food, Drug, and Cosmetic Act and the Fair Packaging and Labeling 

Act, as applicable. If a product qualifies for the label under sec. 4.5, it may need to carry a statement 

that indicates that FDA has not reviewed the product under this provision.

Sec. 5.6 Fragrances

Introduced in the 2012 enhancements to the Standard, version 2.1 of the Criteria for Fragrances 

is not being implemented because of difficulties that have arisen in applying the criteria. 

Numerous attempts among manufacturer partners, manufacturers of fragrances, and the program 
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to implement the criteria revealed the likely root cause: the unavailability of human and 

environmental health information. Consequently, the program will leave in place the Interim 

Fragrances Criteria5and references to the version 2.1 criteria will be deleted from the Standard. 

Also, to further unify our approach to the review of fragrances, the program is aligning across 

product types the requirements applied to labeled products that contain sensitizers that exceed 

the de minimis level (0.01%) in the end-use product. Specifically, we will apply the approach for 

consumer products, as it currently appears in the Standard, to all products, and most notably,

requiring notice for sensitizers that exceed the de minimis level, preferably on the product label. 

As a result, sections 5.6.1 and 5.6.2 will be combined to read as follows:

Sec. 5.6.1 Sensitizers in Labeled Products

Each fragrance material that is a skin sensitizer is limited to no more than 0.01% in the final 

product. EPA will allow manufacturers to use a skin sensitizer at a higher level in certain limited 

situations.

Notwithstanding the provisions in section 3.8 on ingredient communication for fragrances, the 

final product may contain sensitizers if the manufacturer discloses on the product label each 

sensitizing ingredient present in the final product at greater the 100 ppm and provides evidence 

to EPA that the fragrance (or its ingredients) are:

 critical to the fragrance essence or product identity;

 otherwise in compliance with the fragrances criteria6;

 the subject of good faith explorations of alternatives; and 

 subject to a monitoring system that would alert the Agency if a user reports any adverse 

effects from the product.

Alternatively, the manufacturer may demonstrate that the formulated product does not cause a 

sensitization response through appropriate testing (see test methods listed in Master Criteria) and 

limit the amount of fragrance materials in the product to the level in the test sample.

Sec. 6 Use of the Mark

This section contains multiple editorial changes, to conform to the new Safer Choice name and 

logo, as stated below. Sec. 6.2 contains illustrations of the three new logos, geared to product 

class: 1) consumer; 2) institutional and industrial; and 3) fragrance-free.

 

5

See footnote no. 4.

6 See footnote no. 4.
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Sec. 6.1 Terms of Use

Sec. 6.1.1 The partner may use the Safer Choice logo, as shown in sec. 6.2, on containers or 

container packaging of products that qualify for the label (“qualifying products”) or on 

advertising related solely to these products, provided that EPA has reviewed and approved the 

intended logo use. The partner shall not use the logo or describe EPA’s recognition on any 

general company materials, non-qualifying products or associated literature, or advertising not 

specific to the qualifying products. The partner is not permitted to use the EPA official seal or 

logo at any time.

Sec. 6.1.2 Use of the Safer Choice label must include the EPA web address, 

www.epa.gov/saferproducts, as shown in sec. 6.2. Additionally, when advertising the qualifying 

products or informing consumers about them, the partner must include the endorsement 

disclaimer, which appears below. The partner and EPA shall work to find an appropriate place 

to include the disclaimer (e.g., the company’s web site) connected with advertising the qualifying 

products.

EPA/Safer Choice recognition does not constitute endorsement of this product. The 

Safer Choice logo signifies that the product’s formula, as [company name] has 

represented it to the EPA, contains ingredients with more positive human health and 

environmental characteristics than conventional products of the same type. EPA/Safer 

Choice relies solely on [the company name], its integrity and good faith, for information 

on the product’s composition, ingredients and attributes. EPA/Safer Choice has not 

independently identified, that is, via chemical analysis, the ingredients in the product 

formula, nor evaluated any of [the company name’s] non-ingredient claims. EPA/Safer 

Choice provides its evaluation only as to the product’s human health and environmental 

characteristics, as specified in the Standard and based on currently available information 

and scientific understanding. 

Sec. 6.1.3 The partner and EPA acknowledge that under 5 C.F.R sec. 2635.702(c), EPA will not 

endorse the purchase or sale of the partner’s commercial products and services. The partner 

agrees to ensure that promotional materials describing or resulting from the partnership 

agreement do not contain statements implying that EPA endorses the purchase or sale of 

commercial products or services.

Sec. 6.1.4 The partner shall make available to EPA/Safer Choice for review and approval any 

materials, including press releases, promotional materials, and advertisements, the partner 

develops in connection with the partnership, and especially information that describes the Safer 

Choice program or characterizes the program’s position on issues related to a specific product 

sector.
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Sec. 6.1.5 The partner must discontinue use of the Safer Choice logo or any other EPA/Safer 

Choice recognition within 30 days under the following circumstances: If the partner stops 

formulating the qualifying product(s) using the agreed-on ingredients; on the termination of the 

partnership agreement; or, if so notified by EPA in writing. 

Sec. 6.2 Illustrations of the EPA/Safer Choice Certification Mark

For consumer products (primary mark):

For institutional and industrial products: 

For fragrance-free products:

The Partnership Agreement. Section 8 of the Agreement will be revised to read as follows:

[Company name] may use the appropriate Safer Choice 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/Safer Choice has reviewed and approved the 

intended use. [Company name] agrees to not use the logo or describe EPA/Safer Choice 

recognition on any general [Company name] materials, non-Qualifying Products or associated 
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literature, or advertising not specific to the Qualifying Products. [Company name] is not 

permitted to use the EPA official seal or logo at any time.

Use of the Safer Choice logo must be accompanied by the program web address--

www.epa.gov/dfe/saferproducts—in close proximity to the logo, as shown in Attachment A. 

Additionally, when advertising the qualifying products or informing consumers about them, [the 

Company name] must include the endorsement disclaimer, which appears below. [The Company 

name] and EPA shall work to find an appropriate place to include the disclaimer (e.g., the 

company’s web site) connected with advertising the qualifying products.

Insert disclaimer language and remaining provisions as they appear in sec. 6.2, above.

Miscellaneous

The words “Design for the Environment” or “DfE” have changed to “Safer Choice” or simply 

“the program.” 

To better align the Standard with the program’s mission to facilitate the adoption of source 

reduction by businesses and improve the human health and environmental profile of a broad 

range of products, use of the word “cleaning” has been deleted, as appropriate, throughout the 

document. The term “cleaning,” as in “cleaning product,” is too narrow to represent the breadth 

of labeled products under the program.