American Cleaning Institute

American Cleaning Institute January 2015

Table of Contents Required Components... 3 ACI Principles for Sustainability... 3 ACI Sustainability Metrics Program... 4 Sustainability Procedures and Activities... 5 Operating Rules... 8 Commitment... 8 Verification... 8 Program Boundary... 9 Membership Status... 9 Delinquencies... 10 Appendix A: Glossary... 11 Appendix B: Sustainability Procedures and Activities... 12 Essential SPAs... 12 Additional SPAs... 16 Appendix C: ACI-Related Production... 18 Appendix D: Consumer Product Ingredient Communication Initiative... 20 1 P a g e

American Cleaning Institute Charter for Sustainable Cleaning The American Cleaning Institute (ACI) Charter for Sustainable Cleaning ( Charter ) is a common, voluntary approach of the cleaning products industry to promote and demonstrate continual improvement in the industry s sustainability profile. ACI defines sustainability as the ability to improve the quality of life for this and future generations, by creating products that promote hygiene and cleanliness, are environmentally sound, and are economically successful. ACI s sustainability mission is to benefit society and improve the quality of life through hygiene and cleanliness by driving sustainability improvements across our industry and throughout the supply chain. This Charter is one aspect of fulfilling this mission. The Charter exists as a guideline for best practices in sustainability and consists of three required components: 1. Charter companies must formally commit to the ACI Principles for Sustainability. 2. Charter companies must participate in ACI s Metrics Program. 3. Charter companies must work toward implementing a set of Essential Sustainability Procedures and Activities (SPAs), which apply to the design, raw material use, manufacture, consumer use, and disposal of products and packaging, to become members of the Charter. The Charter, which is designed to go beyond basic legal requirements, provides a framework for driving the industry toward common sustainability goals. It requires companies to have systems in place for continual assessment, review, and improvement of sustainability performance, including raw material selection, resource use, and occupational health and safety, at every important stage of the product lifecycle. These are captured in the Charter SPAs. The fact of doing regular assessment and review, and ensuring proper information handling and training, should automatically stimulate and bring about improvement. The SPAs take into account best management practices for the different product lifecycle phases as defined in ISO 14000 (primarily concerned with environmental management ) and similar standards, plus certain other schemes and guidelines specific to the industry, such as the A.I.S.E. Charter for Sustainable Cleaning and the American Chemistry Council s Responsible Care program. By participating in the Charter, companies will have a means of demonstrating their commitment to continuous improvement of key aspects of sustainability relative to the cleaning product supply chain. The improvements can occur at all stages of the product lifecycle, from product specification through manufacturing, to end-use and disposal of products and packaging. ACI will implement the Charter in the spirit of ongoing and open dialogue with all interested parties. The Charter will evolve over time as experience develops and feedback is obtained. Definitions of terms used in this document can be found in Appendix A. 2 P a g e

Required Components 1. Formally Commit to the ACI Principles for Sustainability Definition of Sustainability The ability to create products providing hygiene and cleanliness, in a manner that is environmentally sound, socially responsible and economically viable, without compromising the ability of future generations to meet their needs. Principles for Sustainability The members of the American Cleaning Institute strive to align business practices with the following principles: 1. Protect human health and the environment against undesirable impacts 2. Optimize use of the planet s resources across all phases of a product s lifecycle 3. Govern our businesses with integrity, responsibility, and transparency 4. Develop innovative products that contribute to the long term value of the industry 5. Enhance the health and quality of life of our society APPROVED BY THE ACI BOARD OF DIRECTORS: January 30, 2015 3 P a g e

2. Participate in the annual ACI Sustainability Metrics Program The Sustainability Metrics Program is an initiative of the American Cleaning Institute to report a common set of industry-wide sustainability metrics relevant to both its packaged goods and ingredient supplier members. The goal of the initiative is to publicly report data that drives sustainability performance improvements across the industry. The results are used to gain insight to trends within the industry and are published in ACI s public Sustainability Report. The value of this project increases with additional industry participation. Metrics are reported by individual companies through a secure website with ongoing protection of confidentiality by an outside contractor and aggregated to reflect the cleaning product related industry as a whole. Collected Metrics: Energy Use Greenhouse Gas Emissions Water Use Waste Generation The above metrics are collected for U.S. Cleaning Product related production in facilities (manufacturing, research and development, office) under the operational control or significant influence of a participating company for a given time period. Metrics may be reported on either a company-wide or per-facility basis for product sold on the U.S. market irrespective of the location of production. Total production (weight of finished product, excluding packaging) and the percent of production which is related to ACI-related products are necessary to report in order to normalize the data. Member companies are responsible for data quality, so companies are asked to document methodologies used to collect data in a clear and complete manner and be consistent from year-to-year in the inclusion or exclusion of any input, output, or activity for tracking purposes. Once submitted through the webbased tool, ACI s third-party vendor assesses all data for gaps and errors.. A strong support system is in place to guide members through the reporting process. Metrics Training Webinars are held annually prior to the start of the collection process to inform participants of any updates to the protocol and provide guidance on using the online reporting tool. The ACI Sustainability Metrics Protocol outlines the guidelines of the collection process and provides additional details about the program. This document is updated annually. 4 P a g e

3. Implement Sustainability Procedures and Activities The Sustainability Procedures and Activities (SPAs) detailed in this Charter are set forth as best practices for continual assessment, review, and improvement of sustainability performance at important stages of the product lifecycle. Implementation of these procedures can be a starting point for a company to begin to address key issues in product manufacturing and work toward becoming a sustainable business. As a part of the commitment to the Charter, companies must work toward implementing a set of Essential SPAs and self-certify annually that progress is being made. SPAs are cataloged as either Essential or Additional. Essential SPAs are the key focus of the certification. A Committed Company must be working toward implementation of all Essential SPAs. Additional SPAs are currently not a requirement of the Charter but provide companies additional opportunities for improving their sustainable performance. Additional SPAs will be evaluated by ACI for inclusion as Essential SPAs over time. The guiding principles of the SPAs are listed below. The detailed requirements of each SPA can be found in Appendix B. Essential Raw Material and Packaging Selection: Select raw materials and packaging with consideration of the three pillars of sustainability over the full lifecycle of the product Occupational Health and Safety: Understand the occupational health and safety impacts and ensure risks are effectively controlled Manufacturing Environmental Management: Monitor and understand the environmental impacts of operation Internal Target Setting: Set internal targets for improving the company s sustainability performance Finished Product Safety Evaluation: Ensure products are safe for consumers /customers use Ingredient Communication: Provide consumers with information about the ingredients found in products Post-Market Surveillance System: Monitor products in the marketplace as a basis for continual improvement Product Recall System: Maintain a system for the recall of products in the event that faults become evident Additional Life Cycle Thinking: Minimize burden shifts throughout the supply chain by engaging in the application of lifecycle thinking Supplier Selection: Select suppliers who are similarly working to improve the sustainability of their own operations Resource Management: Seek to use key resources more efficiently 5 P a g e

Packaging Design: Design packaging in a way that seeks to improve the environmental profiles of those products and their packaging Distribution Safety: Ensure products are safe throughout the distribution chain and facilitate the flow information along the supply chain Contract Manufacturers and Co-Packers: Work with contract manufacturers and co-packers to ensure the same standard of sustainability is being upheld Consumer Education: Provide consumers with information around the sustainable use of cleaning products and help consumers achieve the best cleaning results and best product performance SPA requirements are also distinguished based on company type. A Cleaning Product Formulator, or a company whose main cleaning product business is related to formulation of cleaning products (e.g., laundry detergents, hand soaps) is required to implement a different set of SPAs than an Ingredient/Packaging Supplier, or a company whose main cleaning product business is related to supplying packaging or ingredients used in the production of cleaning products (e.g., surfactants, enzymes, builders). The requirements for each group are detailed below. Cleaning Product Formulator Essential SPA - Raw Material and Packaging Selection - Occupational Health and Safety - Manufacturing Environmental Management - Product Recall System - Finished Product Safety Evaluation - Post-Market Surveillance System - Internal Target Setting - Ingredient Communication Additional SPA - Supplier Selection - Resource Management - Packaging Design - Distribution Safety - Consumer Education - Life Cycle Thinking - Contract Manufacturers and Co-Packers Ingredient/Packaging Supplier Essential SPA - Raw Material and Packaging Selection - Occupational Health and Safety - Manufacturing Environmental Management - Internal Target Setting Additional SPA - Supplier Selection - Resource Management - Packaging Design - Distribution Safety - Life Cycle Thinking - Contract Manufacturers and Co-Packers 6 P a g e

Responsible Care Equivalence Ingredient suppliers may fulfill many aspects of the Charter by operating under the guidelines of Responsible Care. In order to accommodate such companies, ACI has determined that the SPAs listed below are satisfied by the Responsible Care Commitment. In order to utilize this equivalence, Committed Companies must identify their Responsible Care Commitment and self-certify implementation of the Responsible Care Commitments. Essential SPA o Occupational health and safety o Manufacturing Environmental Management o Internal Target Setting Additional SPA o Distribution Safety 7 P a g e

The Charter is open to any ACI Member Company: Operating Rules - manufacturing and/or placing on the market in the U.S. soaps, detergents or cleaning products for either household, commercial, institutional, or industrial use, as illustrated in Appendix C - manufacturing and/or placing on the market in the U.S. ingredients or packaging for soaps, detergents or cleaning products for either household, commercial, institutional, or industrial use as illustrated in Appendix C Commitment The first step in becoming a charter member is Commitment. Companies wishing to participate in the Charter program must first sign the Charter Commitment Letter which includes a commitment to the ACI Principles for Sustainability, participation in the ACI Sustainability Metrics Program, and implementation of the Essential SPAs. At the time of commitment, a company must be making progress toward implementation of all Essential SPAs and submitting current data for at least one Metric to the ACI Metrics Program with the intent to reach full compliance within 5 years. Full compliance with the Charter includes implementing all Essential SPA for 100% of cleaning product-related production and submitting metrics data for 4 basic indicators (Energy, GHG, Water, Solid Waste) on an annual basis. Commitment letters are to be signed by an appropriate company executive and should denote a company contact for communication regarding all aspects of the Charter. Commitment letters are accepted on a yearly basis, with a deadline of May 1 each year. For letters received after May 1, commitment will begin the following calendar year. A company in good standing needs only to submit the letter once. An original copy of the signed letter should be sent to the address below: Melissa Bernardo The American Cleaning Institute 1331 L Street, NW, Suite 650 Washington, DC 20005 Once a commitment letter is received, a company officially becomes a Committed Company of the Charter. The Commitment is only applicable to the production of cleaning products and related materials. Verification Verification that a company is making progress toward the SPAs is completed through company selfcertification. Committed Companies are required to submit the applicable SPA Self-Certification Form on an annual basis. Specific Self-Certification Forms are available for cleaning product formulators and ingredient/packaging suppliers. On the Form, Committed Companies are asked to identify the progress they have made toward implementation of the SPAs. The self-certification should be signed by a company employee responsible for overseeing the implementation of the SPAs (Sustainability Manager, EHS Manger, Senior Research Analyst, etc.). The Form may be submitted via email to sustainability@cleaninginstitute.org or Fax to (202) 347-4110. The annual deadline for submission of this form is November 1 st. 8 P a g e

Program Boundary ACI s Charter for Sustainable Cleaning includes in its program boundary operations connected with cleaning products marketed in the United States. This includes cleaning products and their associated ingredients and packaging materials manufactured in or imported into the U.S. Other chemicals used during cleaning product production are also considered by ACI to be within the program boundary. (Appendix C) Because companies may not be able to account for all of its relevant operations, particularly in the early years of Charter membership, committed companies are responsible for determining their individual reporting boundary within the overall boundary of the Charter. Because this approach provides some flexibility, it is important that once set, the companies maintain a consistent boundary from year-to-year in accordance with the guidelines set forth by the program boundary. The boundary must also be consistent between each element of the Charter (i.e., the reporting boundary for metrics should be the same as the reporting boundary for SPAs). Committed companies are expected to provide data for operations associated with cleaning products marketed in the U.S. over which member companies exert operational control. Operational control is defined as those facilities and impacts over which the member company exerts control or significant influence, and should be determined in accordance with the Global Reporting Initiative s (GRI) Boundary Protocol. Mergers, Acquisitions, Divestures, and Site Openings/Closings The impact of mergers or other changes affecting the operations of the company should be taken into account during the first full year the change is in effect. Committed companies who undergo such changes can be granted additional time as needed to fulfill their Charter commitment throughout the business. This determination will be made on an individual basis. Membership status The membership status of each company joining the Charter will be defined by the four criteria listed below. Companies will be notified any time the status of their Charter membership changes. Committed: A company with committed status has officially joined the Charter by signing the Charter Commitment Letter. Member in good standing: This status is assigned to a Committed Company who has successfully met all requirements of the Charter and is currently in good standing. Probationary: Probationary status is assigned to a Charter Member Company when a key deadline or requirement of the Charter has been missed. A Company assigned Probationary status is required to submit an action plan to ACI describing the steps being taken to meet the commitments of the Charter. Probationary status will be reviewed annually. Delinquent: A Charter Member Company who has had a probationary status for two (2) consecutive years or has failed to submit an action plan to ACI following receipt of probationary status is assigned the status of delinquent. Delinquent companies will no longer be publically recognized as a Charter Member Company. Use of the Charter logo will be suspended. Reinstatement: Companies with Delinquent status wishing to be reinstated as a Charter Member must wait one year after such status is received to re-commit. Said company must re-submit the 9 P a g e

Charter Commitment Letter and complete all applicable requirements before being reinstated as a Member in good standing. Delinquencies As Members of the Charter, companies are expected to uphold the requirements set forth within. In such case that a Member Company does not uphold said requirements of their commitment the following actions will be taken as described below. Self-Certification not received: In the case such that the self-certification form is not received by the yearly deadline, company contacts will first be notified via email of the deficiency. Said company will be given 30 days to fulfill the request to submit the missing materials. If the required material has not been received before the 30 day deadline has passed, the company s membership status will be changed to Probationary. Metrics not submitted: In the case such that metrics are not received by the yearly deadline, said company will be unable to meet the requirement of the Charter for the corresponding year. Submissions of metrics data are not accepted past the annual deadline. In such case, the company s membership status will be changed to Probationary. Metrics submitted do not meet required threshold level: In the case such that a company fails to meet the applicable threshold for metrics participation, said company s membership status will be changed to Probationary. SPA threshold not met: In the case such that a company fails to meet the applicable threshold for implementation of Essential SPAs, said company s membership status will be changed to Probationary. Action Plan not received: In the case such that a company with Probationary status fails to submit an action plan to ACI within 60 days of the request, said company s membership status will be changed to Delinquent. 10 P a g e

APPENDIX A: GLOSSARY Sustainability Procedures and Activities (SPAs) Best Practices for continual assessment, review, and improvement of sustainability performance at important stages of the product lifecycle, including, for example, raw material production, product manufacturing, distribution, product use, end-of-life. Essential SPAs Sustainability Procedures and Activities that are mandatory for all Charter companies to implement. Additional SPAs Practices that are not mandatory for Charter membership but can be included in Charter company certifications if progress has been made toward their implementation. Additional SPAs will be evaluated by ACI for inclusion as Essential SPAs over time. Charter Commitment Letter Letter signed by each Charter company committing to the Charter requirements. Consumer Product Ingredient Communication Initiative Voluntary program for manufacturers of air care, automotive, cleaning, and polishes and floor maintenance products to communicate ingredients in their products. See Appendix D. Formulator ACI member company whose main cleaning product business is related to formulation of cleaning products (e.g., laundry detergents, hand soaps) Metrics Program American Cleaning Institute program that gathers, compiles, aggregates, and summarizes U.S. multi-company data to create a multi-year sustainability profile of key performance indicators for manufacturing facilities supplying the U.S. cleaning product market. Principles for Sustainability American Cleaning Institute Board-approved principles for advancing human health and environmental quality, social well-being, and economic growth. Supplier ACI member company whose main cleaning product business is related to supplying packaging or, ingredients (e.g., surfactants, enzymes, builders) used in the production of cleaning products Sustainability The ability to improve the quality of life for this and future generations, by creating products that promote hygiene and cleanliness, are environmentally sound, and are economically successful. Sustainability Metrics Protocol Protocol that provides detailed questions and background information on collecting and reporting environmental metrics from companies participating in the ACI Metrics Program. Sustainability Report Report issued by ACI to the public and interested parties that includes aggregated data for specific metrics using the data received from individual companies in ACI s Metrics Program. 11 P a g e

APPENDIX B: SUSTAINABILITY PROCEDURES AND ACTIVITIES The following table details Sustainability Procedures and Activities (SPAs), which apply to the design, raw material use, manufacture, consumer use, and disposal of products and packaging. The table also includes Additional SPAs, which address areas where some but not all Charter companies have activities that support the overall objective of the Charter and may be reported on by Charter companies in their certification. ACI will periodically conduct a review of the Additional SPAs, with the goal of phasing these in as Essential SPAs over time. Essential Sustainability Procedures & Activities I. Raw Material and Packaging Selection (Formulators & Suppliers) Charter Companies will work to continually improve raw material selection, balanced across the three sustainability pillars (social, economic and environmental) by the following actions: 1. Setting and reviewing specifications for individual raw materials that optimize environmental benefits in sourcing and ensure efficient and reliable processing and formulation into products. 2. Selecting raw materials in a way that looks to establish safety through Raw Material Risk Assessment by carrying out a risk-based assessment. 3. Managing risks to human health and the environment by favoring ingredients: a. Where the margins of safety are wide b. Which are readily biodegradable c. Which do not bio-accumulate 4. Endeavoring to use, bearing in mind lifecycle management principles, a. Recycled materials where these materials are available b. Materials with superior environmental profiles where available. II. Occupational Health and Safety (Formulators & Suppliers) Charter companies must establish, document, implement, maintain and continually improve an Occupational Health and Safety Management System (OHSMS) in relation to their manufacturing activities. The OHSMS, which will be appropriate to the nature and scale and occupational health and safety impacts of their activities, products and services, will ensure that: 1. Hazards arising from within their manufacturing activities that may have a significant impact on occupational health and safety are identified and risk assessments are made; 2. Significant occupational health and safety risks that are identified are eliminated or controlled effectively; 12 P a g e

3. Emergency situations and potential accidents that may impact occupational health and safety have been identified and procedures to prevent or mitigate such impacts are in place and are periodically tested and reviewed; 4. Senior management review takes place at planned intervals and assesses opportunities for improvements and changes to the policy, system, objectives and targets. III. Manufacturing Environmental Management (Formulators & Suppliers) Charter companies must establish, document, implement, maintain and continually improve an Environmental Management System (EMS) in relation to their manufacturing activities. The EMS, which will be appropriate to the nature and scale and environmental impacts of their activities, products and services, will ensure that: 1. Significant environmental aspects of the company s operation that may adversely impact the environment are identified, including but not limited to those for which ACI collects metrics (i.e., energy use, water use, solid waste generation, greenhouse gas emissions); 2. Objectives and targets for those environmental aspects are set and documented, a program to achieve those objectives and targets is in place, internal monitoring is conducted, roles and responsibilities are defined and documented, and objectives and targets are adjusted, as appropriate; 3. Relevant employees are trained and competent for the tasks they perform; 4. Operations that are associated with identified significant environmental aspects are planned to ensure that they are carried out under specified conditions; 5. Emergency situations and potential risk areas that may impact the environment have been identified and procedures to prevent or eliminate associated environmental impacts are in place and periodically tested and reviewed; 6. Procedures are in place to: a. Identify environmental impacts b. Regularly monitor and measure the identified environmental impacts c. Periodically evaluate compliance with legal, regulatory and other relevant requirements d. Control non-conformities and take corrective and preventive actions e. Maintain appropriate records. 7. Senior management review takes place at planned intervals and assesses opportunities for improvements and changes to the policy, the system, objectives and targets. IV. Product Recall System (Formulators) Charter companies must establish and maintain control arrangements for the recall of products that have been distributed in the event that faults become evident. These arrangements will ensure that: 1. Criteria are defined and communicated to all relevant personnel to require them to raise an alarm with designated persons should a fault that may require a recall be discovered; 13 P a g e

2. Charter companies communicate with their suppliers their duty to notify the Charter company and have appropriate contact information should they become aware of faults that may cause the Charter company s products to pose a likelihood of injury, cause gross dissatisfaction, be considered out of specifications or be unacceptable in terms of legal compliance; 3. The Charter company responds quickly and decisively to manage any required product recall so as to minimize or eliminate the likelihood of injury to: a. consumers and the local community b. customers or other trade partners c. employees d. the company s reputation and its shareholders; and 4. Suspect and retrieved stock can be securely isolated until disposal arrangements are in place. V. Finished product safety evaluation (Formulators) Charter companies must establish and maintain control arrangements for the safety evaluation of their products to ensure that they are safe for consumers/customers to use. The safety evaluation should include optional devices and/or personal protection equipment to reduce exposure to the (end) user. This requirement supplements the safety evaluation of individual ingredient and addresses the safety of the formulated product, including its physical form, its mode of use and its packaging. The safety evaluation shall, before the product is put on the market: 1. Evaluate the safety of the product in terms of foreseeable misuse and accidents as well as intended use; 2. Verify that the product has been appropriately labeled, and where applicable, packaged in accordance with the relevant transport regulations. VI. Post-Market Surveillance System (Formulators) Charter companies shall establish a policy of receiving and reviewing experience of their products on the market as a basis for continual improvement in sustainability, including minimizing risks to human health and the environment. Specifically, companies shall include in this policy the following aims: 1. A consumer care-line facility available via a toll-free number (and/or an email address or online response service) to receive inquiries, comments and complaints from consumers about the products and their performance and acceptability. This facility should be operated under procedures which will ensure that: a. Inquiries are appropriately answered, and complaints are investigated and a suitable response made b. Reference is made to suitably qualified or responsible persons as necessary or legally required c. Inquiries, comments and complaints are logged in appropriate detail to provide a basis for review and corrective action or improvement 2. A procedure for acquiring and reviewing available information on accidents with the products, for example as made available via Poison Control Centers A procedure for organizing and reviewing all available feedback, whether from routine use, failures, accidents or emergencies as a basis for continual improvement. 14 P a g e

VII. Internal Target Setting (Formulators & Suppliers) Charter companies shall establish a set of internal targets for improving the company s sustainability performance. These targets should cover the metrics categories used in the ACI Metrics Project where feasible, plus any other metrics which the company considers relevant to its internal processes. Targets shall be reviewed at least annually. VIII. Ingredient Communication (Formulators) All household cleaning products made by Charter companies shall comply with the Consumer Product Ingredient Communication Initiative. (Appendix D) 15 P a g e

Additional Sustainability Procedures and Activities (SPAs) I. Supplier Selection (Formulators & Suppliers) Charter companies will work to continually improve the raw materials and packing materials it selects, balanced across the three sustainability pillars, by selecting suppliers for raw materials for their products who are similarly working to improve the sustainability of their own operations. Charter companies shall favor suppliers who: 1. Have occupational health and safety control arrangements in place to guarantee the safety and welfare of their workforce and that they comply with all legal requirements in this area 2. Have environmental management systems in place to ensure that the impact on the environment from their manufacturing operations are appropriately managed and minimized and that they comply with the relevant legal requirements in this area 3. Have policies in place to address the wider impacts of their activities and to promote continual improvement II. Resource Management (Formulators & Suppliers) Charter companies must establish and maintain management systems that continually improve sustainability, balanced across the three sustainability pillars, by using more efficiently the key resources used in their own production process and in the use of their products. III. Packaging Design (Formulators & Suppliers) Whilst packaging should clearly fulfill its essential functions, including consumer acceptance, Charter companies shall design packaging and select packaging materials for their products in a way that seeks to improve the environmental profile of those products and their packaging across their lifecycles. The packaging system design and material selection shall seek to: 1. Minimize packaging volume and weight 2. Minimize environmental impacts and improve sustainability of the complete packaging system (i.e., primary, secondary and tertiary packaging) across the whole lifecycle of the system. To the extent that it can help achieve this, the packaging systems shall: a. Use the highest percentage of recycled material economically available, legally allowable and technically feasible b. Use refill packs and/or returnable containers 3. Permit materials to be readily recoverable and/or permit recovery after use as energy or by composting. The packaging components should be easily separable to facilitate recovery. 4. Encourage environmentally responsible use of the contents and disposal of the used packaging 5. Minimize contamination that may arise as emissions or leachate from the materials when packaging waste is incinerated or landfilled 6. Not inappropriately appeal to children. 16 P a g e

The optimization with regard to resource use is expected to positively impact both the environmental footprint and the economics of a given packaged product. However, optimizing resource use must not be done at the expense of the related social aspects (e.g. child-resistant closures, consumer convenience). IV. Distribution Safety (Formulators & Suppliers) Charter companies shall establish and maintain control arrangements to ensure that products are safe throughout the distribution chain, from manufacturer to consumer, and survive in acceptable condition, by: 1. Evaluating the safety of the product during distribution in terms of foreseeable mishandling and accidents as well as intended handling before the product is put on the market 2. Facilitating the flow of hazard and safe handling information along the supply chain to support risk evaluation and risk management of its products by having a process for compiling and sending information down the supply chain; and for receiving information from downstream components of the supply chain. V. Consumer Education (Formulators) Charter companies shall provide information to consumers to promote sustainable use of their products and to help consumers achieve the best cleaning results and best product performance. VI. Life Cycle Thinking (Formulators & Suppliers) Charter companies shall have in place and operate a process to review the environmental aspects of new products designated to reduce their environmental burden across the overall product lifecycle through the application of lifecycle thinking. Where Charter companies put in place new measures designed to reduce the environmental burden of products across their lifecycle, they shall have made a reasonable assessment that: 1. The product is still able to deliver an acceptable level of cleaning performance to the consumer, and 2. There will be a net reduction in environmental burden across the lifecycle of the product as a result of those new measures (other factors being equal). VII. Contract Manufacturers and Co-Packers (Formulators & Suppliers) Charter companies shall work with their contract manufacturers and co-packers to ensure that the principles set forth by the Essential SPAs are being met for the company s U.S. cleaning product related production. 17 P a g e

APPENDIX C: ACI-RELATED PRODUCTION The following formulated products, packaging, ingredients, and other chemicals used in cleaning products are those considered by ACI to be related to cleaning product production. A. FORMULATED PRODUCTS LAUNDRY & FABRIC CARE PRODUCTS Bleaches Detergent boosters Dye trapping sheets Fabric fresheners/deodorizers Fabric softener sheets Fabric softeners (powders, liquids) Fabric whiteners/brighteners Home dry cleaning products, including wipes Ironing aids and conditioning products Laundry soaps and detergents, including fine fabric cleaners and other specialties Pre-wash soil and stain removers Stain removers Starches Ultraviolet filters Wrinkle releasers Other laundry/fabric care products TOPICAL CLEANSERS & ANTIMICROBIAL PRODUCTS Antimicrobial soaps and hand cleaners Body soaps (liquids) Hand and body soaps and cleansers Hand or facial wipes Other antimicrobial hand cleaners and hand sanitizers (waterless foams, gels, etc.) SURFACE CLEANERS & ANTIMICROBIAL PRODUCTS All purpose and multi-purpose detergents Hard surface cleaners and wipes for glass, floors, walls, kitchen, bathroom or other surfaces Mildew removers Sanitizers (including biocides & disinfectants) Scouring cleansers Soap scum removers Toilet bowl cleaners Other surface cleaners DISHWASHING AND ASSOCIATED PRODUCTS Automatic dishwashing detergents and soaps Film and spot remover Hand dishwashing liquids and dish wipes Lime and rust remover Pot and pan cleaners Rinse aids Scouring pads containing soap or detergent 18 P a g e

B. PACKAGING, INGREDIENTS AND OTHER CHEMICALS USED IN THE PRODUCTION OF CLEANING PRODUCTS MATERIAL SUPPLIED Abrasive compounds Acid compounds Alkalis Amphoterics Anti-fog compounds Antimicrobials Anti-redeposition agents Bicarbonates or carbonates Bleaching agents Builders Chelating agents Corrosion inhibitors Defoamers Dishwasher rinse agents Dye transfer inhibitors Enzymes Fabric softeners Fatty-acid derivatives Finished product packaging Fragrance/aroma compounds Intermediates for any of the above Oleochemicals Optical brighteners Oxidants Phosphates Polishing agents Preservatives Processing aids Propellants Rinse agents Silicones Soil release agents Solvents Substrates (sheets) for softener sheets Substrates (sheets) for surface wipes Substrates for hand wipes Surface active agents Thickening compounds Other ingredients or chemicals used in the production of cleaning products 19 P a g e

I. Definitions APPENDIX D: CONSUMER PRODUCT INGREDIENT COMMUNICATION INITIATIVE Air Care Product Chemically formulated consumer products designed to enhance or condition the indoor environment by eliminating unpleasant odors, freshening the air or removing airborne particles that are subject to regulation by the Consumer Product Safety Act (15 U.S.C. 2051-2084). Automotive Product Chemically formulated consumer products designed to maintain the appearance or operation of motor vehicles that are subject to regulation by the Consumer Product Safety Act (15 U.S.C. 2051-2084). Cleaning Product Soaps, detergents and other chemically formulated consumer products designed for fabric care, dish and other ware washing and/or surface cleaning that are subject to regulation by the Consumer Product Safety Act (15 U.S.C. 2051-2084). Ingredient A constituent in an Air Care, Automotive, Cleaning, or Polishes and Floor Maintenance Product, not including incidental ingredients that have no technical or functional effect in the product. Manufacturer The producer or generator of an Air Care, Automotive, Cleaning, or Polishes and Floor Maintenance Product that is sold or offered for sale. Identification of the Manufacturer, for purposes of this program, will be determined by the following hierarchy: a. When the name of the entity that manufactured the product held by the container is stated on the container label, then that entity will be considered the product Manufacturer. b. When the container label does not state the entity that manufactured the product held by the container, but the container label does state the distributor of the container, then the distributor will be considered the Manufacturer. c. When the container label does not state either the entity that manufactured the product held by the container or the distributor of the container, but the container label states the importer of the container, then the importer will be considered the Manufacturer. Polishes and Floor Maintenance Product Chemically formulated consumer products such as polishes, waxes, and restorers designed to polish, protect, or maintain furniture, floors, metal, leather, or other surfaces that are subject to regulation by the Consumer Product Safety Act (15 U.S.C. 2051-2084). II. Ingredient Communication a. Effective Date. i. Effective January 1, 2012 Manufacturers participating in the program will communicate Air Care, Automotive, Cleaning, and Polishes and Floor Maintenance Product Ingredients in accordance with the following provisions. ii. Notwithstanding Section II(a)(i), an Air Care, Automotive, Cleaning, or Polishes and Floor Maintenance Product that was manufactured before January 1, 2012 may be sold, supplied, or offered for sale after January 1, 2012 without complying with the following provisions, so long as the product container or package displays the date on which the product was manufactured, or a code indicating such date. 20 P a g e

b. Nomenclature. Ingredients for Air Care, Automotive, Cleaning, and Polishes and Floor Maintenance Products will be identified by: i. The International Nomenclature Cosmetic Ingredient (INCI) name, and/or the International Union of Pure and Applied Chemistry (IUPAC) name, Chemical Abstract Service (CAS) name, Consumer Specialty Products Association (CSPA) Dictionary name, and/or the common chemical name. ii. Dyes and colorants may be listed pursuant to Section II(b)(i) above or by trade name. iii. All chemicals present as components of fragrances may be listed as Fragrances, but the Manufacturer must then refer to the availability of more detail elsewhere. Such detail may include, but is not limited to: a. a link to the list or a subset of the list of fragrance materials authored by the International Fragrance Association (IFRA); or b. a list disclosing the ingredients that the Manufacturer uses in its fragrances. iv. Chemical function and/or chemical class descriptors may be used as an alternative to INCI, IUPAC, CAS, CSPA, or common chemical names where needed for protection of confidential business information. c. Media. Manufacturers will select one or more of the following media for identifying ingredients pursuant to Sections II(b)(i) (ii) above: i. product label; ii. Manufacturer s website; iii. Manufacturer s toll free number; or iv. other non-electronic means. If disclosure does not occur on the product label, the Manufacturer must provide on the label a website address or toll-free number. d. Listing of Ingredients. Ingredients present at a concentration of greater than one percent will be listed in descending order by predominance. Ingredients present at a concentration of not more than one percent will be listed but may be disclosed without respect to order of predominance. 21 P a g e