The US EPA’s Design for the Environment (DfE) program is an easy way to relay to consumers that a product meets stringent requirements for human and environmental health and safety. Additionally, the US Federal Government is increasing requirements that all federal purchases meet certain sustainability requirements, and if a product bears the DfE logo then it will be included in these requirements.
So, how do you know if your antimicrobial product meets the criteria for DfE certification, and how do you go about obtaining DfE Certification? Read on to learn more.
Active ingredients approved under the DfE program
Currently there are 8 approved active ingredients that would allow for a product to be considered under the DfE program:
- Citric acid
- Hydrogen peroxide
- L-lactic acid
- Ethanol
- Isopropanol
- Peroxyacetic acid
- Sodium bisulfate
- Chitosan
These active ingredients have been assessed for their acute toxicological and environmental persistence properties. For a product to be considered under the DfE program, a comprehensive review of the entire product formulation is required. The review will take into consideration the hazard effects of all ingredients in a product, which include the active ingredients, inert ingredients and impurities. Product performance standards and packaging requirements must also be met.
Approval phases for DfE certification
Once you have assessed your product’s relevance to the DfE program and the chemical formulation’s consitutients against the Safer Choice Ingredients List (SCIL), there are three phases of approval:
Phase 1: Auditor approval
A third-party auditor reviews the documentation and confirms whether or not a product meets Safer Choice standards. If a product meets the standards, the auditor will send the application directly to the US Environmental Protection Agency (EPA) for its first review.
Phase 2: OPPT Safer Choice approval
US EPA reviews against Office of Pollution Prevention and Toxics (OPPT) Safer Choice criteria, and if all certification requirements are met, the DfE partnership agreement is signed. At this stage, the applicant must submit a PRIA application for new product registration or a label amendment, as appropriate.
Phase 3: OPP DfE approval
EPA’s Office of Pesticide Pollution (OPP) Antimicrobials Division (AD) will send pre-determination notification to the applicant, along with possible labelling annotation requests. The applicant then submits the final printed label with all annotations addressed. Final approval is given and the application receives an EPA-stamped, accepted label for sale and distribution.
Regulatory support
The DfE certification process can be complex. It’s not always easy to determine if products and chemical formulations meet the stringent criteria for the DfE program; and while the third-party auditor will confirm whether or not a product meets DfE criteria, they will not outline how to make any necessary improvements if a product fails to meet requirements.
TSG’s DfE certification team can shepherd you through the process from start to finish. They can help assess your product portfolio against the DfE program, work with your suppliers and auditors to adjust chemical formulations so they meet program requirements, submit documentation for approval, and project manage EPA reviews.
The table below outlines how TSG can support you throughout the approval process.
Reach out to TSG’s experts Jonathan Walsh or Perri Moeller for support with your DfE product registration.
Alternatively email [email protected] and we’ll get back to you.
