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What are
trace materials? Trace materials may be present in our cleaning products at percent levels, at parts per million (ppm) levels, or even at parts per billion (ppb) levels. We classify trace materials into two different categories: trace constituents and incidental ingredients. What are
trace constituents? Trace constituents can also be naturally occurring impurities in the raw materials we source. This can happen because we use plant and mineral-derived raw materials. An example of this is sodium chloride, or salt. The salt used in our products is obtained from natural sources; however, even after purification, magnesium chloride and calcium chloride can be present as trace constituents at extremely low concentrations in our final product. These trace constituents do not pose any human health or environmental hazard. What are
incidental ingredients? The FDCA requires
the label on each package of a product to declare the name of every ingredient
greater than 1% in the final formulation in descending order of predominance,
except fragrances and flavors which may be listed as fragrance or flavor.
Ingredients present below 1% can be listed in any order desired by the
manufacturer. To make it easier for our consumers to understand, Seventh
Generation groups ingredients by function and lists the functions in order of
predominance. • Substances that have no technical or functional effect in the [product] but are present by reason of having been incorporated into the [product] as an ingredient of another [product] ingredient. • Processing aids, which are as follows: • Substances that are added to a [product] during the processing of such [product] but are removed from the [product] in accordance with good manufacturing practices before it is packaged in its finished form. • Substances that
are added to a [product] during processing for their technical or functional
effect in the processing, are converted to substances the same as constituents
of declared ingredients, and do not significantly increase the concentration of
those constituents. (iii) Substances that are added to a [product] during the
processing of such [product] for their technical and functional effect in the
processing but are present in the finished [product] at insignificant levels and
do not have any technical or functional effect in that [product]. 21 CFR
§701.3(l). Two examples of incidental ingredients in our products include: • Preservatives are often added to the raw materials we purchase. For example, the biodegradable, plant-derived surfactants that we use are subject to microbial contamination. To prevent this, the manufacturers add a preservative to them. By the time we add other substances to the surfactant to make a product, the level of preservative present is too small to be effective. Therefore such preservatives are incidental ingredients. Indeed, we have to add our own preservative to our products to protect them from microbial degradation! • The hydrogen peroxide we use in some of our products contain stabilizers added by our suppliers to prevent the peroxide from decomposing. As with preservatives, these stabilizers are considered incidental ingredients.
What are we doing to find out as much as possible about trace
materials in our raw materials?
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