New York has been trying to require manufacturers of household and commercial cleaning products to disclose their ingredients since 2018, but the rule has never gone into effect as originally written, and there is currently no compliance deadline in place.
Under Environmental Conservation Law Article 35 and 6 NYCRR Part 659, the New York Department of Environmental Conservation (DEC) has authority to require manufacturers of cleaning products sold in New York to disclose product ingredient information. DEC issued a Program Policy implementing this in June 2018, with an original effective date of October 1, 2019.
That policy never took effect as written. On August 27, 2019, the New York State Supreme Court ruled the Program Policy null and void, finding that DEC had not adopted it through the formal rulemaking process required by the State Administrative Procedure Act (SAPA). The court sent the matter back to DEC with instructions to implement any disclosure program through a proper SAPA rulemaking instead of agency policy.
As of mid-2026, DEC has not completed that rulemaking. According to DEC’s own program page, the agency is still working on amendments to Part 659 covering what ingredient information must be reported, how it will be shared publicly, what supporting studies must be submitted, and how confidential business information claims will be handled. DEC has held public meetings on the proposed amendments and published recommended best management practices for ingredient disclosure, but has not yet issued a formal proposed rule or opened a public comment period on binding regulatory text.
In practical terms: there is currently no enforceable ingredient-disclosure deadline for household cleaning products in New York. The 2019 date has no legal effect, and no new date has been set. Companies selling cleaning products in New York should treat this as an active area to monitor, not a rule they are already out of compliance with.
Manufacturers and distributors who want to get ahead of a future rule can review DEC’s best management practices document, which outlines the kind of ingredient disclosure DEC is likely to eventually require, and can contact DEC’s Bureau of Waste Reduction and Recycling to be notified when a formal rulemaking is proposed. Given the multi-year gap since the 2019 court decision, we recommend checking back with DEC directly, or with Quantum’s compliance team, before making claims about specific timing.
For broader chemical ingredient and SDS management obligations that are currently in effect, see Quantum’s chemical management page.
Our team has been working with Chemical Compliance for nearly thirty years, and have supported compliance with similar programs. The New York rule is nothing new to us!
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