Don't Over Claim on Anti-Microbial Functions of Your Textile Products
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| In the US Federal regulation 40 CFR 152 under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), if any antimicrobial treated articles (including textiles & garments) bear implied or explicit “public health claims”, such as killing pathogens or bacteria, the chemicals used in the treatment must be registered with the Environmental Protection Agency (EPA) before the articles can be sold. |
Claims for control of specific microorganisms that are directly or indirectly infectious or pathogenic to man are regarded as “public health claims” where the treated articles must be registered.
The current EPA policy, 40 CFR 152.25, states an exemption (a) for any antimicrobial treated article if it bears “non public health claims”. This exemption covers qualifying an article with, or containing, a pesticide to protect the treated article or substances itself. For example, odor–resistant claims such as an antibacterial deodorizing function on sportswear, is treated as a “non public health claim” because the EPA continues to consider these general types of claims under the term “to protect the treated articles or substance itself”. This type of function is considered a non-public health related claim since the treatment can contribute to the protection of the appearance and maintenance of the intended useful life of the treated article or substance.
EPA does not believe that claims such as “antimicrobial” are consistent with the above exemption if they are: (1) part of the name of the product; or (2) not properly qualified as to their intended non-public health use. Examples of permissible statements would include, but are not limited to: “Antimicrobial properties built in to protect the product”. All references to the pesticide properties and the required qualifying statements should be located together, should be printed in type of the same size, style, and color, and should be given equal prominence.
Below are the examples of labeling claims the EPA is likely to consider acceptable under the exemption:
Odor Resistant Claims:
• This product contains an antimicrobial agent to control odors.
• This product contains an antimicrobial agent to prevent microorganisms from degrading the product.
• Resists Odors - This product has been treated to resist bacterial odors.
• Inhibits the growth of bacterial odors.
• Resists microbial odor development.
• Retards the growth and action of bacterial odors.
• Guards against the growth of odors from microbial causes.
• Guards against degradation from microorganisms.
• Reduces odors from microorganisms.
• Odor-resistant.
• Acts to mitigate the development of odors.
For more details, please refer to the EPA's notice “Applicability of the Treated Articles Exemption to Antimicrobial Pesticides”.
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