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How to Partner
Formulator Program Home | About This Project | Findings & Accomplishments | Safer Detergents Stewardship Initiative | Publications | Partners and Recognized Products
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The DfE Program reviews and recognizes best-in-class wet chemical-based formulations and products. In our review, we look at each ingredient in a formulation within its distinct functional class (e.g., surfactants, solvents) and compare toxicity and fate profiles to identify the safest ingredients. The DfE Program offers formulator companies the opportunity to partner with DfE--and to use the DfE logo--when they design or reformulate high-performing, cost-effective products with a more positive environmental and human health profile using the safest possible ingredients.
Steps to Partnership Flowchart
STEP 1. Become Familiar with the Program. For background and context, look at "When you see the DfE label on a product, what does it mean?". If you’re a cleaning product manufacturer, read over "Criteria for Safer Cleaning Products (CSCP) in the form of a Standard" (PDF) (28 pp, 156K) and the Screens for Safer Ingredients to get a sense of program goals, framework, criteria, and to determine if your product may qualify to bear the DfE label. For manufacturers of other products, read DfE’s "Discriminating and Protective Approach to Product Review and Recognition" (PDF) which includes the DfE criteria in matrix format.
STEP 2. Profiling of All Formulation Ingredients. Applications for partnership must include a full disclosure of all ingredients and ingredient profiles. A profile is a compilation of all hazard information available on a chemical and includes detailed structure, physical-chemical properties, human health and environmental toxicology, and regulatory/administrative status.
To be able to work with all of the companies that request partnership, DfE has qualified third-party profilers. Qualified third-party profilers have the expertise and objectivity needed to ensure a quality review, with high confidence in the accuracy and reliability of the profile information. NSF, International and ToxServices, LLC are qualified third-party profilers for DfE.
The contact at NSF is Teresa McGrath at (651) 493-4247 or tmcgrath@nsf.org. She can provide a free quote for NSF’s service after the product information has been submitted. For more information please see their website: http://www.nsf.org/business/laboratory_services/cleangredient_lab/Formulator.asp
Dr. Ann Marie Gebhart (amgebhart@toxservices.com; 202-429-8794) is the contact for ToxServices. For additional information, please see their Web site: http://www.toxservices.com/USEPA.html
Cleaning product formulators are encouraged to choose ingredients that are listed on CleanGredients™ and have passed the appropriate DfE Screen for Safer Ingredients. These ingredients have already been reviewed by a third-party profiler and do not need additional third-party review.
To learn more about CleanGredients™, please see this link: CleanGredients™
For background on third-party profiling, please see this link: Chemical Profiling of All Formulation Ingredients (PDF) (2 pp, 33K)
To better understand the qualifications of the third-party profilers, please see this link: Third-party profiler qualifications (PDF) (1 pg, 15K)
STEP 3. Assessing Ingredients and Identifying Safer Alternatives. Following third-party profiling, DfE will assess the potential health and environmental effects of each ingredient in your formulation and may identify areas for improvement, safer alternatives, or additional information needs. In the context of its functional class, DfE evaluates each ingredient in a formulation based on critical health and environmental endpoints. The functional class context allows DfE to view ingredients as part of a continuum of improved ingredient choices. DfE has developed two types of screens for its technical review process: the General Screen and Functional Class Screens. The General Screen applies to all ingredients not covered by a specific functional-class screen. Using the General Screen as a template, the Functional Class Screens tailor the health and environmental endpoints in the General Screen in a way appropriate to the specific class, designating key, distinguishing characteristics and adjusting thresholds, as necessary. Functional Class screens define and more fully explore the green end of specific ingredient-class continuums. DfE has issued three functional-class screens--the DfE Screen for Solvents, the DfE Screen for Surfactants, and the DfE Screen for Fragrances (Human Health)--and is currently developing screens for fragrances (environmental toxicity and fate) and additional functional-use classes in partnership with broad stakeholder workgroups.
To learn more about DfE Screens for Safer Ingredients, please see this link: DfE Screens for Safer Ingedients
STEP 4. Discussing the DfE Assessment. Once complete, DfE will discuss with you its assessment, recommendations, changes needed to qualify for recognition, and the elements of a partnership agreement.
STEP 5. Entering into Partnership. After the product manufacturer has satisfied DfE’s requirements for the use of safer ingredients, DfE and the manufacturer sign a partnership agreement. The purpose of the Partnership Agreement is to set forth the basis, terms, and goals of the DfE’s voluntary partnership between the partner and EPA. The Partnership Agreement includes provisions covering the following: how the partner formulates the qualifying products; their environmental and human health benefits; and how the partner and EPA/DfE will work together to continually improve the health and environmental profile of the qualifying products and educate the consumer on these improvements and the DfE Program.
Please see this link for a sample Formulator Partnership Agreement (PDF) (10 pp, 44K)
STEP 6. Beginning the Partnership. DfE and your company decide how to announce the partnership and plan near-term activities. DfE welcomes additional products for review, as well as your ideas on how to improve and strengthen the partnership program. Your company should also carefully review the terms of logo use (PDF) (2 pp, 23K). Please note that the partnership agreement will sunset three years from the date of signature, unless the parties renegotiate and renew the agreement prior to the expiration date. Renewals are handled similarly to initial partnership, beginning with the third-party reviewer and culminating with sign-off by EPA and the partner company.
Please Note: Submission of data under this program is voluntary.
How to start a partnership for a new sector
To open a new sector (i.e., product types that DfE has not previously recognized), DfE asks that you contact us directly. Please contact David DiFiore, DiFiore.David@epa.gov.
PRA Notice: According to the Paperwork Reduction Act (PRA) (44 USC 3501 et seq.), and the implementing regulations (5 CFR 1320 et seq.), a Federal agency may not conduct or sponsor, and a person is not required to respond to, certain collections of information involving identical questions to 10 or more persons unless the agency has obtained approval from the Office of Management and Budget (OMB). For each such collection activity, the agency is required to "inform" the respondent that they are not required to respond to the collection of information unless it displays a valid OMB control number. Failure to display a valid OMB control number permits a respondent to raise the affirmative legal defense provided by the "public protection" provision in section 3512 of the PRA (see also 5 CFR 1320.6).
The Agency has not yet obtained approval from OMB for this information collection. Until such approval is obtained, these activities are solely intended to provide the Agency with information to be used in the Design for the Environment (DfE) Formulators Project. Until approval is obtained, the PRA's "public protection" provision will prevent the Agency from using any information you provide under this DfE project in a compliance or enforcement context to impose any penalties.
EPA will be announcing the availability of the draft Information Collection Request (ICR) to solicit public comments on specific aspects of the collection activities before submitting the ICR to OMB for review and approval. Once available for public review and comment, EPA will provide a link here to the document and the related docket.