The California Department of Toxic Substances Control (DTSC) announced the revised text of the 'Priority Product Rule for Products Containing Hydrofluoric Acid' on September 22, 2026, and opened a public comment period until October 7. This is a proposed revised rule, not a final regulation that has taken effect. For cleaning product companies, the most practical work in the near term is not to use 'total ban'-style marketing, but first to confirm whether their products contain the hydrofluoric acid specified in the rule, what role they play in the California market, and which version of the product needs to undergo evaluation.
The DTSC page lists potential uses as rust removers, metal cleaners or brighteners, wheel cleaners, and some surface cleaners. This range cannot be used to infer that "all acidic cleaners contain hydrofluoric acid." Hydrofluoric acid has a specific chemical identity, with OSHA listing its CAS number as 7664-39-3; corporate verification should refer back to formulations, raw material specifications, supplier information, and finished product versions, rather than relying on marketing terms like "rust removal," "heavy-duty," or "acidic".
The revised proposal includes sales restrictions and liability chain arrangements. DTSC data shows that if the rule is finalized, the primary compliance responsibility will first fall on the manufacturer, and may extend to importers, assemblers, or retailers under certain conditions such as notifications. Since the final text, implementation date, and conditions that trigger liability may still change, companies should record 'proposal content,' 'final rule,' and 'internal company preparations' in three separate columns to avoid mixing them up in communications with clients.
Why do regulatory agencies pay special attention to hydrofluoric acid? CDC/NIOSH materials indicate that hydrofluoric acid can cause exposure through the skin, eyes, inhalation, or ingestion, and may penetrate deep into tissues; visible damage and pain may not appear immediately. The CDC's 2026 chemical facts page also emphasizes that it can cause serious tissue injury and delayed symptoms. This hazard information explains why strict identification and handling are necessary, but it does not prove that any unnamed products contain hydrofluoric acid.
For the first table for manufacturers, it is recommended to organize it as 'Sales Market—Product SKU—Formula Version—Raw Material Chemical Identity—Usage—Packaging—Responsible Entity—Evidence Date.' A Chinese packaging, export packaging, or channel-specific version, even if the base product name is the same, may correspond to different labels, specifications, or supply chain responsibilities. Only when the versions are clearly matched can regulatory screening, substitution assessment, customer responses, and inventory handling be conducted without confusion.
The second step is to verify the level of evidence. Raw material safety data sheets can help identify chemical identity and hazard classification, but they cannot automatically replace finished product formulation records, finished product labels, or assessments of suitability for target markets. Supplier declarations, purchase batches, formulation changes, and testing or analytical data should also indicate the date and scope of applicability. When information cannot be found, it should be recorded as 'to be confirmed' rather than rewriting 'not found' as 'not contained'.
The third step is to clarify the business roles. The brand owner, formula developer, actual manufacturer, importer, distributor, and retailer each have access to different information. The order of responsibilities in a proposal cannot directly replace the division of tasks in a contract, and the contract division of tasks cannot exclude legal obligations. Companies need to ensure that regulatory, R&D, procurement, production, packaging, and sales departments use the same version numbers, and keep records of who confirmed what and when.
EPHYON's publicly available home and personal care OEM/ODM service page requires projects to first define the category, target market, and specifications, and then evaluate the formula, packaging, and production suitability. This project entry point is suitable for adding two checkpoints: 'target market chemical screening' and 'market version evidence package': after the client proposes the use and market, each formula, packaging, and delivery document is confirmed. This service page does not indicate that any EPHYON product contains or does not contain hydrofluoric acid, nor does it constitute a California compliance conclusion.
For projects that are developing rust removers, metal brighteners, or professional surface cleaning products, a safer sequence is: first confirm the target market and intended use; then lock in the formulation and identity of raw materials; next assess regulatory scope, occupational safety, packaging labels, and transportation requirements; and only finally decide whether it is necessary to replace, adjust, or discontinue a market version. Replacements do not just mean changing a raw material name; performance, corrosiveness, compatibility, and usage risks still need to be reassessed.
The signal this public announcement sends to the industry is not 'all cleaners are subject to the same restrictions,' but that the chemical identity, product use, sales region, and responsible role must correspond one by one. For cross-regional sales and OEM/ODM projects, being able to quickly provide a complete version of the evidence is more valuable than trying to trace it temporarily after the rules are announced.
Applicable Scope: This article is based on publicly accessible information from DTSC, CDC/NIOSH, OSHA, and One Clean as of September 29, 2026, to conduct industry observation. DTSC matters are still proposed rules, and the final scope, responsibilities, dates, and enforcement methods are subject to subsequent official texts; this article does not constitute legal, occupational health, or product formulation advice, nor does it infer the ingredients of any unnamed products.