Regulatory Requirements for Laundry Products Containing Distearyldimonium Chloride
Question
I would like to inquire about a formulation using Distearyldimonium Chloride in a laundry product intended to reduce pet hair (dog hair) attachment.
- Does this product require hazardous substance registration or notification with the FDA?
Answer
Regarding the use of Distearyldimonium Chloride in a laundry product (such as a fabric softener or additive to reduce pet hair attachment), the regulatory requirements in Thailand are as follows:
1. Classification under the Hazardous Substance Act
Laundry products, including detergents and fabric softeners, are regulated under the Hazardous Substance Act B.E. 2535 (1992), overseen by the Thailand Food and Drug Administration (FDA).
- Fabric Softeners/Anti-static Agents: Generally, products used for softening fabric or reducing static (which helps in reducing hair attachment) are classified as Hazardous Substance Type 1.
- Distearyldimonium Chloride: This is a cationic surfactant commonly used as a conditioning and anti-static agent.
2. Registration Requirements
- Hazardous Substance Type 1: You do not need a "Registration Certificate" (ใบสำคัญการขึ้นทะเบียน) like Type 2 or 3 substances. However, you are required to "Notify the Facts" (แจ้งข้อเท็จจริงเกี่ยวกับวัตถุอันตรายชนิดที่ 1) to the FDA before production or importation.
- Labeling: The product must follow specific labeling requirements mandated by the FDA for household hazardous substances, including Thai language instructions, warnings, and manufacturer details.
3. Important Considerations
- Claims: If your product claims to "disinfect" or "kill germs," it may be reclassified as a Type 2 or Type 3 hazardous substance, which requires a much more complex registration process and a Registration Certificate.
- Pet Safety: Since the product is intended for laundry that comes into contact with pets, ensure the concentration used is safe and does not cause skin irritation for animals.
Recommendation:
You should consult with the Bureau of Cosmetics and Hazardous Substances, Thai FDA, or use their online system to submit the "Notification of Facts" for a Type 1 Hazardous Substance.
The ingredient mentioned is available as:
- Distearyldimonium Chloride (Cationic surfactant for conditioning and anti-static effects).
- Disclaimer: Regulatory requirements can change. It is always best to verify the current regulations directly with the Thai FDA.*
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