California DTSC Proposes Ban on Cleaning Products Containing Hydrofluoric Acid

The California Department of Toxic Substances Control (DTSC) has initiated rulemaking to list cleaning products containing hydrofluoric acid (HF) as Priority Products under California’s Safer Consumer Products (SCP) Program and to prohibit the sale of those products in California.

A public comment period on the proposal opened on June 5, 2026, and closes on July 20, 2026. DTSC anticipates that the regulation will become effective in mid- to late 2027.

Key Takeaways

• DTSC is proposing to ban the sale of cleaning products containing HF in California. If finalized as proposed, manufacturers would be prohibited from placing those products into the state’s stream of commerce.
• The proposal would cover cleaning products that contain HF directly or contain bifluoride compounds that can release HF. According to DTSC, these may include rust removers, stain removers, bathroom cleaners, automotive cleaners, wheel cleaners, metal cleaners and brighteners, and other products.
• This proposal marks DTSC’s first use of the direct-to-regulatory-response pathway created by SB 502. SB 502, enacted in 2022, allows DTSC to rely on publicly available alternatives studies or evaluations and proceed directly to a regulatory response, instead of requiring manufacturers to conduct an Alternatives Analysis.
• Companies that manufacture, distribute, import, or sell cleaning products in California should evaluate whether their products contain HF or HF-releasing bifluoride compounds and consider commenting before the July 20 deadline.

Covered Products

DTSC’s proposal would apply to “cleaning products containing hydrofluoric acid,” defined to include any stain or rust removal product or other product intended for cleaning that contains HF in anhydrous or aqueous form. The proposed definition would capture products where HF is intentionally added, as well as products containing bifluoride compounds that can release HF.

DTSC has noted that examples of potentially affected products include rust removal and inhibition agents, stain removers, bathroom cleaners, automotive cleaners, wheel cleaners, metal cleaning and brightening agents, coil cleaners and brighteners, boat cleaners, surface cleaners, stone and masonry cleaners, pool tile cleaners, and water-ring removers.

First Use of SB 502 Direct-to-Regulatory-Response Authority

The proposal is DTSC’s first use of the direct-to-regulatory-response pathway created by SB 502, which was enacted in September 2022. Among other changes to California’s Green Chemistry law, SB 502 allows DTSC to rely on publicly available studies or evaluations of alternatives and proceed directly to a regulatory response in lieu of requiring product manufacturers to perform an Alternatives Analysis.

DTSC gives three principal reasons for using that pathway here:

• DTSC states that alternatives to HF already dominate the cleaning products market and are widely available. DTSC identifies alternatives such as citric acid, gluconic acid, and phosphoric acid.
• DTSC states that publicly available evaluations document the use, hazards, and alternatives for cleaning products containing HF. DTSC relies on a peer-reviewed publication, an international agency report, and DTSC’s Product-Chemical Profile for cleaning products containing HF.
• DTSC states that HF’s hazards and the potential for exposure and adverse impacts from HF-containing cleaning products are well documented.

Proposed Sales Prohibition and Expected Impacts

DTSC determined that a sales prohibition is the appropriate regulatory response because of the potential for adverse health effects from HF exposure and the availability of alternatives that DTSC says are widely used and comparably priced. Under the proposal, manufacturers of covered cleaning products containing HF would be prohibited from placing those products into the stream of commerce for sale in California as of the regulation’s effective date.

Comment Period and Rulemaking Process

The 45-day public comment period began on June 5, 2026, and closes on July 20, 2026. DTSC prefers comments to be submitted through CalSAFER, but comments may also be submitted by email to [email protected] or [email protected].

After the comment period closes, DTSC may adopt the proposed regulation. If DTSC makes substantial, sufficiently related changes to the regulatory text, it must make the modified text available for at least 15 additional days of public comment before adoption. Once finalized, DTSC will prepare a Final Statement of Reasons that responds to comments and identifies the filing and effective dates.

Future Implications

This rulemaking is notable not only for the proposed California sales prohibition, but also for the process DTSC is using. If finalized as proposed, the rule would constitute DTSC’s first use of its new authority under SB 502. That could have implications beyond HF-containing cleaning products, as DTSC’s use of this authority may provide a roadmap for future restrictions on other consumer products.

B&D's Consumer Products and Product Stewardship, Global Supply Chains practices work with U.S. and multinational companies that manufacture, distribute, transport, or sell consumer products in a hyper-competitive and evolving marketplace. We help clients identify, understand, and comply with complex regulatory requirements throughout the product lifecycle. With an office in San Francisco, B&D also advises clients throughout California on environmental issues affecting their facilities, operations, and products. For more information, please contact the authors.