As longtime leaders in the sustainable menstrual health movement, we’ve been advocates for the transparent disclosure of ingredients in menstrual products. Until very recently, little material action has been taken on the issue in North America, thanks to ‘grandfathered’ regulatory clauses that allow manufacturers to keep ‘proprietary’ ingredient information to themselves.
This lack of stringency has meant that manufacturers of reusable products have also been able to be less than fully transparent about the ingredients and additives used in their products, as well as the presence of PFAS or other chemical additives. This is changing, thanks to the efforts of environmental activist groups. We applaud a new report that highlights significant progress that has been made in the fight for greater transparency.
After months of field research, on May 17, 2022, Women’s Voices for the Earth (WVE), Clean & Healthy New York, Sierra Club (Atlantic Chapter) and We Act for Environmental Justice issued a report highlighting improvements in ingredient disclosure for menstrual products. The improvements are thanks to a New York State law (A.164-A/S.2387) that went into effect in October 2021.
“We are finally getting a picture of just how complex and extensive the chemical exposure from period products can be on the health of our bodies and on the environment,” said Alexandra Scranton, lead author on the report and WVE’s Director of Science and Research.
What does the law specify?
“EACH PACKAGE OR BOX CONTAINING MENSTRUAL PRODUCTS SOLD IN THIS STATE SHALL CONTAIN A PLAIN AND CONSPICUOUS PRINTED LIST OF ALL INGREDIENTS WHICH SHALL BE LISTED IN ORDER OF PREDOMINANCE. SUCH LIST SHALL EITHER BE PRINTED ON THE PACKAGE OR AFFIXED THERETO.”
Where "INGREDIENT" SHALL MEAN AN INTENTIONALLY ADDED SUBSTANCE PRESENT IN THE MENSTRUAL PRODUCT
How did Aisle measure up in the report?
As a manufacturer of sustainable period care products for decades, this type of regulatory compliance is welcome news. Aisle (formerly known as Lunapads) washable cloth pads and leakproof period underwear were created because our founder, Madeleine Shaw suffered from allergic reactions to tampons. Out of concern for health and sustainability, Aisle products are proudly designed using natural or sustainable textiles that avoid introduction of potentially harmful chemicals or additives.
Operating primarily in the online space, Aisle is a top ranking B Corporation that prides itself on transparency in our manufacturing practices and our customer-facing disclosures. That said, we know there is always room for improvement. While we celebrated the introduction of Bill A.164-A in 2019, we naively assumed that the law was targeted to disposable products and only applied to products sold in stores in NY State.
While the current legislation doesn’t specifically require disclosure online, we believed that the intention of the legislation (ie: “right-to-know legislation and transparency policies for menstrual products”) would be largely satisfied by full disclosure on our website’s product pages: the point of sale where the customer is seeking information and making their purchasing decision. Ingredient disclosure on the outer package received, after the purchase decision was made, seemed unnecessary and less relevant.
We now understand that this is not sufficient. Thanks to the report’s findings, we are putting in place procedures to add a label detailing ingredients to the outer package, to be in compliance with this law.
The report also recommended that brands provide additional disclosure beyond the trade-named ingredients behind their proprietary technology. As a small private company in a competitive industry, we try to strike a balance between disclosing health or sustainability-related information about our ingredients while attempting to preserve our intellectual property (ie: Truetex fabric, used in the gussets of our period underwear). Based on the report’s recommendations, we are also updating this detail in our packaging.
What about PFAS?
The report did not address disclosure about the presence of chemicals such as PFAS. As a next step in this process, we would like to see a legal requirement for companies to test and report on the presence of PFAS in menstrual products. Aisle prides itself on not adding any chemicals or other foreign additives whatsoever to our products, and conducts third party PFAS testing on our pads and underwear. We are also extremely proud to have been consistently cleared, by independent third parties, of any detectable level of PFAS in our products.
We applaud the additional efforts by WVE for exposing compliance to the bill and taking further steps to promote improvements. WVE plays an important role in increasing consumer awareness and pushing brands to adopt higher standards: measures that help all our communities and the environment.