Written on: December 1, 2016 by Doug Raymond
Upcoming effective dates
As of Jan. 1, 2017, the California Air Resources Board (CARB) has future effective volatile organic compounds (VOC) limits that come into effect. Future VOC limits for Aerosol Adhesives and Aerosol Coatings are listed below.
Aerosol Adhesives
| Category | Current VOC | 1/1/2017 VOC |
| Mist Spray | 65% | 30% |
| Web Spray | 55% | 40% |
| Screen Printing | None | 55% |
Aerosol Coatings/General Coatings
| Category | Current Maximum Incremental Reactivity (MIR) | 1/1/2017 MIR |
| Clear Coating | 1.50 | 0.85 |
| Flat Coating | 1.20 | 0.80 |
| Fluorescent Coating | 1.75 | 1.30 |
| Metallic Coating | 1.90 | 1.25 |
| Nonflat Coating | 1.40 | 0.95 |
| Primer | 1.20 | 0.70 |
Aerosol Coatings/Specialty Coatings (A)
| Category | Current MIR | 1/1/2017 MIR |
| Auto Body Primer | 1.55 | 0.95 |
| Electrical/Electronic/Conformal Coating |
– |
2.00 |
| Exact Match Finish
Automotive Engine Industrial |
1.50 1.79 2.05 |
0.95 0.95 1.20 |
| Flexible Coating | – | 1.60 |
| Ground Traffic/Marking Coating |
1.20 |
0.85 |
| Mold Release Coating | – | 1.10 |
| Two Component Coating | – | 1.20 |
| Uniform Finish Coating | – | 1.30 |
These limits are not easy to meet. There is a three-year sell-through for all products made before the effective date. Requirements for sell-through products are, first, all products must be date coded before the effective date. Second, products sold in the last six-months of the sell-through period must have a notification from the seller to the buyer that this product is to be sold in the next six months. Thus, if your reformulations are not finished yet, make sure your company has enough products to last until your reformulation is complete.
Multi-purpose Lubricant Report
If you are a Multi-purpose lubricant manufacturer or Marketer, then a report on your progress toward the 12/31/2018 future effective VOC limit of 10% is required. This report is due before 3/31/2017.
The report requires product and formula data from 2016, plus the label and other information required in Section 94513(a) of the CARB Consumer Products regulation. A detailed list of all requirements will be in the January issue of Regulatory Issues, so stay tuned.
In addition CARB staff needs an update on research and development efforts taken by your company to meet the 10% future VOC limit. More to come next month.
Ozone Transport States
Ozone Transport States of Delaware and New Hampshire have new VOC limits coming into effect in 2017. These new limits are the same as some of the current limits at CARB. Please see chart below.
| Category | Current VOC | 1/1/2017 VOC |
| Construction, Panel and Floor Covering Adhesive |
15% |
7% |
| Air Freshener Dual Purpose Air Freshener/Disinfectant (Aerosol) |
– |
60% |
| Anti-static Product (Aerosol) |
– |
80% |
| Automotive Windshield Cleaner |
– |
35% |
| Bathroom & Tile Cleaner
All Other Forms Non-aerosol |
5% |
N/A 1% |
| Brake Cleaner | 45% | 10% |
| Carburetor or Fuel-injection Air Intake Cleaner |
45% |
10% |
| Disinfectant
Aerosol Non-aerosol |
– – |
70% 1% |
| Engine Degreaser
Aerosol |
35% |
10% |
| Floor Polish or Wax
Resilient (Flexible) Flooring Material Non-resilient Flooring Material |
7%
10% |
1%
1% |
| Furniture Maintenance
Product All Other Forms (Except solid/paste forms) Non-aerosol (except solid/paste forms) |
7%
– |
N/A
3% |
| General Purpose Cleaner Aerosol |
10% |
8% |
| General Purpose Degreaser Aerosol |
50% |
10% |
| Laundry Starch/Sizing/
Fabric Finish Product |
5% |
4.5% |
| Multi-purpose Solvent
Non-aerosol |
– |
3% |
| Nail Polish Remover | 75% | 1% |
| Oven or Grill Cleaner
Liquid Non-aerosol |
5% |
N/A 4% |
| Paint Thinner
Non-aerosol |
– |
3% |
| Rubber/Vinyl Protectant
Aerosol-Tire Shine Products |
– |
10%
NOTE: NH Jan. 1, 2016 |
| Shaving Gel | 7 | 4% |
| Temporary Hair Color (Aerosol) |
– |
55% |
Also, if the product is made before the effective date and properly date coded, the sell-through period is indefinite.
Aerosol 101
Make sure to review the article on the CARB Aerosol 101 on p. 44 of the December 2016 issue of SPRAY. It was a great meeting and a wonderful opportunity for the aerosol industry!
