Written on: June 1, 2022 by Doug Raymond
CARB
As a reminder, the California Air Resources Board (CARB) has new future effective limits that will become effective on Jan. 1, 2023. Your company has seven months before these new limits become effective. There is also a three-year sell-through for products made before the effective date of Jan. 1, 2023. The categories, volatile organic compound (VOC) limits and effective dates are:
Category New VOC limit Effective date
Manual Aerosol Air Freshener 10% Jan. 1, 2023
Future Effective 5% Jan. 1, 2027
Note: “Manual Aerosol Air Freshener” is a new category. The Single-Phase Aerosol and Double Phase Aerosol will be replaced with the Manual Aerosol Air Freshener Category, as well as the following new Aerosol Air Freshener Categories.
Aerosol Air Freshener Categories
Concentrated Aerosol Air Freshener 15% Jan. 1, 2023
Future Effective 10% Jan. 1, 2027
Automotive Aerosol Air Freshener 30% Jan. 1, 2023
Total Release Aerosol Air Freshener 25% Jan. 1, 2023
Category Current VOC limit New VOC limit Effective date
Hair Care Products
Hair Finishing Spray 55% 50% Jan. 1, 2023
Dry Shampoo – 55% Jan. 1, 2023
Future Effective Limit – 50% Jan. 1, 2029
Note: New category VOC limit, not regulated currently
Hair Shine 55% 50% Jan. 1, 2029
Temporary Hair Color 55% 50% Jan. 1, 2029
Personal Fragrance Product Current VOC Limit (manufactured before Jan. 1, 2023)
Products with 20% or less Fragrance 75%
Products with more than 20% Fragrance 65%
Personal Fragrance Product New VOC Limit Effective date
(manufactured Jan. 1, 2023—Dec. 31, 2030)
Aerosol 70% Jan. 1, 2023
Non-Aerosol Products with 7% or less fragrance 70% Jan. 1, 2023
Non-Aerosol Products with 7% or more fragrance 75% Jan. 1, 2023
Note: New Fragrance levels
Personal Fragrance Product New VOC Limit Effective date
Aerosol 50% Jan. 1, 2031
Non-Aerosol Products with 10% or less fragrance 50% Jan. 1, 2031
Non-Aerosol Products with 10% or more fragrance 75% Jan. 1, 2031
Note: New Fragrance Levels
Insecticides
Crawling Bug Insecticide Current VOC Limit New VOC limit Effective date
Aerosol 15% 8% Jan. 1, 2030
Bed Bug Insecticide (new category)
All Forms – 20% Jan. 1, 2030
Aerosol – 15% Jan. 1, 2030
Aerosol Adhesives Current VOC Limit New VOC limit Effective date
Plastic Pipe Adhesive – 60% Immediately
Therefore, if your company produces any of the products found on page 6, your R&D departments should hopefully be hard at work reformulating them.
Next, we are working on the new 2022 State Implementation Plan (SIP), which should be finalized by August 2022.
Finally, to learn about CARB Enforcement staff’s recent industry-led plant tour and Aerosol 101 presentation at the Shield PLZ facility in Chino, CA, turn to p.29 of the June 2022 SPRAY.
Ohio
On May 6, the State of Ohio Division of Air Pollution Control (DAPC) held a virtual public hearing on the amendments to the VOC regulation for Consumer Products. It was only 30 minutes long and DAPC did not answer questions. Only Nicholas Georges from the Household & Commercial Products Association (HCPA) and I, representing the National Aerosol Association (NAA), presented testimony in an attempt to maintain a one-year timeline from adoption until the effective date. DAPC is proposing to move from Ozone Transport Commission (OTC) Model Rule II to OTC Model Rule IV. The proposed effective date is July 1, 2023. Thus, DAPC would need to finalize and adopt its regulation by Jan. 1, 2023. Due to the format of the public hearing, we do not know if or what DAPC’s activity will be. SPRAY
