Written on: September 1, 2022 by Doug Raymond
California Air Resources Board
The Volatile Organic Compound (VOC) Consumer Product Regulation in California was amended in March 2021. On Aug. 1, 2022, the Amendments were approved by the Office of Administrative Law (OAL) and filed with the California Secretary of State. Therefore, the Amendment became effective on Aug. 1, 2022.
The following is a detailed summary of the Amendments, which include new VOC limits that take effect on Jan. 1, 2023—please note that there are only four months until the effective date.
Aerosol Amendments
• New Aerosol Adhesive category
– Plastic Pipe Adhesive, effective Aug. 1, 2022 at 60%
• Manual Air Freshener is a new category developed by merging the Single Phase and Double Phase Aerosol Air Freshener categories. This new category takes effect Jan. 1, 2023, with a VOC limit of 10%; this is followed by a future effective date of Jan. 1, 2027 with a VOC limit of 5%. After Jan. 1, 2023, the Single Phase and Double Phase Aerosol Air Freshener categories will cease to exist
• Three new Aerosol Air Freshener categories were formed:
– Automatic Aerosol Air Freshener, effective Jan. 1, 2023 at 30% VOC
– Concentrated Aerosol Air Freshener, effective Jan. 1, 2023 at 15% VOC and effective Jan. 1, 2027 at 10% VOC
– Total Release Aerosol Air Freshener, effective Jan. 1, 2023 at 25% VOC
• Hair Care Products
– Hair Finishing Spray—VOC limit reduced from 55% VOC to 50% VOC, effective Jan. 1, 2023
– No-Rinse Shampoo gets a name change to Dry Shampoo and, for the first time, has a VOC limit—55%, effective Jan. 1, 2023 and a future effective date of Jan. 1, 2029 at 50% VOC
– Hair Shine and Temporary Hair Color—VOC limits are reduced from 55% VOC to 50%, effective Jan. 1, 2029
• Personal Fragrance Product (PFP)
– PFP Aerosol and non-aerosol with 7% or less fragrance—the VOC limit is reduced from 75% VOC to 70% VOC, effective Jan. 1, 2023. PFP non-aerosol with 7% or more fragrance is at 75% VOC, effective Jan. 1, 2023
– PFP Aerosol and non-aerosol with 10% or less fragrance, the VOC limit is reduced from 70% VOC to 50% VOC, effective Jan. 1, 2031. PFP non aerosol with more than 10% fragrance is at 75% VOC, effective Jan. 1, 2031
• Crawling Bug Insecticide (Aerosol)—VOC limit is being reduced from 15% VOC to 8% VOC, effective Jan. 1, 2030. In addition, a new category was developed—Bed Bug Insecticide (Aerosol), which will have a VOC limit of 15%, effective Jan. 1, 2030
• There is a sunsetting of the 2% Fragrance Exemption as of Jan. 1, 2031. For General Purpose Cleaners non-aerosol, General Purpose Degreasers non-aerosol, Air Fresheners, Disinfectants and Sanitizers, a 0.25 fragrance exemption will remain. Before Jan. 1, 2031, General Purpose Cleaners non-aerosol and General Purpose Degreaser non-aerosol have a monoterpene maximum of 0.25% by weight
• Perchloroethylene, trichloroethylene, methylene chloride and Parachlorobenzenetrifluoride (PCBTF) are prohibited in Manual Aerosol Air Freshener, Concentrated Aerosol Air Freshener, Total Release Aerosol Air Freshener, Crawling Bug Insecticide (Aerosol), Dry Shampoo, Hair Finishing Spray, Hair Shine, Temporary Hair Color and PFPs. This is the first time PCBTF has been prohibited
• Definition changes to Energized Electrical Cleaner and Monoterpenes
• Changes to the Alternative Control Plan (ACP)
• Adoption of a provision to the Innovative Product Exemption (IPE) to reduce or avoid the use of HFC152a by using compressed gas or liquefied gas. The IPE must maintain the same ozone forming potential (OFP). This is a very big change and allows the use of Reactivity to comply
• Three new compounds have been added to the Maximum Incremental Reactivity (MIR) Table:
– Diethyl carbonate
– Alkane mixed—minimally 90% carbon13 and higher carbon number
– HFO 1233zd
• In addition, Method 310 has had changes for clarity. SPRAY
