Written on: March 1, 2025 by Doug Raymond
CARB Survey
The aerosol industry is tasked with completing the California Air Resources Board (CARB) 2023 Consumer Products survey. This is the first step toward the next Consumer Products rulemaking. It is vitally important that Industry supply this information to CARB, whose staff will use it to evaluate new limits for these categories. To be very clear, just because a product category is being surveyed does not necessarily mean that the product category will be regulated, nor does it mean a new limit for already-regulated product categories. CARB staff will review all of the data for the product categories and determine if a reduction can be reached. Thus, if you believe that your product could reduce the amount of volatile organic compounds (VOCs), then it makes sense to try and educate CARB on your product.
Remember, it is extremely likely that CARB will use Reactivity to either regulate new categories or provide a new limit for existing regulated product categories in this rulemaking. Educating CARB staff on what reduction you can provide on your products is always a reasonable thing to do.
Please note that this is a zero-sum issue, meaning CARB will need to get its emission reductions. If it doesn’t get its reduction from one product category, it may need to get more reductions from another category—possibly yours!
The more CARB knows about the limitations of your product the better it can determine if or how much reduction can be taken from that category. It is always best to explain to CARB staff what you can do before stating that there is nothing you can do. Industry has been telling CARB for 25 years that we cannot reduce VOCs in our products. Every rulemaking, a manufacturer testifies that it cannot reduce VOC. Guess what, 99 out of 100 times, Industry finds ways to reduce the VOC in a product. Hopefully, during this rulemaking using Reactivity, Industry will find more flexibility in reformulating and will possibly make emission reductions easier; perhaps this is wishful thinking.
All of the categories being surveyed are listed below. Please review, and if your products fall into one or more of these categories, you should be working on this survey. If not, your company needs to begin immediately. The better the information, the better the rules will be. The CARB deadline is April 8, 2025.
Sector: Adhesives, Sealants & Related Products
* “Code” refers to Survey Code
Subsector: Adhesives
Code Category Name
10115 Plastic Pipe Cement & Primer
Subsector: Sealants & Caulks
Code Category Name
10209 Sealant or Caulking Compound– Chemically Curing
10210 Sealant or Caulking Compound–Nonchemically Curing
Sector: Household & Institutional Products
Subsector: Air Fresheners
Code Category Name
20103 Dual Purpose Air Freshener/Disinfectant (aerosol)
20104 Air Freshener, liquid/pump spray
Subsector: Cleaners & Degreasers
Code Category Name
20305 Disinfectant (aerosol)
20311 General Purpose Cleaner (non-aerosol)
20312 General Purpose Degreaser (aerosol)
20313 General Purpose Degreaser (non-aerosol)
20321 Metal Polish/Cleanser (aerosol)
20326 Oven or Grill Cleaner (non-aerosol)
Subsector: Fabric, Carpet & Upholstery Care Products (Non-Laundry Products)
Code Category Name
20504 Carpet & Upholstery Cleaner (non-aerosol, dilutable)
20513 Spot Remover (non-aerosol)
Subsector: Laundry Products
Code Category Name
20903 Detergent
20919 Liquid Fabric Softener
Subsector: Miscellaneous Household Products
Code Category Name
21003 Cutting or Tapping Oil (aerosol)
21012 Multi-purpose Dry Lubricant
21014 Penetrant
21018 Rust Preventative or Rust Control Lubricant (aerosol)
Subsector: Shoe & Leather Care Products
Code Category Name
21301 Footwear or Leather Care Product (aerosol)
21303 Footwear or Leather Care Product (all other forms)
Subsector: Waxes Polishes
Code Category Name
21405 Floor Wax Stripper
Sector: Personal Care Products
Subsector: Antiperspirants & Deodorants
Code Category Name
30101 Antiperspirant
30102 Deodorant
Subsector: Body, Hand & Face Cleaners
Code Category Name
30201 Anti-microbial Dry Hand Wash (Hand Sanitizer)
30207 Body Wash/Mousse/Gel/Soap/Foam/Scrub
Subsector: Facial & Body Treatment
Code Category Name
30404 Hand & Body Conditioner, Cream, Lotion and Moisturizer
30411 Sunscreen (hair or body) (aerosol)
Subsector: Hair Care Products
Code Category Name
30602 Conditioner without styling claims
30603 Dye, permanent
Sector: Solvent & Thinning – Related Products
Subsector: Miscellaneous Solvents & Thinning Products
Code Category Name
60203 Clean Up Solvent
60211 Lacquer Thinner
60213 Multi-purpose Solvent (nonaerosol)
60214 Paint Remover or Stripper
60216 Paint Thinner (nonaerosol)
60223 Thinner/Reducer/Retardant (Motor Vehicle Coating Systems)
Sector: Vehicle & Marine Vessel Aftermarket Products
Subsector: Detailing Products
Code Category Name
70117 Undercoating (aerosol only) SPRAY
