Cassandra Taylor
Canada’s proposed VOC Limits Nexreg Compliance Inc.
for Certain Products Regulations
Regulatory Specialist,
Regulatory International
Influences
In July 2019, the government of Canada released an amended
version of the draft Volatile Organic Compound (VOC) Concentration
Limits for Certain Products Regulations (known as the
proposed Regulations). Originally drafted in 2008, the proposed
Regulations established VOC concentration limits for certain
product categories not already covered by other Canadian regulations.
Preliminary consultations for the proposed regulations
took place in 2013. A consultation document titled Revisions to the
Proposed Volatile Organic Compound Concentration Limits for Certain
Products Regulations was released for comment and a total of 29
written submissions were received from stakeholders. The public
consultation process formed the basis for the 2019 revision of the
proposed Regulations.
The proposed Regulations would prohibit the import and
manufacture of products in
Canada that exceed the prescribed
VOC concentration limits
in approximately 130 product categories
and subcategories. Where
possible, the proposed Regulations
would align with the 2010
California Air Resources Board
(CARB) Consumer Products Regulations.
Due to Canada’s colder
climate, the proposal includes
some deviations from California’s
standards, including a higher
limit for non-chemically curing
sealant and caulking products, addition
of a category for acoustical
sealants and the exclusion of the
windshield washer fluid category.
What products are affected?
Certain products deemed to contribute to VOC emissions that
are used by household, institutional and commercial consumers
will be restricted. Specific product categories include personal
care, automotive and household maintenance products; adhesives,
adhesive removers, sealants and caulks; and other miscellaneous
products.
The proposed Regulations apply to any product that contains
VOCs and belongs to a product category that is set out in Column
1 of the table to Schedule 1, or Column 1 of Schedule 2. VOC
limits are measured and expressed as a percentage of the product’s
net weight.
The following products are excluded from the proposed Regulations:
• Designed to be used solely in a manufacturing or processing
activity;
• To be used solely in a laboratory for analysis, in scientific
research or as a laboratory analytical standard;
• Regulated under the Pest Control Products Act;
• Manufactured or imported for export only;
• Adhesives that are to be sold in containers of 0.03 l or less;
• Regulated under the Volatile Organic Compound (VOC)
Concentration Limits For Architectural Coatings Regulations or the
Volatile Organic Compound (VOC) Concentration Limits For
Automotive Refinishing Products Regulations;
• Are used in or on a new car at the time of its manufacture; or
• In transit through Canada, from a place outside Canada to
another place outside Canada.
Product categorization
One noteworthy deviation from CARB’s Consumer Products Regulations
is the product category definitions. The proposed Regulations
did not adopt the text of CARB’s definitions. A product is
considered to belong in a product category under Schedule 1 or
Schedule 2 if it is indicated anywhere on its container, or in any
documentation relating to the product that is supplied by the
product’s manufacturer, importer or their authorized representative,
that the product may be used as a product that fits within that
product category.
30 Spray December 2019
Due to Canada’s colder climate, the proposed Regulations include some
deviations from CARB’s standards, including a higher limit for non-chemically
curing sealant and caulking products, the addition of a category for acoustical
sealants and the exclusion of the windshield washer fluid category.