CARB
On Nov. 7, California Air Resources Board (CARB) staff held a public workshop to reveal its proposal for
the next round of rulemaking. CARB has been reviewing Consumer Product categories since April of 2019
to determine which categories will be designated for volatile organic compound (VOC) reductions.
The CARB process has been very comprehensive. Staff surveyed over 400 product categories from over
1,500 product manufactures. In all, approximately one million products were reviewed. This year, CARB
started with 49 product categories that contained 0.5 tons per day (tpd) of emissions or more. After 11
work group meetings, staff eliminated 32 product categories; this left 17 product categories. Staff held three
workgroup webinars to review these 17 categories.
CARB, due to its State Implementation Plan (SIP) commitments, needs to get VOC reductions from
Consumer Products. The SIP commitments are 2.4–4.8 tpd statewide by 2023 and 9.5–11.9 tpd statewide
by 2031. Note the 2031 requirements are inclusive of the 2023 requirements and not in addition to them.
This amount of emission reduction is significant and will be difficult to achieve.
The current proposal contains six product categories and a sunset of the fragrance exemption. The categories
to be regulated are the following:
Manual Aerosol Air Freshener. This will be a completely new category. CARB is proposing to combine the
Single Phase Aerosol Air Freshener and the Double Phase Aerosol Air Freshener into one category. Both of
these categories have been in place for a long time. This new category will have the following limits:
n By Jan. 1, 2023 n By Jan. 1, 2031
• VOC standard of 10% by weight • VOC standard of 5% by weight
• VOC reduction: 1.0 tpd • VOC reduction: 1.8 tpd
In addition, a new category for automatic Air Freshener products will be created at 30% VOC. If you are in
this category, you need to review this proposal and comment. This is a significant change for Air Fresheners.
Hair Finishing Spray
n By Jan. 1, 2023 n By Jan. 1, 2027
• VOC standard of 50% by weight • VOC standard of 45% by weight
• VOC reduction: 1.1 tpd • VOC reduction: 2.7 tpd
This category has not been regulated since 1999. The proposal is seeking significant reductions.
No Rinse Shampoo
n By Jan. 1, 2023 n By Jan. 1, 2027
• VOC standard 50% by weight • VOC standard 45% by weight
• VOC reduction: 0.7 tpd • VOC reduction: 0.9 tpd
This is the first time this category has been regulated. Considering it only has 1.3 tpd of VOC emissions, it
seems that trying to get 0.9 tpd of emission reductions will be difficult to achieve. In addition, dry conditioners
and foams will be included in this category.
Personal Fragrance Products (20% or less fragrance)
n By Jan. 1, 2023 n By Jan. 1, 2027
• VOC standard of 65% by weight • VOC standard of 50% by weight
• VOC reduction: 1.7 tpd • VOC reduction: 5.8 tpd
This category will achieve almost half of the VOC emission reductions needed for total reduction.
Aerosol Crawling Bug Insecticide
n By Jan. 1, 2023 n By Jan. 1, 2027
• VOC standard of 10% by weight • VOC standard of 6% by weight
• VOC reduction: 0.4 tpd • VOC reduction: 0.9 tpd
Aerosol Crawling Bug Insecticide is a U.S. Environmental Protection Agency (EPA) registered product. A
company would need to go through the Federal and State registrations twice in four years, incurring a great
deal of expense and wasted time. Does it make sense to regulate the product twice in four years?
aeropres.com
dscontainers.com
diversifiedcpc.com
formulatedsolutions.com
fluorineproducts-honeywell.com/
solstice-propellants
ikimfg.com
lindalgroup.com
powercontainer.com
precisionglobal.com
terco.com
Regulatory Issues
Doug RaymonD
Raymond Regulatory Resources
summitpackagingsystems.com
8 Spray December 2019
Continued on page 47