The 2% Fragrance Exemption Sunset has an
effective date of 2031, with some exceptions...
Fragrance Exemption Sunset
The 2% Fragrance Exemption Sunset has an effective date of
2031. Exceptions include:
• 0.25% monoterpene exemption allowed in non-aerosol
General Purpose Cleaners/Degreasers in 2023
• 0.25% VOC exemption allowed for Air Fresheners,
Disinfectants and Sanitizers in 2031
VOC Reductions
CARB needed to obtain 1–2 tons per day (tpd) of VOC emissions
in the South Coast area by 2023. The VOC limits for
2023 shown on the previous page get 1.25 tpd in the South
Coast and 3.00 tpd Statewide. CARB was also required to
achieve a total of 4–5 tpd in the South Coast and 8-10 tpd
Statewide by 2031. The VOC limits for 2031 shown on the
previous page achieve a VOC reduction of 4.03 in the South
Coast and 9.80 tpd Statewide by 2031. Thus, CARB fulfills
the State Implementation Plan (SIP) commitments if all of the
VOC limits for the product categories are met.
The big question is whether Personal Fragrance products can
meet the 2031 VOC limits. If not, CARB will need to look elsewhere,
meaning it may target other VOC categories for more
emission reductions.
Other Amendments
The following amendments passed:
• Definition change for Energized Electrical Cleaner
• Prohibition of perchloroethylene, trichloroethylene,
methylene chloride and parachlorobenzotrifluoride
(PCBTF) in the above seven categories. This is to prevent
these compounds from being used. These compounds are
not used now in these categories
• Prohibition on substances with a Global Warming Potential
(GWP) higher than 150. This does not affect the use of
HFC- 152a
• Addition of diethyl carbonate, 1-chloro-3,3,3-trifluoropro-
pane, HFO-1233zd and alkane mixed-minimally 90% C13
and higher to the maximum incremental reactivity (MIR)
Table of Values
• Updates to Test Method 310
• Updates to Alternative Control Plan and Innovative
Product Exemption (IPE)
Innovative Product Exemption
Another issue that arose during the hearing was the new IPE
provision for compressed gases and the proposed IPE provision
for reactivity. The Board directed staff to work on these issues,
as well as on a possible exemption for HFO-1233zd.
Hearing Summary
All considered, the hearing went as expected with no real surprises.
Once public comments were concluded, the Board directed
the Executive Officer to determine if additional conforming
modifications to the regulations were appropriate and to make
any proposed modifications
(along with supporting
documentation) available
for public
comment for
15 days. This
15-day period
is mandated under
Government
Code Section
11346.8(c). CARB
must consider any
written comments
received during
the 15-day period,
respond to them in the
Final Statement of Reasons
and make any additional
changes, as appropriate. If a change is substantial, but not
sufficiently related to the original proposal (i.e. not reasonably
foreseeable based on the notice of proposed action), the agency
must then start another 45-day comment period.
However, another 45-day comment period is unlikely. CARB
will likely make all changes in a 15-day comment period. Be
aware that it may take 60–90 days for the 15-day comment
period to begin.
Outcome
After two years of work, Industry has VOC limits that it can
hopefully live with. The
exception might be the 50%
limit for Personal Fragrance
products. The CARB Board
instructed staff to work on
the IPE for Compressed Gas,
which is good. The resolutions
instruct staff to work on the
exemption for the HFO-1233zd,
which could lead to another tool for
Industry to use to reduce VOCs.
Finally, there was a resolution to have
CARB staff continue to work on reactivity
for use with Consumer Products. Spray
May 2021 Spray 9