Spray Decemberr 2016 Regulatory Issues Doug Raymond Raymond Regulatory Resources 8 Spray December 2016 Upcoming effective dates As of Jan. 1, 2017, the California Air Resources Board (CARB) has future effective volatile organic compounds (VOC) limits that come into effect. A detailed chart of future VOC limits for Aerosol Adhesives and Aerosol Coatings can be found in the complete version of this column found at These limits are not easy to meet. There is a three-year sell-through for all products made before the effective date. Firstly, requirements for sell-through products state that all products must be date coded before the effective date. Secondly, products sold in the last six-months of the sell-through period must have a notification from the seller to the buyer that this product is to be sold in the next six months. Thus, if your reformulations are not finished yet, make sure your company has enough products to last until your reformulation is complete. Multi-purpose Lubricant Report If you are a multi-purpose lubricant manufacturer or marketer, then a report on your progress toward the 12/31/2018 future effective VOC limit of 10% is required. This report is due before 3/31/2017. The report requires product and formula data from 2016, plus the label and other information required in Section 94513(a) of the CARB Consumer Products regulation. A detailed list of all requirements will be in the January issue of Regulatory Issues, so stay tuned. In addition, CARB staff needs an update on research and development efforts taken by your company to meet the 10% future VOC limit. More to come next month. Ozone Transport States Ozone Transport States of Delaware and New Hampshire have new VOC limits coming into effect in 2017. These new limits are the same as some of the current limits at CARB. Also, if the product is made before the effective date and properly date coded, the sell-through period is indefinite. For the complete chart, visit this column at Aerosol 101 Make sure to review the article on the CARB Aerosol 101 on p. 44 of this issue of SPRAY. It was a great meeting and a wonderful opportunity for the aerosol industry! Spray

Spray Decemberr 2016
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