I hope that you all had healthy and happy holidays! Welcome to a New Year—a new year with the same
issue: The California Air Resources Board (CARB).
CARB
CARB rule development is entering its final phase. It started developing amendments to the Consumer
Products volatile organic compound (VOC) regulation in May of 2019. Industry has been working closely
with CARB for the past 18 months to develop a regulation that reduces VOCs in our products but allows
manufacturers to produce effective and efficient products. Remember, CARB needs to attain emission
reductions of 2–4 tons per day (TPD) of VOC emissions by 2023 and 8–10 TPD of VOC emissions by
2031. The 8–10 TPD is inclusive of the 2–4 TPD, not in addition to it. This is no easy feat to accomplish.
On Jan. 8, 2021, CARB will publish its 45-day final draft regulation. In March, the CARB Executive
Board will vote on the adoption of these amendments.
Thus, Industry needs to comment on the draft final amendments when published. From the Nov. 10
workshop/webinar we can expect the following:
Categories targeted for reductions
Air Fresheners
• Manual Air Fresheners: a combination of the Single & Double Phase Air Freshener category
o VOC limit proposed 10% in 2023
o Future effective VOC limit proposed 5% in 2027
• Automatic Aerosol Air Freshener: a product used in a dispenser
o VOC limit proposed 30% in 2023
o No future VOC limit proposed
• Concentrated Aerosol Air Freshener: a new product category formed in this rule development
o VOC limit proposed 15% in 2023
o Future effective limit proposed 10% in 2027
• Total Release Air Freshener: a new product category formed in this rule development
o VOC limit proposed 25% in 2023
o No future effective VOC limit proposed
Hair Care Products
• Hair Finishing Spray (Hair Spray)
o VOC limit proposed 50% in 2023
o No future effective limit proposed
o CARB dropped the 45% proposed future effective limit
• Dry Shampoo
o VOC limit proposed 55% in 2023
o Future effective VOC limit 50% in 2029
o CARB modified future effective VOC limit from 45% to 50%
• Hair Shine & Temporary Hair Color
o VOC limit proposed 50% in 2029
Personal Fragrance
• Aerosol Personal Fragrance Products: a new product category formed in this rule development
o VOC limit proposed 70% in 2023
o Future effective VOC limit 50% in 2031
• Non-aerosol product ≤ 7% fragrance: a new product category formed in this rule development
o VOC limit proposed 70% in 2023
• Non-aerosol products with ≤ 10% fragrance: a new product category formed in this rule development
o VOC limit proposed 50% in 2031
Note: For fragrance in non-aerosol products, the percentage changes from 7% in 2023 to 10% in 2031.
Also, CARB is proposing a technology assessment in 2025 for personal fragrance products in anticipation
of the 2031 VOC limit.
aeropres.com
dscontainers.com
diversifiedcpc.com
powercontainer.com
precisionglobal.com
terco.com
Regulatory Issues
Doug Raymond
Raymond Regulatory Resources
summitpackagingsystems.com
8 Spray January 2021
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