Regulatory Issues
The new proposal is:
70% VOC limit Jan. 1, 2023 for:
• All aerosol Personal Fragrance Products (regardless of
fragrance content)
• Non-aerosol products less than or
equal to 7% fragrance content
Then:
50% VOC limit Jan. 1, 2031 for:
• All aerosol Personal Fragrance Products
(regardless of fragrance content)
• Non-aerosol products with less than
or equal to 10% fragrance content
This change does two things: it provides
non-aerosol products between
7% and 10% fragrance content to
reformulate, and it discourages companies
from increasing the fragrance
content to comply. CARB is also
proposing to provide a Technology
Assessment in 2026 to ensure the 50%
VOC limit is feasible.
2% Fragrance Exemption
CARB is proposing to sunset (remove)
the 2% Fragrance Exemption from all categories in 2031.
This will be a big change, as this exemption has been around
for a long time. The good news is that Industry has a decade
to review all the products and determine if a reformulation
is necessary. The bad news is this will be an incredible
amount of work, as every product containing a fragrance
will need to be reviewed not only for reformulation, but for
VOC content, as well.
Concerning General Purpose Cleaners and Non-aerosol
Degreasers, CARB is proposing to allow 0.25% monoterpenes.
This is a big win for Industry.
Above right is the chart from the CARB presentation
that summarizes the above. The entire presentation can be
found at https://ww2.arb.ca.gov/sites/default/files/2020-07/
Workshop_Presentation_July_28_2020_final.pdf
Again, there is good news/bad news. The good news is that
Hair Care products do not have to reduce VOC content to
45%. The bad news is that CARB is very close to its VOC
emission reduction. Thus, there is little room to raise any
VOC limits or change this proposal significantly.
CARB is requesting comments on this proposal, followed
by ongoing talks with Industry and possibly an additional
workshop in the Fall. The final Final Draft will be released
on Dec. 4 for a 45-day comment period. This is your very
last chance to comment or effect a change, as the Board
hearing for adoption is scheduled for Jan. 28, 2021.
Next month’s column will feature updates for all the
other issues in this rule.
CARB 2020-2021 FINAL FEES
CARB emailed its final FY2020-2021 fee invoices to manufacturers
of consumer products and architectural coatings
September 2020 SPRAY 35
Continued from page 8
on July 31. The base year for fee determination is 2018, and the
final fee rate is $192.97. Companies have 60 days to pay these
invoices. Spray