CARB
On July 28, the California Air Resources Board (CARB) held a fourth workshop via webinar concerning
amendments to its Consumer Products volatile organic compound (VOC) regulation, whose rule development
began in April of 2019. CARB is required to regulate Consumer Products to achieve the maximum
feasible reduction in VOC emissions. However, the regulations must be technologically and commercially
feasible and not eliminate a product form.
CARB needs to achieve VOC emission reductions required by the State Implementation Plan (SIP). For
2023, CARB needs to achieve between 4–5 tons per day (TPD) statewide and a total of 8–10 TPD by 2031.
CARB posted what could be its final draft proposal of categories and VOC limits during this webinar.
Proposed categories are Manual Air Fresheners, Crawling Bug Insecticide, Hair Care Products, Personal Fragrance
Products and a sunsetting of the Fragrance Exemption.
CARB has kept much of its proposal the same but has made some changes. Below are detailed explanations
of each category with VOC limits and effective dates as proposed:
Manual Aerosol Air Freshener
This category is a combination of two existing categories. The Single and Double Phase Aerosol Air Freshener
categories will be combined into the Manual Aerosol Air Freshener category starting Jan. 1, 2023. The proposed
VOC limit for this new category is 10% VOC by Jan. 1, 2023. Currently, the Single and Double Phase
categories are at 30% and 20%. This will mean a significant reduction in the VOC limit and there will be a
further limit reduction to 5% VOC in 2027. Therefore, Aerosol Air Fresheners are in for a significant VOC
reduction.
With the creation of this new Manual Air Freshener category, CARB has also created three new niche
categories of Aerosol Air Fresheners:
1. Automatic Aerosol Air Freshener for use in dispensers with a VOC limit of 30% in 2023.
2. Concentrated Aerosol Air Freshener (which has a very restrictive definition) has a VOC limit of 15% in
2023 and 10% VOC limit in 2027.
3. Total Release Air Freshener with a VOC limit of 25% in 2023. No future effective limit.
The Aerosol Air Freshener category will look completely different starting in 2023.
Aerosol Crawling Bug Insecticide
This category currently has a VOC limit of 15%, and CARB is proposing that it be reduced to 6% VOC in
2030. This is a change from CARB’s original proposal that required a step-down reduction in the VOC limit.
Industry preferred only one reduction in the VOC limit, and due to it being a U.S. Environmental Protection
Agency (EPA)-registered pesticide product, Industry also preferred only one reformulation. CARB, however, is
allowing products solely for use on bedbugs to remain at 15% VOC.
Hair Care Products
CARB is proposing new VOC limits on Hair Finishing Sprays, Dry Shampoo, Hair Shine and Temporary
Hair Color. Originally, CARB proposed VOC limits for Hair Spray and Dry Shampoo at 50% in 2023 and
45% in 2027. It then added Hair Shine and Temporary Hair Color with a VOC limit of 45% in 2027.
Now for the big change! There will be no further reduction for Hair Spray—or any other Hair Care product
categories—as the proposed 45% VOC limit has since been dropped. The Dry Shampoo limit has now been
changed to 55% VOC in 2023 and 50% VOC in 2029. Hair Shine and Temporary Hair Color will need to
reduce their VOC from the current 55% to 50% in 2029.
CARB Enforcement seeks to have all Hair Care products at the same limit so that there is no confusion
with claims.
To reiterate, by CARB abandoning the 45% VOC future effective limit, it loses a significant portion of
VOC reductions.
Personal Fragrance Products
This category may be the most complicated category to explain. CARB’s original proposal was:
• 68% VOC limit by Jan. 1, 2023 for all products under 10% Fragrance content
• 50% VOC limit by Jan. 1, 2027 for all products under 10% Fragrance content
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Regulatory Issues
Doug Raymond
Raymond Regulatory Resources
summitpackagingsystems.com
8 Spray September 2020
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