Beveridge & Diamond

California Expands Rules Limiting VOCs in Consumer Products

Beveridge & Diamond, P.C., December 7, 2010

On November 18, 2010, the California Air Resources Board (“CARB”) adopted amendments to the state’s Regulation for Reducing Emissions from Consumer Products.  The amendments require reductions in the levels of volatile organic compounds (“VOCs”) contained in eleven product categories and prohibit manufacturers from using certain toxic air contaminants (“TACs”), higher global warming potential compounds, and surfactants in products that are reformulated to meet the reduced VOC limits.  Several of the new restrictions will become effective at the end of 2012; the amendments will be fully effective by the end of 2013.

The amendments set new or lower VOC limits for the following consumer product categories:

  • Flying Bug Insecticide (Effective 12/31/2013);
  •  Furniture Maintenance Products (Effective 12/31/2013);
  • General Purpose Cleaners (Effective 12/31/2012);
  • General Purpose Degreasers (Effective 12/31/2012);
  • Glass Cleaners (Effective 12/31/2012);
  •  Heavy Duty Hand Cleaners or Soaps (Effective 12/31/2013);
  • Metal Polish or Cleaner (Both Aerosol and Non Aerosol) (Effective 12/31/2012);
  • Oven or Grill Cleaners (Both Aerosol and Non Aerosol) (Effective 12/31/2012);
  • Special Purpose Lubricants (Both Aerosol and Non Aerosol) (Effective 12/31/2012);
  • Spot Remover (Dry Clean Only) (Both Aerosol and Non Aerosol) (Effective 12/31/2012); and
  • Wasp or Hornet Insecticide (Effective 12/31/2013).

See Initial Statement of Reasons, California Air Resources Board, at Table ES-2 (Executive Summary, Page 7), available here

In addition to new or lowered VOC limits for the eleven aforementioned categories of products, the amendments will also ban the use of several chlorinated TACs (methylene chloride, perchloroethylene, and trhichloroethylene) in three product categories, prevent the use of compounds with global warming potential (“GWP”) values higher than 150 in six product categories, and prohibit the use of alkylphenol ethoxylate surfactants in five categories.  The regulations also modify Test Method 310 to analyze the VOC content of fabric softener single-use dryer products, and the aromatic compound content of paint thinner and multi-purpose solvent products.  Id. 

California regulates VOC emissions from consumer products as part of its strategy for meeting federal ambient air quality standards for ozone under the 2007 State Implementation Plan (“SIP”).  CARB estimates that it has eliminated approximately 225 tons of VOC emissions per day through existing consumer products emissions regulations.  However, CARB reports that emissions from consumer products still account for approximately 245 tons per day of VOC emissions (roughly 12% of the statewide VOC inventory).  It is expected that CARB will undertake additional rulemaking to meet its SIP commitment for VOC reductions from consumer products.

Note that the VOC limits set by CARB are in addition to, and often more stringent than, the VOC limits for consumer products set at the federal level by EPA.  Businesses (including importers and retailers) that sell, supply, offer for sale, or manufacture for sale in California VOC containing products should be aware of the California limits, even if their products are fully compliant with EPA requirements. 

For more information on the CARB regulations or on California’s regulation of VOCs in consumer and industrial products, please contact Amy M. Lincoln at (415) 262-4029,, Laura Duncan at (415) 262-4003,, or Daniel M. Brian at (415) 262-4016,