On August 1, 2022, proposed amendments to California’s Consumer Product Volatile Organic Compounds (VOC) Regulations were approved by the Office of Administrative Law and filed with the Secretary of State. These amendments are a result of the California Air Resources Board’s (CARB) efforts to reduce VOC emissions from consumer products, which CARB states are the second largest source of VOC emissions. Amendments to the regulations include:

  • New, revised, and retired product category definitions
  • Reduced VOC standards
  • Sunset of the 2% fragrance exemption
  • Revisions to CARB Method 310
  • New Maximum Incremental Reactivity Values
  • Special reporting requirements for personal fragrance products
  • Innovative product exemptions
  • New product categories for which the use of certain chemicals is prohibited

SRC Senior Consultant, Jamie Venable, provides below a digest of the active and upcoming changes and deadlines for compliance. While some of these amendments have taken affect as of 8/1/2022, many will take effect 1/1/2023 or later, as follows:

 

New, Revised, and Retired Product Category Definitions:

Revised Category Definitions:

Products manufactured BEFORE 1/1/2023

Products manufactured on or AFTER 1/1/2023

Category Energized Electrical Cleaner Category Energized Electrical Cleaner
“Energized Electrical Cleaner”:

A product that meets both of the following criteria:

1) the product is labeled to clean and/or degrease electrical equipment, where cleaning and/or degreasing is accomplished when electrical current exists, or when there is a residual electrical potential from a component such as a capacitor;

2) the product label clearly displays the statements: “Energized Equipment use only. Not to be used for motorized vehicle maintenance, or their parts;”

3) “Energized Electrical Cleaner” does not include “Electronic Cleaner”

 

 

 

“Energized Electrical Cleaner”:

A product that meets the following criteria:

  1. the product is labeled to clean and/or degrease electrical equipment, where cleaning and/or degreasing can only be performed when electrical current exists, or when there is a residual electrical potential from a component such as a capacitor; and
  2. the product label clearly displays the statements: “Energized Equipment use only. Not to be used for motorized vehicle maintenance, or their parts;”
  3. “Energized Electrical Cleaner” does not include:
    1. “Electronic Cleaner”; or
    2. Products manufactured on or after January 1, 2023, that are sold to “Automotive Maintenance Facilities” or “Automotive Repair Facilities”, as defined in CCR Title 17 Sect. 93111(c)(4)
Hair Finishing Spray Hair Finishing Spray
A consumer product that is designed or labeled for application to styled hair to provide sufficient rigidity, to hold, retain or finish the style of the hair for a period of time. “Hair Finishing Spray” includes aerosol hair sprays, pump hair sprays, spray waxes; color, glitter, or sparkle hair sprays that make finishing claims; and products that are styling and finishing product. “Hair Finishing Spray” does not include spray products that are intended to aid in styling but do not provide finishing of a hair style.

“Finish” or “finishing” means the maintaining and/or holding of previously styled hair for a period of time.

“Styling” means the forming, sculpting, or manipulating the hair to temporarily alter the hair’s shape.

A product that is labeled for application to hair once styling is complete and includes products that are labeled for both hair styling and finishing. “Hair Finishing Spray” does not include products labeled for hair styling but not labeled for finishing the hair style.

“Finish” or “finishing” means the maintaining and/or holding of a hairstyle once all styling is complete.

“Styling” means forming, sculpting, or manipulating the hair to alter the hair’s shape.

 

 

 

 

Hair Styling Product Hair Styling Product
A consumer product that is designed or labeled for application to wet, damp or dry hair to aid in defining, shaping, lifting, styling and/or sculpting of the hair. “Hair Styling Product” includes, but is not limited to, hair balm, clay, cream, creme, curl straightener, gel, liquid, lotion, paste, pomade, putty, root lifter, serum, spray gel, stick, temporary hair straightener, wax, spray products that aid in styling but do not provide finishing of a hair style, and leave-in volumizers, detanglers and/or conditioners that make styling claims. “Hair Styling Product” does not include “No Rinse Shampoo,” “Thermal Protectant,” “Hair Mousse,” “Hair Shine,” “Hair Finishing Spray,” or shampoos or conditioners that are rinsed from the hair prior to styling.

“Finish” or “finishing” means the maintaining and/or holding of previously styled hair for a period of time.

“Styling” means the forming, sculpting, or manipulating the hair to temporarily alter the hair’s shape.

A consumer product that is designed or labeled for application to wet, damp or dry hair to aid in defining, shaping, lifting, styling and/or sculpting of the hair. “Hair Styling Product” includes, but is not limited to, hair balm, clay, cream, creme, curl straightener, gel, liquid, lotion, paste, pomade, putty, root lifter, serum, spray gel, stick, temporary hair straightener, wax, spray products that aid in styling but do not provide finishing of a hair style, and leave-in volumizers, detanglers and/or conditioners that make styling claims. “Hair Styling Product” does not include “Dry Shampoo,” “Thermal Protectant,” “Hair Mousse,” “Hair Shine,” “Hair Finishing Spray,” or shampoos or conditioners that are rinsed from the hair prior to styling.

“Finish” or “finishing” means the maintaining and/or holding of a hairstyle once all styling is complete.

“Styling” means forming, sculpting, or manipulating the hair to alter the hair’s shape.

 

Hair Shine Hair Shine
Any product designed for the primary purpose of creating a shine when applied to the hair. “Hair Shine” includes, but is not limited to, dual-use products designed primarily to impart a sheen to the hair. “Hair Shine” does not include “Hair Finishing Spray,” “Hair Mousse,” “Hair Styling Product” or products whose primary purpose is to condition or hold the hair. Any product labeled for the primary purpose of creating a shine when applied to the hair. “Hair Shine” includes, but is not limited to, dual-use products designed primarily to impart a sheen to the hair. “Hair Shine” does not include “Hair Finishing Spray,” “Hair Mousse,” or “Hair Styling Product.”
Multi-purpose Solvent does not include: Multi-purpose Solvent does not include:
  1. Solvents used in cold cleaners, vapor degreasers, conveyorized degreasers or film cleaning machines;
  2. Solvents labeled exclusively for the clean-up of application equipment used for polyaspartic and polyurea coatings;
  3. Products that are labeled exclusively to clean a specific contaminant, on a single substrate;
  4. “Rubbing Alcohol;”
  5. Laboratory reagents used in analytical, educational, research, scientific or other laboratories; and
  6. Products that are used exclusively for the thinning of “Industrial Maintenance Coatings,” “Zinc –Rich Primers,” or “High Temperature Coatings” that meet both of the following criteria:
    1. the Responsible Party also manufactures for sale in California “Industrial Maintenance Coatings,” “Zinc – Rich Primers,” or “High Temperature Coatings;” and
    2. the label states the specific product or brand of the “Industrial Maintenance Coating,” Zinc-Rich Primer,” or “High Temperature Coating” for which the product is used.

 

 

 

 

 

 

  1. Solvents used in cold cleaners, vapor degreasers, conveyorized degreasers or film cleaning machines;
  2. Solvents labeled exclusively for the clean-up of application equipment used for polyaspartic and polyurea coatings;
  3. Products that are labeled exclusively to clean a specific contaminant, on a single substrate;
  4. “Rubbing Alcohol;”
  5. Laboratory reagents used in analytical, educational, research, scientific or other laboratories; and
  6. Products that are used exclusively for the thinning of “Industrial Maintenance Coatings,” “Zinc –Rich Primers,” or “High Temperature Coatings” that meet both of the following criteria:
  7. the Responsible Party also manufactures for sale in California “Industrial Maintenance Coatings,” “Zinc – Rich Primers,” or “High Temperature Coatings;” and
  8. the label states the specific product or brand of the “Industrial Maintenance Coating,” Zinc-Rich Primer,” or “High Temperature Coating” for which the product is used.
  9. Denatured alcohol products that are sold directly or through distributors to a “Public Utility” as defined by §216 of the Public Utilities Code, and is used to maintain electrical equipment that meet both of the following criteria:
    1. the equipment is owned by a “Public Utility”; and
    2. the equipment manufacturer states that maintenance can only be performed with        denatured alcohol.

Retired Product Categories*:

  • Single Phase Aerosol Air Freshener
  • Double Phase Aerosol Air Freshener
  • No Rinse Shampoo

*Product Categories not applicable to products manufactured on or after 1/1/2023

 

New Product Categories/Subcategories:

Category/Subcategory Effective Date VOC Standard
Automatic Aerosol Air Freshener

An aerosol “Air Freshener” that is labeled to be used in an “Automatic Air Freshening Dispenser” (device labeled to dispense an automatic aerosol air freshener at a predetermined time or interval of time, under preset conditions, and/or due to sensor activation).

1/1/2023 30
Manual Aerosol Air Freshener

An aerosol “Air Freshener” that is designed or labeled to be handheld and/or manually activated. A “Manual Aerosol Air Freshener” is not a “Concentrated Aerosol Air Freshener” or a “Total Release Aerosol Air Freshener” or a “Dual Purpose Air Freshener/Disinfectant.”

1/1/2023

1/1/2027

10

5

Concentrated Aerosol Air Freshener

A “Manual Aerosol Air Freshener” enclosed under pressure which:

(1) contains 15 percent or more fragrance

(2) is designed with a valve that permits the dispensing of no more than 185 microliters of product upon each activation, and

(3) is sold in aerosol containers of two ounces or less by weight.

1/1/2023

1/1/2027

15

10

Total Release Aerosol Air Freshener

An aerosol air freshener product enclosed under pressure which

(1) dispenses all or most of its contents during a single application, and

(2) is sold in containers of five ounces or less by weight.

 

1/1/2023 25
Dry Shampoo

A product labeled to be applied to hair and massaged or brushed/combed through the hair for the purpose of cleaning the hair without needing to be rinsed.

1/1/2023

1/1/2029

55

50

Bed Bug Insecticide

Any insecticide product that is designed for use against the adult, nymph, or eggs of insects that belong to the family Cimicidae and the genus Cimex,which includes species such as Cimex lectularius (Common Bed Bugs) and Cimex hemipterus (Tropical Bed Bugs.)

1/1/2030 All forms: 20

Aerosol: 15

Plastic Pipe Adhesive

An “Aerosol Adhesive” labeled exclusively to bond segments of acrylonitrile butadiene styrene (ABS), polyvinyl chloride (PVC), or chlorinated polyvinyl chloride (CPVC) pipe together.

8/1/2022 60

Reduced VOC Standards:

Category/Subcategory

Effective Date

VOC Standard

Hair Finishing Spray 1/1/2023 50
Hair Shine 1/1/2029 50
Temporary Hair Color 1/1/2029 50
Crawling Bug Insecticide, Aerosol 1/1/2030 8
Personal Fragrance Products, Aerosol 1/1/2023

1/1/2031

70

50

Personal Fragrance Products, Nonaerosol; ≤7% fragrance 1/1/2023 70
Personal Fragrance Products, Nonaerosol; >7% fragrance 1/1/2023 75
Personal Fragrance Products, Nonaerosol; ≤10% fragrance 1/1/2031 50
Personal Fragrance Products, Nonaerosol; >10% fragrance 1/1/2031 75

Sunset of 2% Fragrance Exemption:

The 2% combined fragrance exemption will no longer apply to consumer products as of 1/1/2031, with the following exceptions:

Product Category

Products manufactured on or after 1/1/2031

General Purpose Cleaner, Nonaerosol Exemption up to a 0.25% by weight of combined fragrances and/or monoterpenes*
General Purpose Degreaser, Nonaerosol Exemption up to a 0.25% by weight of combined fragrances and/or monoterpenes*
Air Freshener Exemption up to a 0.25% by weight of combined fragrances
Disinfectant Exemption up to a 0.25% by weight of combined fragrances
Sanitizer Exemption up to a 0.25% by weight of combined fragrances

*A monoterpene is defined as one or more of the following chemical compounds:

  • Limonene (CAS No. 5989-27-5, d-isomer) (CAS No. 5989-54-8, l-isomer)
  • Dipentene (CAS No. 138-86-3, dl-limonene)
  • α-pinene (CAS No. 8056-8) (CAS No. 7785-70-8, d-isomer), (CAS No. 7785-26-4, l-isomer)
  • β-pinene (CAS No. 127-91-3) (CAS No. 18172-67-3, l-isomer)

 

CARB Method 310 Revisions:

  • Clarification concerning referenced test methods
  • Revised equations to calculate VOCs and reactive organic content (ROCs)
  • New Calculation to determine product-weighted maximum incremental reactivity PWMIR using ROC compounds
  • Revisions concerning when enforcement actions may be taken

*See the Final Executive Order for all revisions.

 

New Maximum Incremental Reactivity Values:

  • 1-chloro-3,3,3-trifluoropropene; HFO-1233zd: 4
  • Alkane Mixed – Minimally 90% C13 and higher carbon number: 60
  • Diethyl carbonate: 71

 

Special Reporting Requirements for Personal Fragrance Products Containing 10% by Weight of Combined Fragrance Ingredients:

Responsible parties must submit the following information to the Executive Officer By 3/31/2026:

  • Product sales data and composition for the year 2025
  • VOC content of fragrance ingredients, if requested by the executive officer
  • Entire product label
  • Written update concerning research and development efforts to date to achieve the VOC standard of 50% by weight. Report must include:
    • Cost of reformulation efforts
    • Discussion of past, planned, & ongoing research to meet VOC standard of 50% by weight
    • Detailed description and date of steps taken to achieve compliance, including but not limited to:
      • Types of formulations to be tested
      • Formulation data
      • Prototype testing
      • Toxicity testing and research
      • Stability testing
      • Expert olfactory odor testing
      • Consumer acceptance research

 

Innovative Product Exemptions:

Potential exemptions for Innovative Gas Propellant Product or Innovative Liquefied Propellant Product in the following categories when the criteria below is met*:

  • Hair Finishing Spray
  • Dry Shampoo
  • Personal Fragrance Product

Criteria:

Innovative Compressed Gas Propellant Product:

  • For a product manufactured before 1/1/2029
    • HFC-152a propellant is replaced with propellant comprised of compressed air, compressed nitrogen, and/or compressed carbon dioxide
    • Use of replacement propellant will result in the innovative gas propellant product achieving ≥50% reduction in greenhouse gas emissions compared to the representative HFC 152a product
  • For a product manufactured on or after 1/1/2029:
    • Only includes ingredients with a global warming potential <10; or, achieves ≥90% reduction in greenhouse gas emissions compared to the representative HFC-152a product
  • Weight of the product propellant(s) does not exceed 50% by weight of the representative HFC-152a product propellant(s)
  • The ozone forming potential does not exceed that of the representative HFC-152a product

Innovative Liquefied Propellant Product:

  • For a product manufactured before 1/1/2029
    • Achieves ≥50% reduction in greenhouse gas emissions compared to the representative HFC-152a product
  • For a product manufactured on or after 1/1/2029
    • Only includes ingredients with a global warming potential <10; or, achieves ≥90% reduction in greenhouse gas emissions compared to the representative HFC-152a product
  • The ozone forming potential does not exceed that of the representative HFC-152a product

 

*Manufacturer must apply in writing to the Executive Officer for exemption. See the Final Executive Order for detailed information on representative HFC-152a product definition and formulations.

 

New Product Categories Added to List Where use of Certain Chemicals is Prohibited:

Use of methylene chloride, perchloroethylene, and trichloroethylene is prohibited

Product Category

Effective Date

Sell-Through Date

Plastic Pipe Adhesive 8/1/2022 8/1/2025

Use of parachlorobenzotrifluoride, methylene chloride, and trichloroethylene is prohibited

Product Category

Effective Date

Sell-through Date

Manual Aerosol Air Freshener 1/1/2023 1/1/2026
Concentrated Aerosol Air Freshener 1/1/2023 1/1/2026
Total Release Aerosol Air Freshener 1/1/2023 1/1/2026
Crawling Bug Insecticide 1/1/2030 1/1/2033
Dry Shampoo 1/1/2023 1/1/2026
Hair Finishing Spray 1/1/2023 1/1/2026
Hair Shine 1/1/2029 1/1/2032
Temporary Hair Color 1/1/2029 1/1/2032
Personal Fragrance Products containing ≤7% fragrance 1/1/2023 1/1/2026
Personal Fragrance Products containing 7% – ≤10% fragrance 1/1/2031 1/1/2034

Use of any chemical that has a global warming potential value ≥150 is prohibited

Product Category

Effective Date

Sell-through Date

Plastic Pipe Adhesive 8/1/2022 8/1/2025
Manual Aerosol Air Freshener 1/1/2023 1/1/2026
Concentrated Aerosol Air Freshener 1/1/2023 1/1/2026
Total Release Aerosol Air Freshener 1/1/2023 1/1/2026
Crawling Bug Insecticide 1/1/2030 1/1/2033
Dry Shampoo 1/1/2023 1/1/2026
Hair Finishing Spray 1/1/2023 1/1/2026
Hair Shine 1/1/2029 1/1/2032
Temporary Hair Color 1/1/2029 1/1/2032
Personal Fragrance Products containing ≤7% fragrance 1/1/2023 1/1/2026
Personal Fragrance Products containing 7% – ≤10% fragrance 1/1/2031 1/1/2034

 

SRC has instituted these changes into our VOC ingredient spreadsheet for VOC content review. In addition to EPA, FDA, and State pesticide registration services, the SRC team has the expertise to assist you with VOC requirements related to your products. Please contact your SRC consultant for assistance with VOC compliance questions or for a full ingredient review of your product.


Jamie Venable

Senior Consultant

Posted: 10/04/2022