Aerosol Coatings and Aerosol Adhesives – CARB amendments

Written on: June 1, 2013 by Doug Raymond


California Air Resources Board (CARB) issues remain the topic of the industry. On April 24,
CARB staff held a workshop to discuss amendments to the Consumer Products VOC regulation. CARB amendments to volatile organic compounds (VOC) standards are focused on two product categories: Aerosol Coatings and Aerosol Adhesives.

Remember, most of the Specialty Coating limits were capped at the highest levels that were reported. They are proposed to be effective on 1/1/2015. Other Specialty Coatings Categories were added at relatively high levels as well; the proposed effective date is 1/1/2017. One major change is that every aerosol coating will be included in this regulation regs-chart-1unless specifically exempted.

This means that if your product meets the definition of an aerosol coating, then the product needs to be placed in one of the categories. Make sure if the product is a specialty coating that the product displays claims only for that category or the product will be subject to the Most Restrictive limit provision.

In addition, numerous definitions were added into the Aerosol Coating regulations such as Resin, Coating Solid etc. Again, please review this regulation.

Remember, all other Specialty Adhesives are unchanged. These limits are very low; however, CARB states that these limits are technologically feasible.

The big news is that CARB staff has significantly modified their proposal to remove the changes to the LVP-VOC definition. This is a welcome change. Industry was concerned with any changes to the LVP-VOC definition until the scientific studies have been regs-chart-2completed. In March 2013, CARB Executive Board voted to consider studies on the LVP-VOC topic. Later in May 2013, CARB Scientific Committee reviewed the proposal on the LVP-VOC research. The Executive Board will likely vote in June to approve work on these studies. Again, this was a significant and positive change to the proposal. Scientific research on the LVP-VOC issue is needed before any changes should be made.

In addition, changes to the Multi-purpose Solvent and Paint Thinner categories were made. The changes affects how these two product categories can be sold in the South Coast Air Quality Management District only. This is consistent with the District Rule 1143. In addition, a 10% limit has been proposed for Aerosol Multi-purpose Solvents and Paintregs-chart-3 Thinners.
Other changes worth noting:
• Change to General Purpose Degreaser definition.
• Definitions added for Specialty Purpose Cleaners and Special Purpose Degreaser.
• Proposal for HFO-1234ze to be added as a VOC exempt compound.
• Changes to Hair Finishing Spray and Hair Styling Spray definitions.
• 10% VOC limit for Multi-purpose Lubricant proposed delay from 12/31/2015 to 2/31/2018.

regs-chart-4I encourage everyone to review the Consumer Product Regulation and the Aerosol Coating regulation to ensure that none of the changes have an adverse effect on your products. The proposed changes can be found at

regs-chart-5Lastly, CARB has delayed this rule adoption until September 26–27, 2013. This means that the official proposal will not be released until July 2013 for a 45-day comment period.

regs-chart-6Other upcoming meetings
• Ozone Transport Commission (OTC), June 13, 2013, New Haven, CT
• Natural Conference on Weights & Measures (NCWM), July 14–18, 2013, Louisville, KY Spray