Aerosol Coating Proposed Changes

Written on: September 1, 2013 by Doug Raymond



On August 7, the California Air Resources Board (CARB) released their proposed amendments for the Consumer Products rule and the Aerosol Coating rule. There are now 45 days to review and comment on these proposed changes. These proposed amendments are to be adopted on September 26, 2013.

Industry has been working with CARB for more than a year on these amendments. Below is a summary of each regulation:

Aerosol Coating Proposed Changes

Any product that meets the definition of an aerosol coating is regulated; this means marketers need to carefully review labels so that products are in the right category, otherwise the product could default to the lowest general-purpose coatings category limit.

  • General Coatings Maximum Incremental Reactivity (MIR) limits lowered. Effective date 01/01/2017.
  • New categories and New MIR limits for some categories called Specialty Coatings (A) effective date 01/01/2017.
  • All other specialty coatings were capped. New MIR limits effective 01/01/2015.
  • More reporting requirements.
  • Definitions added or changed to provide clarity.

Overall, the largest issue is that the General Coating limits will be very challenging to meet. Anyone that produces aerosol coatings should review this regulation completely to ensure their products are compliant and categorized properly. This will be another area where CARB enforcement will target. Therefore, we have a little over a year to make sure the Specialty Coatings label claims are correct.

 Consumer Products Proposed Changes

  • Multi-purpose Solvent and Paint Thinner have new limits and requirements in the South Coast Air Quality Management District (SCAQMD).
  • Aerosol Adhesives limits for Spray & Mist product categories have new limits as of 01/01/2017.
  • Aerosol Multi-purpose Solvent and Aerosol Paint Thinner have been defined and regulated with a VOC limit as of 1/1/2016.
  • In addition, prohibitions on Aerosol Adhesives, Aerosol Multi-purpose Solvent and Aerosol Paint Thinners for chlorinated compounds Global Warming Potential Compounds have been added.
  • Numerous definitions have been changed.

On the positive side, the following proposed changes have been added:

  • Multi-purpose lubricant VOC limit delayed until 12/31/2018.
  • All references to the LVP-VOC definition changes have been removed.
  • Dry lubricant definition clarified to not include other lubricants.
  • Addition of Single Use General Purpose Cleaner and Single Use General Purpose Degreaser definitions.
  • VOC exemption for HFO-1234ze.

Two of the bigger issues in this rule were the changes to the Mutli-purpose Solvent and Paint Thinners category, which apply to the SCAQMD area. The dropping of the Low Vapor Pressure Volatile organic Compound (LVP-VOC) definition changes due to the upcoming scientific studies was proper and provides for science to prevail on this issue

Again, I encourage everyone that manufactures a Consumer Product to review these proposed changes completely. Industry has 45 days to review and comment on this proposal.

To review the regulation changes, visit:

 OTC updates

To date, no individual states have adopted the new Ozone Transport Commission (OTC) model rule that has an effective date of 1/1/2014. State activity is expected to start this fall.

 Green Chemistry

The Safer Consumer Product Regulation was released on July 24 and will be effective in October 2013. To review, visit:


The National Conference on Weights & Measures (NCWM) was held in Louisville, KY in July. During the bag-on-valve (BOV) meeting, a manufacturer provided a presentation and proposed changes to the Laws & Regulation (L&R) committee. The proposal was to add the wording “non-aerosol” to the label and be able to have the net content declared in volume (instead of weight) for some BOV products that met a certain criteria.

Several people in the room, including members of the National Aerosol Association (NAA) opposed this proposal. The L&R committee is reviewing comments. Its next meeting is in January 2014, where hopefully a plan to proceed will occur. SPRAY