Regulatory Issues

Written on: September 1, 2016 by Doug Raymond

As of Jan.1, 2017, the California Air Resources Board (CARB) will have volatile organic compound (VOC) limits that become effective for the following Consumer Product categories.

Aerosol Adhesive categories with future effective limits are below. These new limits will be challenging to meet.

Aerosol Adhesives
Category                    Current Limit            1/1/2017 Limit

Mist Spray Adhesive              60                                30

Web Spray Adhesive              55                                40

Aerosol Coating categories with future effective limits are listed below. Similar to Aerosol Adhesive limits, these new limits will be challenging. Remember, Aerosol Coatings are regulated by Reactivity, so these are maximum incremental reactivity (MIR) limits.

Aerosol Coatings
General Coatings
Category                                Current Limits          Future Limit

                                                (06/01/2002)                (01/01/2017)

Clear Coatings                         1.50                             0.85

Flat Paint Products                 1.20                             0.80

Fluorescent Coatings              1.75                             1.30

Metallic Coatings                    1.90                             1.25

Specialty Coatings (A)

Non-flat Paint Products        1.40                             0.95

Primers                                    1.20                             0.70

Auto Body Primer                  1.55                             0.95

Exact Match Finish:

  • Engine paint                        70                             0.95
  • Automotive                          50                             0.95
  • Industrial                          2.05                             0.95

All the above categories have a three-year sell-through. Thus, any product made before 1/1/2017 (i.e. manufactured by midnight on 12/31/2016) is permitted to be sold for three years in California. This is provided that the product containers are labeled correctly with the date code and category code. If you are not using the CARB Standard date code, then codes need to be updated every year with CARB. Additional requirements become effective in order to sell the product in the last six months of the three-year sell-through. 

CARB Survey Reminder

Reporting of the 2015 sales through the CARB Survey started on July 1, 2016 and ends Nov.1, 2016. This survey is mandatory. Failure to provide the survey data could result in a Notice of Violation from CARB Enforcement to your company.


CARB staff is still proposing a ten ton emission reduction from Consumer Products in their State Implementation Plan (SIP).This is an ongoing project for the staff. The CARB element of the SIP will be added to the Districts’ elements and finalized in an Executive Board hearing proposed for January 2017. Industry has the ability to comment on the proposed SIP elements.

The good news is that South Coast Air Quality Management District (SCAQMD) has not proposed any changes to Consumer Products as they have in previous SIP submittals. Also, it does not appear as there will be any changes to the low vapor pressure (LVP) definition at this time. The final study on LVPs is not due to be finalized until December 2016.


Green Chemistry/Safer Consumer Product Regulation
The Dept. of Toxic Substance Control (DTSC) has begun its regulation of Priority Products, starting with Baby Blankets. In 2014, DTSC listed Baby Blankets, Paint Strippers and Spray Foam Insulation on its Priority Products list. With DTSC asking for comments on Baby Blankets, it is only a matter of time until its staff begins work on the remaining two categories; it will be most likely the Fall when these categories get reviewed.

Also, DTSC staff has targeted other categories for consideration in its 2015 three-year work plan. Therefore, staff will likely revisit these categories later this year.