Regulatory Issues

Written on: June 1, 2024 by Doug Raymond

OTC Meeting
On April 22, the Ozone Transport Commission (OTC) held its Spring virtual meeting, during which it was mentioned that the Consumer Model Rules were edited. Changes included administrative and formatting updates, such as modified dates and rules. As well, it was reported that the Consumer Products Phase I, II, III and IV were reposted.

Next on the agenda is the Annual Public Meeting in Portland, ME, on June 13, 2024.

Oregon is considering a Consumer Products volatile organic compound (VOC) regulation. Our first pre-meeting was in January. Oregon has informed Industry that it is moving forward with Consumer Products and Architectural Coating rulemakings. The State was planning a Rule Advisory Committee (RAC) meeting in mid- to late May.

It is likely that Oregon will put in the OTC Model Rule IV rule. There will be more to come on this issue.

The California Air Resources Board (CARB) Consumer Products survey is likely to to be further delayed. Industry has expected the survey’s release for more than seven months now; however, CARB staffing and other issues have delayed this release. It is doubtful that we will see the survey any time before July 2024 at the earliest.


Remember, this survey will be the beginning of CARB’s next rulemaking, which is expected to be presented to its executive board in 2027. CARB is targeting 20 tons of VOC emissions reductions per day or equivalent, which is two-and-a-half times the VOC emission reductions in the last rulemaking.

Other States
Clark County, NV, showed interest in developing a rulemaking on Consumer Products VOC regulations. To date, the County has not acted on this rulemaking but has moved ahead with other VOC regulations.


Similarly, New Jersey has stated that it plans to have a rulemaking on Consumer Products to update its OTC Model Rule II to OTC Model Rule IV. However, the Garden State has not yet released a timeline for this rulemaking. SPRAY