Written on: June 1, 2025 by Nicholas Georges
California has long been at the forefront of environmental protection in the U.S., especially when it comes to air quality. The California Air Resources Board (CARB) leads this charge by working collaboratively with stakeholders, including Industry, to set air quality standards in the U.S. and around the world.
CARB uses a testing procedure i called CARB Method 310 (Method 310) to determine the total volatile organic compounds (VOCs) in consumer products and reactive organic compounds (ROCs) in aerosol coatings to ensure compliance with CARB’s regulations.
Companies are not responsible for conducting this testing. Rather, a theoretical calculation of a product’s regulatory VOC content or Maximum Incremental Reactivity (MIR) value is sufficient. However, companies need to ensure that their calculations are consistent with Method 310. It is also important to understand what is involved with this test and how it fits into the overall enforcement process—should CARB enforcement ever need to issue a notice of potential violation.
CARB learns about potential violations through inspections, tips from the public, data analysis, referrals from other agencies, mandatory emissions reporting and voluntary disclosures. For inspections, CARB enforcement will obtain products from store shelves or purchase them through e-commerce for testing as part of their compliance verification process.
After obtaining samples, CARB will utilize Method 310 for testing. The method describes sampling procedures, the different analytical techniques that can be used to calculate a product’s VOC and/or ROC content and how to determine compliance. It does this by referencing a range of test methods and literature developed by ASTM International, the National Institute for Occupational Safety & Health (NIOSH) and the U.S. Environmental Protection Agency (EPA). If CARB enforcement initially finds that a product does not comply with relevant standards, it will request that the responsible party ii submit the product formulation along with any other necessary supporting documentation—and may also order further testing. Per the General Consumer Products Regulation iii, the responsible party has 25 working days to provide the requested information.
It’s important to remember that with this testing method, the analysis may differ from the theoretical calculation. Method 310 tests for all VOCs, including exempt VOCs and low vapor pressure (LVP) VOCs, and this discrepancy should be resolved by providing CARB enforcement with the formulation and other necessary supporting documentation. If a discrepancy remains unresolved, enforcement may allow the responsible party to explain the issue. Appropriate enforcement action will be taken by CARB if a product is determined to be not compliant.
To avoid enforcement action, companies should review their products sold in California, ensure that the product label and product category are consistent (and remember, every word counts!), calculate the regulatory VOC content of each product, include a date code on each container (and submit a yearly date code explanation if utilizing a company specific code) and retain records for a minimum of three years.
Companies don’t need to perform Method 310 on their products, but it sure does help to understand how it fits into the overall enforcement process. To stay up-to-date on all CARB activity for consumer products, or if you have any questions about compliance or enforcement, please contact me at [email protected]. SPRAY
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ii The term “responsible party” means the company, firm or establishment that is listed on the product’s label. If the label lists two companies, firms or establishments, the responsible party is the party that the product was “manufactured for” or “distributed by,” as noted on the label.
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