Written on: May 1, 2026 by Doug Raymond
At the National Aerosol Association (NAA) Aerosol Summit, held in Nashville, TN, in March, we had numerous great speakers. These included two that affect our regulatory agenda—Ravi Ramalingam, Branch Chief from the California Air Resources Board (CARB), and Allison Cain from U.S. Environmental Protection Agency (EPA), Office of Air & Radiation.
CARB
Ramalingam presented on the past accomplishments of CARB Consumer Products Volatile Organic Compounds (VOC) Regulation, which includes 150 categories regulated, as well as a reduction of 250 tons per day (tpd) of VOC reductions. He further provided an overview of the 2021 regulation, which resulted in seven categories being regulated or re-regulated. Ramalingam also explained that Consumer Product VOC emissions are on the rise and, by 2040, could be the top contributor of VOC emissions in California.
Ramalingam added that the regulations are data-driven; therefore, there is a need for updating inventory with the soon-to-be-released survey data. He predicted that there is expected growth in emissions by 28 tpd by 2037; however, CARB only needs to reduce emissions by 20 tpd. All emissions will be reduced, including VOC and Low Volatile Organic Compounds (LVOC), by the use of Reactivity. Keep in mind that if CARB does not use Reactivity in the next rulemaking, then it may need to look to regulate Low Vapor Pressure Volatile Organic Compounds (LVP-VOCs), which is not good news. Currently, LVP emissions are greater than VOC emissions.
Currently, CARB is looking at Ozone Formation Potential (OFP) instead of VOC emissions. OFP is the appropriate way to regulate Consumer Products. Ramalingam presented examples of how emissions will be calculated. Hopefully, this method will allow for greater VOC emission reductions.
Benefits of this new Reactivity approach should prevent repeated category regulation, increase flexibility and encourage more effective and cost-effective products, as well as more technological advances for product reformulation.
Ramalingam noted the regulation of toxic compounds, mainly parachlorobenzotrifluoride (PCBTF), for the next rulemaking. There are about 19 product categories that currently use PCBTF that will likely be considered for regulation.
A timeline for the next rulemaking was presented:
• April 15, 2026: Draft Data Summary released
• April 27, 2026: CARB webinar to discuss the data
• June 1, 2026: Review and feedback from Industry is due
• August 2026: Final Draft Summary
After Data summaries are complete, CARB will need to determine if there was under-reporting in categories. Industry will need to assist in this endeavor, which will be difficult.
Ramalingam then discussed the 2025 Personal Fragrance Products (PFP) Assessment. From these assessments, CARB will evaluate whether Fragrance manufacturers can meet the new 50% VOC standard for Jan. 1, 2031. If manufacturers cannot meet this standard, then Industry will need to make up the tonnage in other categories.
The bottom line is that Industry will need to do a significant amount of work. Stay tuned, as the work began on April 15 of this year.
EPA
Cain presented on current EPA reorganization. The new Office of Clean Air Programs will be run by Cindy Newburg. This new office will be for the Chemical Coatings & Consumer Product Division, responsible for programs dealing with:
• Ozone Depleting Substances (ODS)
• Hydrofluorocarbons (HFCs)
• Substitutes for ODS and HFCs
• Volatile Organic Compounds (VOCs)
• Coatings & Consumer Products
Cain then reviewed the American Innovation & Manufacturing (AIM) Act, specifically, Technology Transition Rule requirements. This rule restricts the use of high global warming compounds, such as HFC-134a, in most aerosol products; it also has labeling and reporting requirements. Labeling for most aerosols was required by Jan. 1, 2025, while labeling for Technical Aerosols is required by Jan. 1, 2028.
Reporting is required annually, starting March 31, 2026; Cain illustrated how to complete reporting requirements.
Remember, HFC-152a is allowed in all aerosols and the AIM Act is an HFC phase-down, not a phase-out, of HFCs.
If you were not in attendance, you missed a great meeting!
Editor’s Note: Complete coverage of the NAA Aerosol Summit will appear in the June 2026 issue. Views and opinions expressed in this column are solely the author’s and do not necessarily represent those of SPRAY Technology & Marketing/Industry Publications. SPRAY
