Written on: September 1, 2026 by Doug Raymond
CARB activity update
Regarding California Air Resources Board (CARB) staff, Moslem Mardi, a manager who works for the Consumer Products Branch Chief, Ravi Ramalingam, is back at work. Josh Berghouse, a CARB staff member who worked on the last Rulemaking and had left the Consumer Products group for another section of CARB, has returned to the Consumer Products group. This will provide CARB staff with more institutional knowledge. As mentioned in my last column, two long-term staff members moved to other sections. Ramalingam, who has been on medical leave since the middle of April, was thought to be coming back in August, but his new timeline is Fall 2026. This is another setback. There is a rumor is that an interim Branch Chief will be assigned to the Consumer Products section soon, so we will need to wait and see.
Currently, Industry is waiting for the Final Results of the latest survey. Also, we are waiting for the draft results of the Personal Fragrance Product (PFP) Assessment. As a reminder, Industry needs to achieve 20 tons per day of emission reductions by 2037. The PFP assessment could lead to more emission reductions needed if the PFP products cannot meet the current volatile organic compound (VOC) limits slated for 2031. Currently, PFP products are to get 5.05 tons per day (TPD) and will likely get some tonnage reductions, but not the full 5.05 TPD. Thus, the tonnage needs will move from 20 TPD to something greater. The rulemaking completion deadline is late 2027, so there is not a significant amount of time to accomplish this goal.
Several associations and industry members met with CARB in August to provide training sessions, including one on Aerosols. A full report of those meetings will be provided in the next issue.
Currently, we have no choice but to wait and see what the results will show. After the results are released, expect CARB staff to work at an expedited pace to make up for past time lapses. If you had products in the past survey, be prepared to be involved with CARB, who will need to set new limits to achieve its VOC emission goals—whether mass-based or the more likely reactivity-based.
Stay tuned, as there will be much more to come.
Other State activity
Oregon, as reported in the last issue, is dropping activity on a Consumer Products Rule.
Maryland is moving forward on updating its Consumer Product regulation from Ozone Transport Commission (OTC) Model Rule IV to OTC Model Rule V. Maryland appears to be moving faster on this than Maine, so look for a draft this Fall.
Maine is planning to move its Consumer Products regulation from OTC Model Rule II to OTC Model Rule IV. The Pine Tree State will likely not present a proposal until 1Q 2027.
Currently, Colorado has OTC Model Rule V as a contingency measure if it does not hit its ozone numbers, which given the current state of activity (extreme heat and wildfires), is likely. Thus, start planning to move to Model Rule V. Colorado is also planning to move to CARB’s current limits; Industry is trying to talk legislators out of this.
New Jersey OTC Model Rule IV became effective August 18, 2026—I hope you made it! SPRAY
