December 2016

Regulatory Issues

Upcoming effective dates
As of Jan. 1, 2017, the California Air Resources Board (CARB) has future effective volatile organic compounds (VOC) limits that come into effect. Future VOC limits for Aerosol Adhesives and Aerosol Coatings are listed below.

Aerosol Adhesives

Category Current VOC 1/1/2017 VOC
Mist Spray 65% 30%
Web Spray 55% 40%
Screen Printing None 55%

 

Aerosol Coatings/General Coatings

Category Current Maximum Incremental Reactivity (MIR) 1/1/2017 MIR
Clear Coating 1.50 0.85
Flat Coating 1.20 0.80
Fluorescent Coating 1.75 1.30
Metallic Coating 1.90 1.25
Nonflat Coating 1.40 0.95
Primer 1.20 0.70

 

Aerosol Coatings/Specialty Coatings (A)

Category Current MIR 1/1/2017 MIR
Auto Body Primer 1.55 0.95
Electrical/Electronic/Conformal Coating  

 

2.00

Exact Match Finish

Automotive

Engine

Industrial

 

1.50

1.79

2.05

 

0.95

0.95

1.20

Flexible Coating 1.60
Ground Traffic/Marking Coating  

1.20

 

0.85

Mold Release Coating 1.10
Two Component Coating 1.20
Uniform Finish Coating 1.30

These limits are not easy to meet. There is a three-year sell-through for all products made before the effective date. Requirements for sell-through products are, first, all products must be date coded before the effective date. Second, products sold in the last six-months of the sell-through period must have a notification from the seller to the buyer that this product is to be sold in the next six months. Thus, if your reformulations are not finished yet, make sure your company has enough products to last until your reformulation is complete.

Multi-purpose Lubricant Report
If you are a Multi-purpose lubricant manufacturer or Marketer, then a report on your progress toward the 12/31/2018 future effective VOC limit of 10% is required. This report is due before 3/31/2017.

The report requires product and formula data from 2016, plus the label and other information required in Section 94513(a) of the CARB Consumer Products regulation. A detailed list of all requirements will be in the January issue of Regulatory Issues, so stay tuned.

In addition CARB staff needs an update on research and development efforts taken by your company to meet the 10% future VOC limit. More to come next month.

Ozone Transport States
Ozone Transport States of Delaware and New Hampshire have new VOC limits coming into effect in 2017. These new limits are the same as some of the current limits at CARB. Please see chart below.

 

Category Current VOC 1/1/2017 VOC
Construction, Panel and Floor Covering Adhesive  

15%

 

7%

Air Freshener Dual Purpose Air Freshener/Disinfectant (Aerosol)  

 

 

 

60%

Anti-static Product (Aerosol)  

 

80%

Automotive Windshield Cleaner  

 

35%

Bathroom & Tile Cleaner

All Other Forms

Non-aerosol

 

5%

 

N/A

1%

Brake Cleaner 45% 10%
Carburetor or Fuel-injection Air Intake Cleaner  

45%

 

10%

Disinfectant

Aerosol

Non-aerosol

 

 

70%

1%

Engine Degreaser

Aerosol

 

35%

 

10%

Floor Polish or Wax

Resilient (Flexible) Flooring

Material

Non-resilient Flooring

Material

 

 

 

7%

 

10%

 

 

 

1%

 

1%

Furniture Maintenance

Product

All Other Forms (Except solid/paste forms)

Non-aerosol (except solid/paste forms)

 

 

 

7%

 

 

 

 

N/A

 

3%

General Purpose Cleaner Aerosol  

10%

 

8%

General Purpose Degreaser Aerosol  

50%

 

10%

Laundry Starch/Sizing/

Fabric Finish Product

 

5%

 

4.5%

Multi-purpose Solvent

Non-aerosol

 

 

3%

Nail Polish Remover 75% 1%
Oven or Grill Cleaner

Liquid

Non-aerosol

 

5%

 

N/A

4%

Paint Thinner

Non-aerosol

 

 

3%

Rubber/Vinyl Protectant

Aerosol-Tire Shine Products

 

10%

NOTE: NH

Jan. 1, 2016

Shaving Gel 7 4%
Temporary Hair Color (Aerosol)  

 

55%

Also, if the product is made before the effective date and properly date coded, the sell-through period is indefinite.

Aerosol 101
Make sure to review the article on the CARB Aerosol 101 on p. 44 of the December 2016 issue of SPRAY. It was a great meeting and a wonderful opportunity for the aerosol industry!