April 2020

CARB Webinar Summary

CARB Workshop
On April 14, the California Air Resources Board (CARB) held an on-line work shop to discuss its current proposal for the volatile organic compound (VOC) amendments to its Consumer Products Regulation.
Staff first reminded the Industry of their requirements to meet the State Implementation Plan (SIP). The SIP requirements are a reduction of 1-2 tons per day (tpd) in South Coast Air Quality Management District (SCAQMD) which equates to 2-4 tpd statewide by 2023. Also, the SIP requirements of 4-5 tpd in SCAQMD or 8-10 tpd statewide by 2031. To accomplish these emission reductions CARB has targeted seven product categories.
These categories are detailed below.
  • Manual Aerosol Air Freshener is proposed for a 10% VOC limit in 2023 and a 5% VOC limit by 2027. 
    • Plus three subcategories proposed:
      • Automatic Aerosol Air Freshener – 30% VOC limit 2023
      • Concentrated Aerosol Air Freshener – 15% VOC limit by 2023. 5% VOC limit by 2031
      • Total Release Air Freshener – 25% VOC limit by 2025
    • New definitions for all categories
  • Aerosol Crawling Bug Insecticide –  6% VOC limit by 2029
  • Hair Finishing Spray – 50% VOC limit by 2023, 45% VOC limit by 2029
  • Dry Shampoo – 55% VOC limit by 2023, 45% VOC limit by 2029
  • Temporary Hair Color – 55% VOC limit currently, 45% VOC limit by 2029
  • Hair Shine – 55% VOC limit currently, 45% VOC limit by 2029
    • Definition changes
  • Personal Fragrance Products – < 20% Fragrance category is being modified to: 
    • Personal Fragrance Products < 10% Fragrance – 68% VOC limit by 2023, 50% VOC limit by 2027
    • This means all product from 10% to 20% stays at 75% and all product above 20% can move from 65% to 75%. 
Next the sunsetting of the 2% Fragrance was discussed. CARB is proposing to sunset the 2% Fragrance exemption in 2031. In addition, add the following:
  • Allow 0.25% monoterpenes in non-aerosol General Purpose Cleaners and Degreasers beginning in 2023
  • Maintain 0.25% fragrance exemption inclusive of monoterpenes after 2031. 
This has been the first time CARB has moved on this issue. Please find attached all the proposed limits & reductions. 
After a short break, CARB discussed other topics.
  • Additions proposed for MIR table
    • HFO-1233(zd)
    • Alkane Mixed – minimally 90% C13 and higher carbon number
    • Diethyl Carbonate
The above compounds are proposed to be added to the Reactivity Table for Section 94700.
  • Incentives for the use of Compressed Gas Propellants instead of Liquefied Gas Propellants.
This use would need to be done through an Innovative Product Exemption.
  • Prohibition of Chlorinated compounds use proposed in these categories.
    • Manual Air Freshener
    • Hair Finishing Sprays
    • Dry Shampoo
    • Hair Shine
    • Temporary Hair Color (Aerosol)
    • Personal Fragrance Product less than 10% Fragrance
    • Aerosol Crawling Bug Insecticide
  • Potential prohibition of the use of PCBTF in the above categories.
  • Proposed retail ban of Energized Electrical Cleaner and Energized Electronic Cleaner as well as a Restriction of Energized Electronic Cleaner use in Automotive Maintenance. CARB has not given any sufficient reasons for these restrictions.
  • Alternative Control Plan (ACP) changes.
    • CARB proposes to limit the ACP products for products slightly under the limit. Need to review.
  • Innovative Product Exemption (IPE)
    • CARB proposes to eliminate products that use combustion to reduce VOC emissions.
  • Web-based claims
    • CARB is proposing to be able to use claims on company websites to be able to classify products categories.  This is a major departure from using only the label for this classification.  Need to monitor wording closely.

Comments are due by May 14.