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
CARB
Consumer Products rulemaking
Since the California Air Resources Board (CARB) webinar on June 2, 2026, some unavoidable obstacles have popped up that will delay the CARB rulemaking process. Earlier this year, two long term staff members for CARB—Dan Garrett and Lucy Negrete—took other positions within the organization and left the Consumer Products sector. While we wish them good luck in their future endeavors, their departure leaves a hole in certain areas of the Consumer Products branch and their knowledge and experience will be missed.
Further, many of you are familiar with the Consumer Products Branch Chief, Ravi Ramalingam, who has spoken at past Western Aerosol Information Bureau (WAIB) events and, just this March, presented on CARB activity in Nashville, TN, at the Aerosol Summit. Unfortunately, Ramalingam has been on medical leave since mid-April. He is expected back soon and we wish him a full recovery. As you can imagine, this has delayed some work. Moslem Mardi, a manager that works under Ramalingam, has been keeping things moving. However, Mardi recently had a personal situation that necessitated him being out until the end of July. With all of these obstacles, it is likely the originally scheduled Consumer Products rulemaking timeline will shift.
Industry had proposed a training session for CARB in mid-July that has now been postponed to mid-August. Hopefully, by late Summer or early Fall, we will be back on track with this rulemaking.
Industry is waiting for the 2023 survey results to be finalized and the best guess is that will be by the end of September. Once the final survey results are released, the categories surveyed can be analyzed to determine if any mass-based volatile organic compound (VOC) reductions or reactivity-based reductions can be accomplished. Remember, just because a category was surveyed does not mean that category will be regulated or re-regulated. Any companies that have products in the surveyed categories should be reviewing formulas for either mass-based or reactivity-based reduction possibilities in order to be ready to engage when the rulemaking begins.
PFP
The Personal Fragrance Products (PFP) industry is waiting for the results of the PFP assessment. These PFP categories were regulated in the last rulemaking with very strict VOC limits.
CARB is reviewing the VOC limits to determine if they need to be adjusted; if the limits are adjusted upward, then more mass-based VOC or reactivity-based VOC reductions will be needed. We are expecting these final assessment results shortly after the above-mentioned survey results.
In the meantime, enjoy the rest of your Summer while we await these results.
Other State activity
Oregon has decided to drop its development of a Consumer Products VOC Regulation. This is great news. Remember, Oregon is the State that is in VOC attainment, but was going to adopt a rule.
Maine is looking into updating its Consumer Products regulation to adopt Ozone Transport Commission (OTC) Model Rule IV. Work will likely start soon and continue through this Fall.
Maryland will be updating its OTC Model Rule IV to OTC Model Rule V. It will be the first State to implement Model Rule V since Colorado adopted OTC Model Rule V for contingency only.
Finally, on Aug. 18, 2026, New Jersey’s new Consumer Products Regulation becomes effective. The rule goes from OTC Model II to OTC Model Rule IV. SPRAY
CARB webinar & Industry action
On June 2, 2026, the California Air Resources Board (CARB) held a webinar on its 2023 Consumer Product Survey results; the timeline is as follows:
• Dec. 3, 2024: The survey launched with 37 categories
• April 8, 2025: Original deadline for survey
• Survey deadline delayed due to poor response
• Sept. 22, 2025: New survey deadline
• May 5, 2026: The draft survey data summary was released
• June 8, 2026: Deadline for draft comments from Industry
• Late Summer 2026: The final 2023 survey data is scheduled to be released
On the June 2 webinar, CARB walked participants through some of the data from the May 5 release.
This survey has been very challenging, to say the least. Only slightly more than 50% of the companies that reported in the 2013–2015 survey reported on these current 37 categories. This equates to approximately 400+ of the companies that reported in 2013–2015 not reporting in 2025. How does this happen?
CARB then reviewed its Quality Assurance/Quality Control process. The data released was significant. If you have products in one or more of these 37 categories, then you need to take a serious look at this data. CARB supplied a complete Data Summary of all categories, as well as a list of the number of products per company, which was very interesting. CARB also updated the chemical list and assignments, noting whether a chemical is a volatile organic compound (VOC) or low vapor pressure volatile organic compound (LVP-VOC)-exempt. This list is awesome and very helpful! The only issue is that not all chemicals are on the list.
CARB next provided a list of hydrocarbon solvents, supplying the trade name, manufacturer, bin number and Maximum Incremental Reactivity (MIR) value, which was all very helpful information for a calculating MIR content.
The webinar also provided the categories with the highest emissions for VOC and for ozone forming potential (OFP). If your product is in one of these categories, you need to be paying specific attention to this rulemaking.
CARB further reviewed a few categories and showed some gaps in the data. These are the next steps:
• June 8, 2026: 2023 Data summary feedback from Industry was due back to CARB
• Summer 2026: Individual and workgroup meetings will be held
• Late Summer 2026: The final 2023 survey data is scheduled to be released
• 2026–2027: Category evaluation, webinar and workshops will be held
• Late 2027: Board hearing to adopt amendments
Industry has been working hard on these draft survey results and several industry associations have joined forces to assist CARB in filling in some of the data gaps. Numerous calls were held for Industry and trade groups to evaluate the data; these trade organizations include American Cleaning Institute (ACI), American Coatings Association (ACA), Fragrance Creator Association (FCA), Household & Consumer Product Association (HCPA), National Aerosol Association (NAA) and the Personal Care Products Council (PCPC). The goal is for all these associations to work together and expeditiously send in one set of comments for CARB’s review. Nicholas Georges from HCPA has been doing a wonderful job spearheading this association alliance and has helped tremendously. In fact, there was a great cooperative effort by all involved.
Companies should now be reviewing their products and getting ready for the rulemaking process, slated to begin this Fall.
New Jersey reminder
New Jersey has updated its Consumer Products Regulation from Ozone Transport Commission (OTC) Model Rule II to OTC Model Rule IV. VOC limits become effective Aug. 18, 2026. SPRAY
CARB
Finally, the California Air Resources Board (CARB) has released its Draft Data Summary from the 2023 Consumer Product Survey. This survey data will be used in the current round of rule development, which needs to be completed by the end of 2027. There are 37 initial product categories that will be looked at for regulation or re-regulation. CARB needs to get 20 tons per day (TPD) of emission reductions for its State Implementation Plan (SIP) commitment.
More than likely, CARB will lean toward Reactivity limits for this regulation. One only needs to review CARB’s summary page to see why. Total volatile organic compound (VOC) tonnage is 97.23 TPD. Ozone Forming Potential (OFP) or Reactivity-based tonnage is 229.5 TPD. If we go strictly by VOC, we need 20% of available VOC tonnage to be reduced. This is a significant amount. If we use OFP, then we are looking at less than 10% reduction from the total OFP.
To complicate the issue, Industry needs to get additional tonnage if the Personal Fragrance Product (PFP) category cannot get its tonnage. Currently, the PFP category is on the hook for 5.05 TPD, and it is not likely that it will achieve this reduction. We will need to wait and see on this issue, but expect that we will need to get more than 20 TPD.
Reactivity is being used because it is sound science and the best way to reduce ozone, as any reduction in Reactivity is an automatic reduction in ozone formulation. Reducing VOC, depending on the compound, may not reduce ozone, because the replacement compounds may be more reactive. Thus, we are moving in the right direction to combat the smog issue.
Industry needs to review the information from CARB here.
This link contains a massive amount of information that was collected from 600 manufacturers on 46,200 products sold into California. If you sell any of the 37 product categories, review your category for accuracy.
Seven industry trade organizations—the American Cleaning Institute (ACI), Consumer HealthCare Products Association (CHPA), Fragrance Creator Association (FCA), Household & Consumer Product Association (HCPA), National Aerosol Association (NAA) and the Personal Care Product Association (PCPC)—have been working together in a collaborative effort to try and get the best result we can from this rulemaking.
Below is a set of groups we plan to work on. Please review them, find which group your category is in and become active. If you are not a member of any of these above associations, don’t worry, this activity is open to all. Call Nicholas Georges of HCPA at 708-214-4466 or me at 440-339-4539 and we will be happy to get you involved.
Group 1
• Air Freshener, Liquid/Pump Spray
• Carpet & Upholstery Cleaner (non-aerosol/dilutable)
• Disinfectant (aerosol)
• Dual Purpose Air Freshener/Disinfectant (aerosol)
• Footwear or Leather Care Product (aerosol)
• Footwear or Leather Care Product (non-aerosol)
• Spot Remover (non-aerosol)
Group 2
• Antiperspirant
• Deodorant
• Anti-microbial Dry Hand Wash (Hand Sanitizer)
• Sunscreen (hair or body) (aerosol)
Group 3
• Body Wash/Mousse/Gel/Soap/Foam/Scrub
• Hand & Body Conditioner, Cream, Lotion and Moisturizer
• Conditioner without styling claims
• Dye (permanent)
Group 4
• Cutting or Tapping Oil (aerosol)
• Metal Polish/Cleanser (aerosol)
• Multi-purpose Dry Lubricant
• Penetrant
• Rust Preventative or Rust Control Lubricant (aerosol)
• Undercoating (aerosol)
Group 5
• Clean-Up Solvent
• Lacquer Thinner
• Multi-purpose Solvent (non-aerosol)
• Paint Thinner (non-aerosol)
• Paint Remover or Stripper
• Thinner/Reducer/Retardant (Motor Vehicle Coating Systems)
Group 6
• Floor Wax Stripper
• Oven or Grill Cleaner (non-aerosol)
• Plastic Pipe Cement & Primer
• Sealant or Caulking Compound (Chemically Curing)
• Sealant or Caulking Compound (Non-chemically Curing)
Group 7
• Detergent (Laundry)
• General Purpose Cleaner (non-aerosol)
• General Purpose Degreaser (aerosol)
• General Purpose Degreaser (non-aerosol)
• Liquid Fabric Softener
Remember, this activity will be ongoing throughout 2026 and most of 2027. Now is the time to be active and get involved! SPRAY
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
CARB
The saga continues with the California Air Resources Board (CARB) Consumer Products Volatile Organic Compound (VOC) Survey Results. CARB was originally planning to have the survey results posted in January, then February, 2026. When results were still not finished, I inquired if they would be ready in March; the response from CARB staff was “soon.”
The timeline looks something like this:
My point is that January–July 2027 is approximately eight months in which to develop a regulation to achieve 20-tons-per-day of emission reductions (or equivalent). This is not a lot of time to develop a regulation of this magnitude. Our last rulemaking in the early 2020s consisted of eight tons of reductions per day. This regulation took two years because of the COVID-19 pandemic. Thus, this rulemaking will be very challenging and I encourage all manufacturers and marketers that have categories within the rulemaking to be fully involved in development. Once this process starts, it will likely move quickly, so pay close attention. The bottom line is that there is a significant amount of work to be done.
Personal Fragrance Product
The above rule development will be tough and the issue will be further complicated if additional tonnage is needed. The Personal Fragrance Product (PFP) category—with fragrance of less than 10%—is on the hook for five tons of emissions per day. The Technical Assessment was due March 31 and CARB should have results available by June–July 2026. Industry may be on the hook for an additional few tons of emissions and this will make our work even more difficult. Hopefully, PFP manufacturers can get a significant portion of the five ton, so make sure your Technical Assessment is sent in, even if it is late.
Our next year will be extremely challenging.
New Jersey
New Jersey has updated its Consumer Products Regulation from Ozone Transport
Commission (OTC) Model Rule II to IV. VOC limits become effective Aug. 18, 2026.
HFC reporting
Both New York State and the U.S. Environmental Protection Agency (EPA) required hydrofluorocarbon (HFC) reporting, which was due on March 31, 2026. If you have not already reported your HFC usage, do so, as it is better late than never! SPRAY
HFC Reporting
By March 31 of this year, both New York State and the U.S. Environmental Protection Agency (EPA) require reporting for the use of hydrofluorocarbons (HFCs) in products.
The EPA held a webinar on Dec. 17, 2025, to provide information and answer questions on the reporting requirements of the American Innovation & Manufacturing (AIM) Act’s Technology Transition rule. The webinar gave step-by-step instructions on how to register and use the reporting platform. Manufacturers and importers covered by the rule must report annually, with the first reports due this year on March 31.
During the webinar, there was some confusion on who needs to report. The simplest way to explain this is that the company whose name is on the label is responsible for reporting. To report, one can email [email protected]; remember to report!
For New York, a company needs to register and create an account here. Once created, the forms can be found here.
For the purposes of this regulation, a “regulated substance” is any chemical intended for use in the sectors listed in the regulation, including aerosol products, that has a 20-year Global Warming Potential (GWP20) greater than 10 or that is reasonably anticipated to have a GWP greater than 10 over an integrated 20-year time frame. This includes HFCs, hydrofluoroolefins (HFOs), hydrocarbons, etc.
The table of many substances that would be considered a “regulated substance” from the Intergovernmental Panel on Climate Change (IPCC) can be found here.
The New York State Dept. of Environmental Conservation (NYSDEC) has also created a list of many of the compounds that are considered to be regulated under this rule, although this is not a complete list of all substances. You can find this list here.
Anyone who supplies, manufactures, produces or distributes aerosol products is required to register. For the purposes of this regulation, and confirmed in conversations with NYSDEC staff, contract manufacturers are not obligated to register. The term “manufacturers” relates to the company whose name appears on the label.
CARB
Completion of the California Air Resources Board (CARB) 2025 Personal Fragrance Technical Assessment is required by March 31, 2026. The reporting tool for this assessment has some sections whose relevance fragrance industry manufacturers may question. For example, there is a section to report Hydrocarbon Solvents, and I doubt that many, if any, personal fragrance manufacturers use these solvents. These firms should therefore mark this section “Not Applicable.” There may be other sections that are not pertinent to fragrance, so I advise firms to ignore these sections.
All companies that sold into California in 2025 a personal fragrance product with less than or equal to 10% fragrance by weight of combined fragrance ingredients need to complete the Technical Assessment. Data to be submitted include sales data, brand names, formulations, formulator contacts, labels and written report on efforts to meet the upcoming 50% volatile organic compound (VOC) standard. This assessment is vital to determine if the future 50% VOC standard is technically and commercially feasible. Currently, this 50% limit accounts for five tons per day of emission reductions for Industry. This is a zero-sum action. If the 50% limit is not feasible, then the rest of Industry needs to make up the shortfall.
All personal fragrance manufacturers are encouraged to submit this report.
CARB Survey
CARB has indicated that the survey results will be released soon—likely March 2026. Remember, this is the first step in the next rulemaking planned by CARB. When these results are released, Industry will likely only have 60 business days to review them for any anomalies in each of the product category results. This information will then be finalized, and CARB staff will use this data to work on amendments to the Consumer Products VOC rule. Thus, when the results are finalized, we will find out which product categories will be regulated in the next rulemaking.
Industry should be prepared to begin, in earnest, developing a beneficial regulation with CARB staff.
NJ Reminder
New Jersey has updated its Consumer Products Regulation from Ozone Transport Commission (OTC) Model Rule II to IV. VOC limits become effective Aug. 18, 2026. SPRAY
CARB
There are several California Air Resources Board (CARB) activity updates.
Survey Results
CARB was planning to have the draft results from the 2023 Consumer Product Survey released in January 2026, but, according to discussions with CARB staff, it appears as the results will be somewhat delayed and likely released in February–March 2026.
This is the first step in CARB’s planned rulemaking. When these results are released, Industry will need to review them and look for any anomalies in each of the product category results. This information will then be finalized and CARB staff will use this data to work on amendments to the consumer products volatile organic compound (VOC) rule. Therefore, when the results are finalized, we will find out which product categories will be regulated in the next rulemaking.
Industry should be prepared to begin in earnest with CARB staff to develop a beneficial regulation.
2025 Personal Fragrance Technical Assessment
Completion of the Technical Assessment on Personal Fragrances is required by March 31, 2026. CARB released its reporting tool on Jan. 5.
The Technical Assessment needs to be completed by all companies that sold a Personal Fragrance Product into California during 2025 with less than or equal to 10% fragrance by weight of combined fragrance ingredients. Data required to be submitted includes sales data, brand names, formulations, formulator contacts, labels and a written report on efforts to meet the upcoming 50% VOC standard. This information will be used by CARB staff to determine if the 50% VOC standard is commercially feasible. Thus, all companies required to report should send in the most complete and accurate information as possible for CARB to complete its assessment. CARB is not required to make any changes to its rule.
It’s worth remembering that if fragrance manufacturers cannot meet the 50% future VOC standard and CARB changes the limit, then the rest of Industry will need to make up the VOC tonnage shortfall, which is about five tons per day.
CARB Date Code
As reported last month, if you do not use CARB’s standard date code on your products, then you should have reported your unique code to CARB staff by Jan. 31; if you did not report and you should have, please get this done.
Other States
New Jersey has updated its Consumer Products Regulation from OTC Model Rule II to IV. VOC limits become effective Aug. 18, 2026.
Oregon is considering going right to the Ozone Transport Commission (OTC) Model Rule V, and would be the first State to move to that rule.
Industry might also see regulatory activity this year in Michigan, Maine, Washington, D.C. and possibly Texas.
AIM Rule
Hydrofluorocarbon (HFC) reporting to the U.S. Environmental Protection Agency (EPA) is also due March 31, 2026, and manufacturers using HFCs under the American Innovation & Manufacturing (AIM) Act’s Technology Transition Rule will need to report their products. We will discuss this more in next month’s column. SPRAY
Happy New Year! Get prepared to work with the California Air Resources Board (CARB) this year…
CARB
CARB will likely release its draft volatile organic compound (VOC) survey results in mid-to-late January. Remember, this is the CARB 2023 Consumer Product survey of 37 product categories that was originally released on Dec. 3, 2024, and had a deadline of April 8, 2025. Due to extremely poor response from Industry, CARB had a webinar in September 2025 and released the names of the non-responding companies. Per CARB, fewer than 50% of the companies that it expected to report had done so. CARB staff granted more time for companies to respond.
CARB estimated that 574 companies did not respond, which will make our next rulemaking extremely challenging. Thus, the survey results that are released this January are extremely important, as they will be used to develop the next set of amendments for the Consumer Products Rule. Since CARB is on the hook for 20 tons of VOC reductions from the 37 product categories, this will be one of the most challenging rules we will have had in the 35 years that CARB has been regulating Consumer Products.
The good news is that we will be using the concept of Reactivity, which should be an advantage for Industry; any reduction in a Maximum Incremental Reactivity (MIR) value for a category is a reduction in ozone for the State of California. This is not true for mass VOC reductions.
CARB will adopt these amendments in 2027. However, since the reductions are not needed until 2035, all reductions that are achieved before that year are grown and counted toward the 2035 tonnage. This is a good thing!
The current timeline is as follows:
Be prepared to review the initial draft results of the survey; this is the data that will control the entire rule development.
CARB Fragrance Report
By March 31, 2026, any manufacturer of a personal fragrance product with less than or equal to 10% by weight of fragrance ingredients must submit a report to CARB. This is to be a written report concerning Research & Development (R&D) efforts to achieve the 50% VOC limit by Jan. 1, 2031.
CARB is expecting to get data on formulation, prototype testing, toxicity testing, stability testing and consumer acceptance in an attempt to determine if the 50% limit needed by that date is technically feasible.
Hopefully, the fragrance industry can meet this limit since it represents a four-ton-per-day reduction. If Industry cannot make this limit, more tonnage will need to be reduced by other categories.
CARB Date Code
This is my annual friendly reminder about Product Dating/Date coding: Make sure you are up to date on your date code filings. This is an area in which CARB continues to become stricter and more vigilant.
Remember, date code information needs to be reported to CARB every year by your company if you do not use CARB’s standard date coding. For California, Section 94512 (b) product dating specifically requires all consumer products destined to be sold into the State to display the day, month and year the product was manufactured or a code indicating the date. CARB has been increasing its investigative activity and levying fines for non-compliance of this section.
The date or date-code information shall be located on the container or inside the cover/cap so that it is readily observable or obtainable (by simply removing the cap/cover) without irreversibly disassembling any part of the container or packaging. Information may be displayed on the bottom of a container as long as it is clearly legible without removing any product packaging.
CARB’s standard code must be represented separately from other codes on the product container so that it is easily recognizable, e.g.: YY DDD = Year Year Day Day Day. A manufacturer who uses this standard CARB code to indicate the date of manufacture does not have to report this code.
Failure to register a date code is subject to a fine. Date code explanation needs to be submitted to CARB Enforcement on an annual basis, on or before Jan. 31 of each year. Email: [email protected].
Oregon
The State of Oregon is working on a Consumer Products Rule. The current timeframe is:
Oregon is considering going right to the Ozone Transport Commission (OTC) Model Rule V, and would be the first State to do so.
New Jersey
As a friendly reminder, New Jersey has updated its Consumer Products Regulation from OTC Model Rule II to IV. VOC limits become effective Aug. 18, 2026.
Aerosol Coating Reporting
Every three years, aerosol coatings manufacturers need to report to the U.S. Environmental Protection Agency (EPA)—and it is that year once again. Reports are due March 31, 2026, and the requirements can be found at 40 CFR 59.51(i).
HFC Reporting
Hydrofluorocarbons (HFC) reporting to the EPA is also due March 31, 2026, and manufacturers using HFCs under the American Innovation & Manufacturing (AIM) Act’s Technology Transition Rule will need to report their products. We will discuss this more in next month’s column. SPRAY
SCAQMD
On Aug. 12, the South Coast Air Quality Management District (SCAQMD) started work on 12 rules, requesting survey data on all rules with a deadline of Nov. 14, 2025. SCAQMD is opening these rules in an attempt to prohibit the use of para-chlorobenzotrifloride (PCBTF) and tert-butyl acetone (T-BAc); SCAQMD has determined these two compounds to be toxic, as well as volatile organic compound (VOC)-exempt. Exempt VOC compounds are typically used wherever possible to lower VOC content. However, even though SCAQMD is opening the rules to prohibit these compounds does not mean other changes cannot be made.
SCAQMD has already prohibited PCBTF and T-BAc from Rules 1165 on Adhesives, 1151 on Automotive Coatings and 1171 on Degreasing Solvents. There were other changes to these rules, as well—for example, the Concept of Reactivity has been introduced to the rules with some future effective limits and category limits rose to accommodate the prohibitions. In Rule 1171, aerosol usage was changed.
I suggest that the following rules be monitored closely:
• Rule 1113: Architectural Coatings is probably the largest category, as far as tonnage.
• Rule 1122: Solvent Degreaser, to make sure the amendments are reasonable.
• Rule 1143: Consumer Paint Thinners and Multi-purpose Solvent because the consumer products industry was very involved in this. Also, the California Air Resources Board (CARB) has a similar rule, and we need to make sure rules stay consistent.
• Rule 1144: Metalworking Fluids and Direct-Contact Lubricants. Again, we need to ensure that this rule does not affect any of our CARB limits.
There are numerous other rules that are being worked on, so if your company is regulated by any other rules, you should pay attention.
On Nov. 20, SCAQMD held its second workshop on Rule 1144. Just in case we still need to monitor this rule, SCAQMD staff has said that the only changes will be the prohibition of PCBTF and T-BAc, as well as any clean-up of wording—but there will be no new categories or lowering of limits.
On Nov. 18, SCAQMD held its Public Meeting to discuss Rule 1168 and the prohibition of PCBTF and T-BAc. This was just a technology check-in, as you may remember that this was one of the rules that was already amended.
Stay tuned for more to come.
CARB
No new news on CARB, as the survey process is still moving forward. Staff is busy trying to combine and update survey data, and believes activity will start in January 2026. Therefore, plan to make time in your schedule to work on any upcoming rules.
Remember, if you produce Personal Fragrance products with less-than or equal-to 10% fragrance then you must report your Research & Development efforts to achieve the 50% VOC limit set for Jan. 1, 2031, to CARB by the March 31, 2026, deadline.
OTC
The Ozone Transport Commission (OTC) held its Fall public stakeholders’ webinar on Oct. 9. OTC has not proposed any new Model Rules but did clean up its website on Consumer Products. I, representing the National Aerosol Association (NAA), as well as Nicholas Georges, representing the Household & Commercial Products Association (HCPA), made short comments to inform the OTC that the Concept of Reactivity is coming and that we can provide assistance. OTC thanked us for the offer
New Jersey
Reminder: New Jersey updated its VOC regulation from OTC Model Rule II to OTC Model Rule IV. VOC limits are effective as of Aug. 18, 2026.
Wishing you all Happy & Safe Holidays! SPRAY
