VOC compliant consumer products under California CARB rules
VOC compliant means meeting the rules for a specific product category. Check California limits, formula exclusions, manufacture dates and restrictions.
What does VOC compliant mean for California consumer products?
For California consumer products, VOC compliant means meeting the volatile organic compound requirements for that product category. There is no universal VOC percentage.
Check the category, the applicable date, the exclusions and the other requirements under CARB's consumer products regulation. A cleaner, a hairspray, an air freshener and an adhesive cannot share an assumed limit just because someone treats all four as spray products. But spray packaging does not pick the category. For a "VOC compliant cleaner," start with the defined category and the label uses. For hairsprays and air fresheners, also check the requirements for the specific category. A VOC percentage does not establish compliance with separate ingredient prohibitions or global warming potential restrictions. CARB treats those as separate requirements.
What California VOC limits measure
The CARB compilation defines VOC content as VOC weight expressed as a percentage of product weight, excluding the container. That percentage is formulation content. An indoor-air concentration is a different measurement.
Don't add up every organic ingredient. LVP-VOCs are not counted toward total product VOC content for compliance purposes. Confirm the ingredient meets the relevant definition before you exclude it. The category comes first.
What to check before calling a product VOC compliant
Before calling a cleaner, hairspray, air freshener or adhesive VOC compliant, check the requirements below. The product must meet all applicable requirements, not just pass a VOC-content calculation.
- Identify the product category. Compare actual uses and label claims with the definitions in the compilation. A marketing name is a poor shortcut.
- Find the applicable standard and effective date. Category VOC standards sit in section 94509(a), which CARB's enforcement guidance identifies. The current-regulations index is headed "Updates to the Consumer Products Regulations Effective August 1, 2022." That heading does not show that later amendments are absent. Check the applicable text, and later amendments, before you copy a number from the compilation table.
- Calculate VOC content with the accounting rules, including which ingredients are excluded. Use CARB's compliance page for that accounting rule. Do not treat every organic ingredient as a counted VOC.
- Check the manufacture date and any transition provisions. Products subject to section 94509 must display the manufacture day, month and year, or a code indicating that date. A sequential batch number that cannot be attributed to a specific day, month and year is not enough. CARB's product-dating page states that requirement. Sell-through has its own conditions in the compilation. Don't assume one sell-through period fits every product.
- Review other applicable restrictions. A passing VOC-content figure does not resolve category-specific ingredient prohibitions or global warming potential restrictions. CARB's enforcement guidance keeps those checks separate.
California VOC regulations and federal rules differ
Federal and California VOC regulations are separate. EPA maintains national VOC emission standards for certain consumer-product categories under 40 CFR Part 59, Subpart C. EPA describes this federal framework. Meeting federal requirements does not establish compliance with the applicable California requirements.
Spray paint needs its own CARB article. Aerosol-coating rules use a reactivity limit, expressed as product-weighted maximum incremental reactivity. Don't transfer that framework to every aerosol cleaner, hair product or air freshener. CARB's aerosol-coating guidance keeps that framework separate.
Subject to exceptions, the consumer products article applies to any person who sells, supplies, offers for sale, or manufactures consumer products for use in California. CARB's enforcement page states the covered acts.
RegAffairs AI explains the category-based requirements in its answer on VOC compliance for California consumer products.