California VOC Exempt Solvents

No, not for every product. Acetone is excluded from the VOC definition for all products under CARB's main Consumer Products rule (Article 2), so it does not count toward any Table of Standards limit. But CARB's reactivity-based rules count it as an ingredient. That covers all aerosol coatings and Multi-purpose Lubricants that choose the reactivity compliance option.

Approach: I checked CARB's consumer products tables in our datasets for acetone's reactivity (MIR) value, then read CARB's current unofficial texts of Article 2 (consumer products) and Article 3 (aerosol coatings) for every provision that could bring acetone back in. Article 1 (antiperspirants and deodorants) has its own definitions, and I did not review it.

Where acetone is exempt

• Article 2, § 94508(a)(138)(B): the VOC definition excludes acetone, ethane, methyl acetate, PCBTF and perchloroethylene as "low-reactive organic compounds which have been exempted by the U.S. EPA" (Article 2, Nov 2022, p. 64). The rule calls these "Table B" compounds in § 94508(a)(126).
• The exclusion has no category carve-outs. None of the § 94509(m) bans names acetone. Those bans cover methylene chloride, perchloroethylene, trichloroethylene, PCBTF, para-dichlorobenzene and alkylphenol ethoxylates.
• South Coast nonaerosol Multi-purpose Solvent and Paint Thinner (§ 94509(p)(4)): since 1 January 2015 the limit is 25 g/L of VOC. For these products the rule removes only the LVP-VOC exemption ("there is no LVP-VOC exemption for these products"). It does not remove the acetone exclusion.

Where acetone still counts

1. Aerosol Coating Products (Article 3, §§ 94520-94528): limits are on product reactivity (PWMIR, grams of ozone per gram of product), not on VOC content.
   • Every ingredient at 0.1% by weight or more must be included in the PWMIR.
   • Each reactive organic compound gets its MIR value from § 94700 (§ 94522(h)).
   • The exclusion list in the Article 3 text I read covers only non-carbon ingredients, coating solids, extenders, plasticizers, and fragrance and antimicrobials up to 0.25%. There is no exempt-solvent list (Article 3, pp. 18-19).
   • Acetone's MIR is 0.36 under the 2 October 2010 values, which apply to products made on or after 1 January 2015. The 18 July 2001 value was 0.43 ^[10].
   • Scope: an "Aerosol Coating Product" is defined to exclude products covered by Article 2, so a given aerosol falls under one rule or the other.
2. Multi-purpose Lubricant, alternate compliance option (§ 94509(r)): instead of meeting the 10% VOC limit, a product may meet a reactivity limit of 0.45 g O₃/g product. The VOC content must not exceed 25%, and all ingredients at 0.1% or more count at their § 94700 MIR values. Acetone is therefore excluded from the 25% VOC figure but counts toward the 0.45 reactivity limit (Article 2, pp. 82-83).

Labeling, now expired

• § 94512(e): from 31 December 2010 until 31 December 2017, a "Flammable" or "Extremely Flammable" Multi-purpose Solvent or Paint Thinner could not be sold under names such as "Paint Thinner" unless it carried a California VOC hang-tag statement, or showed the flammable compound's common name ("e.g., 'Acetone'") in English and Spanish (Article 2, p. 100).
• Being VOC-exempt does not change federal flammability labeling.

Separately, South Coast AQMD Rule 102 and other air districts' rules govern coatings and stationary-source use; those are not covered by the consumer products rules.

Methyl acetate works like acetone: it is excluded from the VOC definition for every product under CARB's consumer products rule, and no category bans it. It still counts in aerosol coatings and under the Multi-purpose Lubricant reactivity option. Several other exempt solvents are different. PCBTF, perchloroethylene and methylene chloride are excluded from VOC but banned outright in dozens of product categories. The fluorinated exempt compounds can be caught by a separate ban on high global warming potential (GWP) compounds.

Approach: I checked the reactivity (MIR) values and the category bans in CARB's consumer products tables, and applied the provisions of Article 2 and Article 3 covered in my earlier answers. The tables do not give a GWP value for each compound, so I can't say which fluorinated compounds hit the GWP ban.

Where each exempt solvent stands

Solvent	VOC-exempt in Article 2	Category bans	MIR (2010 / 2001), counted in aerosol coatings and MPL reactivity option
Methyl acetate	Yes, § 94508(a)(138)(B)	None	0.07 / 0.07 [11]
Ethane	Yes, (B)	None	0.28 / 0.31 [12]
Methane	Yes, (A)	None	0.014 / 0.01 [13]
PCBTF	Yes, (B)	Table (m)(1)(B)	0.13 / 0.11 [14]
Perchloroethylene	Yes, (B)	Tables (m)(1)(A) and (B)	0.03 / 0.04 [15]
Methylene chloride	Yes, (A)	Tables (m)(1)(A) and (B)	0.04 / 0.07 (listed as dichloromethane) [16]
1,1,1-Trichloroethane	Yes, (A)	Not named in either ban table	0.01 / 0.00 [17]
Methylated siloxanes	Yes, (A)	None	D5: 0.00 / 0.00 [18]; I found no value for other siloxanes

Trichloroethylene is not on the exempt list. Its MIR is 0.64 ^[19], and it is banned in the same categories as perchloroethylene and methylene chloride.

The category bans

• Table 94509(m)(1)(A) bans methylene chloride, perchloroethylene and trichloroethylene in 43 rows of categories. Examples:

  • general purpose cleaners and degreasers, effective 12/31/2008 and 12/31/2005 ^[20][21]
  • contact adhesives, effective 12/31/2005 ^[22]
  • single purpose cleaners and degreasers, effective 1/1/2017 ^[23]
  • plastic pipe adhesive, the latest entry: effective 8/1/2022, sell-through 8/1/2025 ^[24]
  • Pressurized Gas Duster, where trichloroethylene is expressly not prohibited ^[25]

• Table 94509(m)(1)(B) adds PCBTF to the same three solvents for aerosol air fresheners, dry shampoo, hair finishing spray, hair shine, temporary hair color and aerosol crawling bug insecticide. Two further rows are split by fragrance content:

  • 7 percent fragrance or less: effective 1/1/2023 ^[26]
  • between 7 percent and a higher limit: effective 1/1/2031 ^[27]
  • The table row does not show the parent category name or the upper limit for these two rows.

• Fluorinated exempt compounds (HFCs, HCFCs, HFO-1234ze, HFE 7200): Table 94509(n)(1) bans "any chemical compound that has a Global Warming Potential (GWP) Value of 150 or Greater" in its listed categories. Examples:

  • pressurized gas duster, effective 12/31/2010 ^[28]
  • hair care products, effective 1/1/2023 ^[29]
  • aerosol crawling bug insecticide, effective 1/1/2030 ^[30]

  Being VOC-exempt does not protect a compound from this ban. Whether a particular fluorinated compound is caught depends on its GWP, which these tables don't give.

Where they still count

As with acetone, every exempt solvent at 0.1% or more counts at its MIR value toward an aerosol coating's product reactivity limit (Article 3). The same applies to the 0.45 reactivity limit when a Multi-purpose Lubricant uses the alternate compliance option. Methyl acetate has a low MIR (0.07 against acetone's 0.36), so it adds less to product reactivity. PCBTF is banned in Multi-purpose Lubricant: perchloroethylene and methylene chloride since 12/31/2010 for non-solid products ^[31], and silicone-based versions since 12/31/2012 ^[32].

All 53 rows of the two chlorinated-solvent and PCBTF ban tables, with effective and sell-through dates, are in the panel document.