Q.01

What does VOC compliant mean for consumer products sold in California?

In California, "VOC compliant" means the product's volatile organic compound (VOC) content is at or below the limit CARB sets for its product category, as of the date the product was made or sold. CARB is the California Air Resources Board, and the limits sit in the Consumer Products Regulation, title 17 CCR §§94507-94517. The rule reads: "no person shall sell, supply, offer for sale, or manufacture for sale in California any consumer product which, at the time of sale or manufacture, contains volatile organic compounds in excess of the limits" in the §94509(a) Table of Standards (CARB compilation, p. 67). There is no single California VOC number. Compliance always depends on the category, the limit and the effective date that apply.

Who it applies to

  • Anyone who sells, supplies, offers for sale or manufactures consumer products for use in California (§94507).
  • "Consumer product" means chemically formulated household and institutional products. Examples include detergents, cleaners, polishes, cosmetics, personal care, home/lawn/garden products, disinfectants, aerosol paints and automotive specialty products. Aerosol adhesives are covered for consumer, industrial and commercial uses. Other paints, furniture coatings and architectural coatings are not covered (§94508(a)(29)) (p. 35).

How VOC is measured

  • "VOC Content" is VOC weight as a percentage of product weight, excluding the container (§94508(a)(139)).
  • The VOC definition leaves out several compounds. These include methane, some CFCs, HCFCs and HFCs (for example HFC-134a and HFC-152a), HFO-1234ze, completely methylated siloxanes, and acetone, ethane, methyl acetate, PCBTF and perchloroethylene (§94508(a)(138), pp. 63-64).
  • The limits do not apply to LVP-VOCs (§94510(d)). An LVP-VOC is, for example, a compound with vapour pressure under 0.1 mm Hg at 20 °C, or a boiling point above 216 °C (§94508(a)(84)).
  • Fragrance is exempt up to 2% by weight for products made before 1 January 2031. From that date, nonaerosol general purpose cleaners and degreasers, air fresheners, disinfectants and sanitizers drop to 0.25% (§94510(c), p. 104).
  • Compliance testing uses CARB Method 310 (§94515(a)).
  • For products meant to be diluted with water, the limit applies after the minimum recommended dilution. Pump sprays are an exception: their limit applies before any dilution (§94509(b)).

What the limits look like (examples from the §94509(a) table)

CategoryEffective dateVOC limit (% by weight)
Manual Aerosol Air Freshener1/1/2023 → 1/1/202710 → 5 [1][2]
Hair Finishing Spray1/1/202350 [3]
Hair Shine1/1/202950 [4]
General Purpose (cleaner)1/1/9510 [5]
Brake Cleaner12/31/201010 [6]

Limits tighten in steps over time, and several categories have future dates in 2027 and 2029. So a formula that complies today can stop complying later.

Other conditions that come with being compliant

  • Certain chemicals are banned in some categories. Methylene chloride, perchloroethylene and trichloroethylene are banned in categories such as spot removers and sealants [7]. PCBTF is added to that ban for products such as hair finishing spray from 1/1/2023 [8]. Para-dichlorobenzene is banned in solid air fresheners [9], and alkylphenol ethoxylate surfactants in nonaerosol general purpose cleaners [10]. In listed categories, any compound with a global warming potential (GWP) of 150 or more is banned, for example in temporary hair color from 1/1/2029 [11].
  • Lowest limit applies. If the label claims the product can be used in a category with a lower limit, the lowest limit applies (§94512(a)(1)).
  • Date code on the pack. Each container must show the manufacture date or a code for it. Batch numbers that can't be traced to a specific day, month and year don't count (§94512(b)(1)) (p. 116).
  • Three-year sell-through. Products made before a limit takes effect may be sold for up to three years after it. This only works if the product shows a date or date code (§94509(c)) (p. 83).
  • Products shipped out of state. The rules do not cover products made in California for use outside the state. A seller can also be exempt if it shows the product is meant for use outside California and that it took reasonable precautions to keep it out. That second route does not cover products sold to California retail outlets (§94510(a)-(b)).
  • Other routes to compliance: innovative product exemptions (§94511), variances (§94514), and Alternative Control Plans, which let a manufacturer average emissions across its products (§§94540-94555) (p. ii).

Related CARB regulations

  • Antiperspirants and deodorants have their own VOC limits under Article 1 (§§94500-94506.5).
  • Aerosol coating products (spray paints) are not limited by VOC percentage. They must meet reactivity limits under §94522, which are based on the Maximum Incremental Reactivity (MIR) values in §§94700-94701 (p. 149).

Local air district rules, such as South Coast AQMD's, were not part of this search.

Approach: I used the CARB Consumer Products Regulation tables (VOC standards, chemical and GWP bans) in the datasets, and CARB's compiled regulation text for definitions, exemptions and labeling. That compilation is CARB's unofficial version, current as of August 2022; CARB says the official text is the California Code of Regulations published by the Office of Administrative Law.

Sources:

Q.02