Automotive Specialty Products Alliance • 1667 K Street, N.W. Suite 300 • Washington, DC 20006

Phone 202.833.7308 • Fax 202.223.2636 • www.aspalliance.org

October 16, 2012

Air Resources Board 

1001 I Street, 23rd Floor

Sacramento, California 95814

Attn: Ms. Lori Andreoni 

Manager, Board Administration and Regulations Coordination Unit

http://www.arb.ca.gov/lispub/comm/bclist.php

Subject: Proposed Amendments to the California Consumer Products Regulation Pertaining to 

Automotive Windshield Washer Fluid Products; Board Agenda Item # 12-7-2

Dear Board Members:

The Automotive Specialty Products Alliance (ASPA) appreciates the opportunity to offer comments on 

the California Air Resources Board (ARB) proposal to modify current regulatory requirements for 

Automotive Windshield Washer Fluid (AWWF) Products. As discussed below, ASPA supports the 

ARB proposal to redefine “Type A” areas to better characterize areas of the state that generally 

experience freezing temperatures, and to clarify the definition of the AWWF product category.

1. The modified definition of the AWWF product category in ARB’s proposal improves the clarity 

of the applicable requirements.

ASPA strongly supports ARB’s proposal to consolidate all definitions pertaining to the AWWF 

category in a single modified definition. Clearly defined product categories and related terms are 

critically important to California’s complex and comprehensive Consumer Products Regulation [17 

CCR §94508 (a)].

The current description of Type “A” area lists: (1) specific air basins that are defined in other sections of 

the California Code of Regulations, or (2) entire counties.1

 The current reference to specified air basins 

is not readily comprehensible. Therefore, ASPA supports ARB’s proposal to include the names of the 

counties that comprise the air basins in the Type “A” area. ASPA agrees with ARB staff’s statement that 

“...county boundaries are more readily understood than are air basins boundaries.” 2

ASPA also supports ARB’s proposal to use the U.S. Postal Service’s zip codes to identify the freezing 

regions of the state that are being added to the Type “A” area. ASPA agrees with ARB staff’s 

conclusion that zip codes “...are commonly used and understood...and their use would provide a 

practical way for manufacturers, distributors, and retailers to manage the distribution and sale of AWWF 

products into the new Type ‘A’ areas.” 3

 1 See Table of Standards at 17 CCR § 94509(a). 

2 ARB, “Staff Report: Initial Statement of Reasons, Proposed Amendments to the California Regulation for 

Reducing Emissions from Consumer Products Pertaining to Automotive Windshield Washer Fluid Products,” (Aug. 29, 

2012) at Ch. 2 p. 16. 

3 Id. at Ch. 2 p. 11. 
ASPA Comments on Board Agenda Item # 12-7-2

October 16, 2012

Page 2 of 2

2. ARB’s proposed modifications will promote public safety by including additional parts of the 

state, which routinely experience freezing temperatures, in the “Type A” area. 

The use of freeze-resistant pre-mixed (i.e. ready-to-use) AWWF products enables drivers to maintain 

clear vision during the winter months, when drivers in colder areas of the state must routinely contend 

with ice, snow, freezing rain and road spray on their windshields. Expanding the “Type A” area to 

include narrowly-defined additional parts of the state (identified by zip codes) that routinely experience 

freezing, ARB will ensure drivers will be able to use freeze-resistant AWWF products to maintain the 

clear vision necessary to safely operate their vehicles in freezing conditions – a boon to public safety.

3. ARB’s proposed modification to labeling requirements for concentrated AWWF products will 

improve safety for drivers who travel to areas of the state that experience freezing temperatures.

The draft proposed modifications will permit product labels for dilutable (i.e. concentrated) AWWF 

products to include instructions informing consumers that they may follow the dilution instructions for 

“Type A’ areas when travelling to areas in California with freezing temperatures. ASPA supports this 

proposed revision since it will allow manufacturers to provide instructions on product labels that clearly 

communicate that drivers may legally mix dilutable AWWF to prevent it from freezing in the vehicles 

windshield washer fluid reservoir.

If you have any questions, please contact me at 202-833-7308.

About ASPA: The Automotive Specialty Products Alliance combines the efforts of the Automotive 

Aftermarket Industry Association (AAIA), the Consumer Specialty Products Association (CSPA), and 

the Motor & Equipment Manufacturers Association (MEMA) – three national trade associations 

representing companies engaged in the manufacture, formulation, distribution, and sale of automotive 

specialty products. ASPA presents a unified industry voice for the associations’ members engaged in the 

automotive chemical and vehicle appearance products markets.

Respectfully submitted,

Sean R. Moore

On behalf of the ASPA Operating Committee and Board of Directors

cc: Carla D. Takemoto, Chief, Area Source and Emissions Inventory Programs Branch, PTSD

Jose Gomez, Manager, Technical Development Section, Area Source and Emissions 

Inventory Programs Branch, PTSD

Olufemi Olaluwoye, Air Pollution Specialist, Technical Development Section, Area Source 

and Emissions Inventory Programs Branch, PTSD