Air Resources Board Suggested Control Measure for Architectural Coatings 

Approved 2007 SCM.doc 1 1-Feb-08 

California Air Resources Board (ARB) 

Suggested Control Measure for Architectural Coatings 

1. APPLICABILITY

1.1 Except as provided in subsection 3, this rule is applicable to any person 

who: 

1.1.1 Supplies, sells, or offers for sale any architectural coating for use 

within the District; or 

1.1.2 Manufactures, blends, or repackages any architectural coating for 

use within the District; or 

1.1.3 Applies or solicits the application of any architectural coating within 

the District. 

2. SEVERABILITY 

2.1 Each provision of this rule shall be deemed severable, and in the event 

that any provision of this rule is held to be invalid, the remainder of this 

rule shall continue in full force and effect. 

3. EXEMPTIONS 

3.1 This rule does not apply to: 

3.1.1 Any architectural coating that is supplied, sold, offered for sale, or 

manufactured for use outside of the District or for shipment to other 

manufacturers for reformulation or repackaging. 

3.1.2 Any aerosol coating product. 

3.2 With the exception of section 7, this rule does not apply to any 

architectural coating that is sold in a container with a volume of one liter 

(1.057 quart) or less. 

4. DEFINITIONS

4.1 Adhesive: Any chemical substance that is applied for the purpose of 

bonding two surfaces together other than by mechanical means. 

4.2 Aerosol Coating Product: A pressurized coating product containing 

pigments or resins that dispenses product ingredients by means of a 

propellant, and is packaged in a disposable can for hand-held application, 

or for use in specialized equipment for ground traffic/marking applications. 
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4.3 Aluminum Roof Coating: A coating labeled and formulated exclusively for 

application to roofs and containing at least 84 grams of elemental 

aluminum pigment per liter of coating (at least 0.7 pounds per gallon). 

Pigment content shall be determined in accordance with SCAQMD 

Method 318-95, incorporated by reference in subsection 8.5.4. 

4.4 Appurtenance: Any accessory to a stationary structure coated at the site 

of installation, whether installed or detached, including, but not limited to: 

bathroom and kitchen fixtures; cabinets; concrete forms; doors; elevators; 

fences; hand railings; heating equipment, air conditioning equipment, and 

other fixed mechanical equipment or stationary tools; lampposts; 

partitions; pipes and piping systems; rain gutters and downspouts; 

stairways, fixed ladders, catwalks, and fire escapes; and window screens. 

4.5 Architectural Coating: A coating to be applied to stationary structures or 

their appurtenances at the site of installation, to portable buildings at the 

site of installation, to pavements, or to curbs. Coatings applied in shop 

applications or to non-stationary structures such as airplanes, ships, 

boats, railcars, and automobiles, and adhesives are not considered 

architectural coatings for the purposes of this rule. 

4.6 Basement Specialty Coating: A clear or opaque coating that is labeled 

and formulated for application to concrete and masonry surfaces to 

provide a hydrostatic seal for basements and other below-grade surfaces. 

Basement Specialty Coatings must meet the following criteria: 

4.6.1 Coating must be capable of withstanding at least 10 psi of 

hydrostatic pressure, as determined in accordance with ASTM 

D7088-04, which is incorporated by reference in subsection 8.5.12; 

and 

4.6.2 Coating must be resistant to mold and mildew growth and must 

achieve a microbial growth rating of 8 or more, as determined in 

accordance with ASTM D3273-00 and ASTM D3274-95, 

incorporated by reference in subsection 8.5.19. 

4.7 Bitumens: Black or brown materials, including, but not limited to, asphalt, 

tar, pitch, and asphaltite that are soluble in carbon disulfide, consist 

mainly of hydrocarbons, and are obtained from natural deposits or as 

residues from the distillation of crude petroleum or coal. 

4.8 Bituminous Roof Coating: A coating which incorporates bitumens that is 

labeled and formulated exclusively for roofing. 

4.9 Bituminous Roof Primer: A primer which incorporates bitumens that is 

labeled and formulated exclusively for roofing and intended for the 

purpose of preparing a weathered or aged surface or improving the 
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adhesion of subsequent surfacing components. 

4.10 Bond Breaker: A coating labeled and formulated for application between 

layers of concrete to prevent a freshly poured top layer of concrete from 

bonding to the layer over which it is poured. 

4.11 Coating: A material applied onto or impregnated into a substrate for 

protective, decorative, or functional purposes. Such materials include, but 

are not limited to, paints, varnishes, sealers, and stains. 

4.12 Colorant: A concentrated pigment dispersion in water, solvent, and/or 

binder that is added to an architectural coating after packaging in sale 

units to produce the desired color. 

4.13 Concrete Curing Compound: A coating labeled and formulated for 

application to freshly poured concrete to perform one or more of the 

following functions: 

4.13.1 Retard the evaporation of water; or 

4.13.2 Harden or dustproof the surface of freshly poured concrete. 

4.14 Concrete/Masonry Sealer: A clear or opaque coating that is labeled and 

formulated primarily for application to concrete and masonry surfaces to 

perform one or more of the following functions: 

4.14.1 Prevent penetration of water; or 

4.14.2 Provide resistance against abrasion, alkalis, acids, mildew, 

staining, or ultraviolet light; or 

4.14.3 Harden or dustproof the surface of aged or cured concrete. 

4.15 Driveway Sealer: A coating labeled and formulated for application to worn 

asphalt driveway surfaces to perform one or more of the following 

functions: 

4.15.1 Fill cracks; or 

4.15.2 Seal the surface to provide protection; or 

4.15.3 Restore or preserve the appearance. 

4.16 Dry Fog Coating: A coating labeled and formulated only for spray 

application such that overspray droplets dry before subsequent contact 

with incidental surfaces in the vicinity of the surface coating activity. 

4.17 Exempt Compound: A compound identified as exempt under the definition 

of Volatile Organic Compound (VOC), subsection 4.63. Exempt 

compounds content of a coating shall be determined by U.S. EPA Method 

24 or South Coast Air Quality Management District (SCAQMD) Method 
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303-91 (Revised 1993), incorporated by reference in subsection 8.5.8. 

4.18 Faux Finishing Coating: A coating labeled and formulated to meet one or 

more of the following criteria: 

4.18.1 A glaze or textured coating used to create artistic effects, 

including, but not limited to: dirt, suede, old age, smoke damage, 

and simulated marble and wood grain; or 

4.18.2 A decorative coating used to create a metallic, iridescent, or 

pearlescent appearance that contains at least 48 grams of 

pearlescent mica pigment or other iridescent pigment per liter of 

coating as applied (at least 0.4 pounds per gallon); or 

4.18.3 A decorative coating used to create a metallic appearance that 

contains less than 48 grams of elemental metallic pigment per liter 

of coating as applied (less than 0.4 pounds per gallon), when 

tested in accordance with SCAQMD Method 318-95, incorporated 

by reference in subsection 8.5.4; or 

4.18.4 A decorative coating used to create a metallic appearance that 

contains greater than 48 grams of elemental metallic pigment per 

liter of coating as applied (greater than 0.4 pounds per gallon) and 

which requires a clear topcoat to prevent the degradation of the 

finish under normal use conditions. The metallic pigment content 

shall be determined in accordance with SCAQMD Method 318-95, 

incorporated by reference in subsection 8.5.4; or 

4.18.5 A clear topcoat to seal and protect a Faux Finishing coating that 

meets the requirements of subsection 4.18.1, 4.18.2, 4.18.3, or 

4.18.4. These clear topcoats must be sold and used solely as part 

of a Faux Finishing coating system, and must be labeled in 

accordance with subsection 6.1.4. 

4.19 Fire-Resistive Coating: A coating labeled and formulated to protect 

structural integrity by increasing the fire endurance of interior or exterior 

steel and other structural materials. The Fire Resistive category includes 

sprayed fire resistive materials and intumescent fire resistive coatings that 

are used to bring structural materials into compliance with federal, state, 

and local building code requirements. Fire Resistive coatings shall be 

tested in accordance with ASTM Designation E 119-07, incorporated by 

reference in subsection 8.5.2. Fire Resistive coatings and testing 

agencies must be approved by building code officials. 

4.20 Fire-Retardant Coating: A coating labeled and formulated to retard ignition 

and flame spread, that has been fire tested and rated by a testing agency 

approved by building code officials for use in bringing building and 

construction materials into compliance with federal, state and local 

building code requirements. The fire-retardant coating and the testing 

agency must be approved by building code officials. The fire-retardant 
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coating shall be tested in accordance with ASTM Designation E 84-07, 

incorporated by reference in subsection 8.5.1. 

Effective January 1, 2010, the Fire Retardant coating category is 

eliminated and coatings with fire retardant properties will be subject to the 

VOC limit of their primary category (e.g., Flat, Nonflat, etc.). 

4.21 Flat Coating: A coating that is not defined under any other definition in this 

rule and that registers gloss less than 15 on an 85-degree meter or less 

than 5 on a 60-degree meter according to ASTM Designation 

D 523-89 (1999), incorporated by reference in subsection 8.5.3. 

4.22 Floor Coating: An opaque coating that is labeled and formulated for 

application to flooring, including, but not limited to, decks, porches, steps, 

garage floors, and other horizontal surfaces which may be subject to foot 

traffic. 

4.23 Form-Release Compound: A coating labeled and formulated for 

application to a concrete form to prevent the freshly poured concrete from 

bonding to the form. The form may consist of wood, metal, or some 

material other than concrete. 

4.24 Gonioapparent: A change in appearance with a change in the angle of 

illumination or the angle of view, as defined according to ASTM 

E-284-06b, incorporated by reference in subsection 8.5.13. 

4.25 Graphic Arts Coating or Sign Paint: A coating labeled and formulated for 

hand-application by artists using brush, airbrush, or roller techniques to 

indoor and outdoor signs (excluding structural components) and murals, 

including lettering enamels, poster colors, copy blockers, and bulletin 

enamels. 

4.26 High-Temperature Coating: A high performance coating labeled and 

formulated for application to substrates exposed continuously or 

intermittently to temperatures above 204oC (400o

F). 

4.27 Industrial Maintenance Coating: A high performance architectural coating, 

including primers, sealers, undercoaters, intermediate coats, and topcoats 

formulated for application to substrates, including floors, exposed to one 

or more of the following extreme environmental conditions listed in 

subsections 4.27.1 through 4.27.5, and labeled as specified in subsection 

6.1.5: 

4.27.1 Immersion in water, wastewater, or chemical solutions (aqueous 

and non-aqueous solutions), or chronic exposure of interior 

surfaces to moisture condensation; or 
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4.27.2 Acute or chronic exposure to corrosive, caustic or acidic agents, or 

to chemicals, chemical fumes, or chemical mixtures or solutions; 

or 

4.27.3 Frequent exposure to temperatures above 121oC (250o

F); or 

4.27.4 Frequent heavy abrasion, including mechanical wear and frequent 

scrubbing with industrial solvents, cleansers, or scouring agents; 

or 

4.27.5 Exterior exposure of metal structures and structural components. 

4.28 Low Solids Coating: A coating containing 0.12 kilogram or less of solids 

per liter (1 pound or less of solids per gallon) of coating material as 

recommended for application by the manufacturer. The VOC content for 

Low Solids Coatings shall be calculated in accordance with subsection 

4.64. 

4.29 Magnesite Cement Coating: A coating labeled and formulated for 

application to magnesite cement decking to protect the magnesite cement 

substrate from erosion by water. 

4.30 Manufacturer’s Maximum Thinning Recommendation: The maximum 

recommendation for thinning that is indicated on the label or lid of the 

coating container. 

4.31 Mastic Texture Coating: A coating labeled and formulated to cover holes 

and minor cracks and to conceal surface irregularities, and is applied in a 

single coat of at least 10 mils (at least 0.010 inch) dry film thickness. 

4.32 Medium Density Fiberboard (MDF): A composite wood product, panel, 

molding, or other building material composed of cellulosic fibers (usually 

wood) made by dry forming and pressing of a resinated fiber mat. 

4.33 Metallic: Similar to the appearance of a gonioapparent material, as 

defined herein, containing metal flakes. 

4.34 Metallic Pigmented Coating: A coating that is labeled and formulated to 

provide a metallic appearance. Metallic Pigmented coatings must contain 

at least 48 grams of elemental metallic pigment (excluding zinc) per liter of 

coating as applied (at least 0.4 pounds per gallon), when tested in 

accordance with SCAQMD Method 318-95, incorporated by reference in 

subsection 8.5.4. The Metallic Pigmented Coating category does not 

include coatings applied to roofs or Zinc-Rich Primers. 

4.35 Multi-Color Coating: A coating that is packaged in a single container and 

that is labeled and formulated to exhibit more than one color when applied 

in a single coat. 
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4.36 Nonflat Coating: A coating that is not defined under any other definition in 

this rule and that registers a gloss of 15 or greater on an 85-degree meter 

and 5 or greater on a 60-degree meter according to ASTM Designation D 

523-89 (1999), incorporated by reference in subsection 8.5.3. 

4.37 Nonflat - High Gloss Coating: A nonflat coating that registers a gloss of 70 

or greater on a 60-degree meter according to ASTM Designation D 523-

89 (1999), incorporated by reference in subsection 8.5.3. Nonflat – High 

Gloss coatings must be labeled in accordance with subsection 6.1.10. 

4.38 Particleboard: A composite wood product panel, molding, or other building 

material composed of cellulosic material (usually wood) in the form of 

discrete particles, as distinguished from fibers, flakes, or strands, which 

are pressed together with resin. 

4.39 Pearlescent: Exhibiting various colors depending on the angles of 

illumination and viewing, as observed in mother-of-pearl. 

4.40 Plywood: A panel product consisting of layers of wood veneers or 

composite core pressed together with resin. Plywood includes panel 

products made by either hot or cold pressing (with resin) veneers to a 

platform. 

4.41 Post-Consumer Coating: Finished coatings generated by a business or 

consumer that have served their intended end uses, and are recovered 

from or otherwise diverted from the waste stream for the purpose of 

recycling. 

4.42 Pre-Treatment Wash Primer: A primer that contains a minimum of 

0.5 percent acid, by weight, when tested in accordance with ASTM 

Designation D 1613-06, incorporated by reference in subsection 8.5.5, 

that is labeled and formulated for application directly to bare metal 

surfaces to provide corrosion resistance and to promote adhesion of 

subsequent topcoats. 

4.43 Primer, Sealer, and Undercoater: A coating labeled and formulated for 

one or more of the following purposes: 

4.43.1 To provide a firm bond between the substrate and the subsequent 

coatings; or 

4.43.2 To prevent subsequent coatings from being absorbed by the 

substrate; or 

4.43.3 To prevent harm to subsequent coatings by materials in the 

substrate; or 

4.43.4 To provide a smooth surface for the subsequent application of 

coatings; or 
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4.43.5 To provide a clear finish coat to seal the substrate; or 

4.43.6 To block materials from penetrating into or leaching out of a 

substrate. 

4.44 Reactive Penetrating Sealer: A clear or pigmented coating that is labeled 

and formulated for application to above-grade concrete and masonry 

substrates to provide protection from water and waterborne contaminants, 

including, but not limited to, alkalis, acids, and salts. Reactive Penetrating 

Sealers must penetrate into concrete and masonry substrates and 

chemically react to form covalent bonds with naturally occurring minerals 

in the substrate. Reactive Penetrating Sealers line the pores of concrete 

and masonry substrates with a hydrophobic coating, but do not form a 

surface film. Reactive Penetrating Sealers must meet all of the following 

criteria: 

4.44.1 The Reactive Penetrating Sealer must improve water repellency at 

least 80 percent after application on a concrete or masonry 

substrate. This performance must be verified on standardized test 

specimens, in accordance with one or more of the following 

standards, incorporated by reference in subsection 8.5.20: ASTM 

C67-07, or ASTM C97-02, or ASTM C140-06; and 

4.44.2 The Reactive Penetrating Sealer must not reduce the water vapor 

transmission rate by more than 2 percent after application on a 

concrete or masonry substrate. This performance must be verified 

on standardized test specimens, in accordance with ASTM 

E96/E96M-05, incorporated by reference in subsection 8.5.21; and 

4.44.3 Products labeled and formulated for vehicular traffic surface 

chloride screening applications must meet the performance criteria 

listed in the National Cooperative Highway Research Report 244 

(1981), incorporated by reference in subsection 8.5.22. 

Reactive Penetrating Sealers must be labeled in accordance with 

subsection 6.1.8. 

4.45 Recycled Coating: An architectural coating formulated such that it 

contains a minimum of 50% by volume post-consumer coating, with a 

maximum of 50% by volume secondary industrial materials or virgin 

materials. 

4.46 Residential: Areas where people reside or lodge, including, but not limited 

to, single and multiple family dwellings, condominiums, mobile homes, 

apartment complexes, motels, and hotels. 

4.47 Roof Coating: A non-bituminous coating labeled and formulated for 

application to roofs for the primary purpose of preventing water 

penetration, reflecting ultraviolet light, or reflecting solar radiation. 
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4.48 Rust Preventative Coating: A coating formulated to prevent the corrosion 

of metal surfaces for one or more of the following applications: 

4.48.1 Direct-to-metal coating; or 

4.48.2 Coating intended for application over rusty, previously coated 

surfaces. 

The Rust Preventative category does not include the following: 

4.48.3 Coatings that are required to be applied as a topcoat over a 

primer; or 

4.48.4 Coatings that are intended for use on wood or any other nonmetallic surface. 

Rust Preventative coatings are for metal substrates only and must be 

labeled as such, in accordance with the labeling requirements in 

subsection 6.1.6. 

4.49 Secondary Industrial Materials: Products or by-products of the paint 

manufacturing process that are of known composition and have economic 

value but can no longer be used for their intended purpose. 

4.50 Semitransparent Coating: A coating that contains binders and colored 

pigments and is formulated to change the color of the surface, but not 

conceal the grain pattern or texture. 

4.51 Shellac: A clear or opaque coating formulated solely with the resinous 

secretions of the lac beetle (Laciffer lacca), and formulated to dry by 

evaporation without a chemical reaction. 

4.52 Shop Application: Application of a coating to a product or a component of 

a product in or on the premises of a factory or a shop as part of a 

manufacturing, production, or repairing process (e.g., original equipment 

manufacturing coatings). 

4.53 Solicit: To require for use or to specify, by written or oral contract. 

4.54 Specialty Primer, Sealer, and Undercoater: A coating that is formulated 

for application to a substrate to block water-soluble stains resulting from: 

fire damage; smoke damage; or water damage. 

Specialty Primers, Sealers, and Undercoaters must be labeled in 

accordance with subsection 6.1.7. 

4.55 Stain: A semitransparent or opaque coating labeled and formulated to 

change the color of a surface but not conceal the grain pattern or texture. 
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4.56 Stone Consolidant: A coating that is labeled and formulated for application 

to stone substrates to repair historical structures that have been damaged 

by weathering or other decay mechanisms. Stone Consolidants must 

penetrate into stone substrates to create bonds between particles and 

consolidate deteriorated material. Stone Consolidants must be specified 

and used in accordance with ASTM E2167-01, incorporated by reference 

in subsection 8.5.23. 

Stone Consolidants are for professional use only and must be labeled as 

such, in accordance with the labeling requirements in subsection 6.1.9. 

4.57 Swimming Pool Coating: A coating labeled and formulated to coat the 

interior of swimming pools and to resist swimming pool chemicals. 

Swimming pool coatings include coatings used for swimming pool repair 

and maintenance. 

4.58 Tint Base: An architectural coating to which colorant is added after 

packaging in sale units to produce a desired color.

4.59 Traffic Marking Coating: A coating labeled and formulated for marking and 

striping streets, highways, or other traffic surfaces, including, but not 

limited to, curbs, berms, driveways, parking lots, sidewalks, and airport 

runways. 

4.60 Tub and Tile Refinish Coating: A clear or opaque coating that is labeled 

and formulated exclusively for refinishing the surface of a bathtub, 

shower, sink, or countertop. Tub and Tile Refinish coatings must meet all 

of the following criteria: 

4.60.1 The coating must have a scratch hardness of 3H or harder and a 

gouge hardness of 4H or harder. This must be determined on 

bonderite 1000, in accordance with ASTM D3363-05, incorporated 

by reference in subsection 8.5.15.; and 

4.60.2 The coating must have a weight loss of 20 milligrams or less after 

1000 cycles. This must be determined with CS-17 wheels on 

bonderite 1000, in accordance with ASTM D4060-07, incorporated 

by reference in subsection 8.5.16; and 

4.60.3 The coating must withstand 1000 hours or more of exposure with 

few or no #8 blisters. This must be determined on unscribed 

bonderite, in accordance with ASTM D4585-99, and ASTM D714-

02e1, incorporated by reference in subsection 8.5.17; and 

4.60.4 The coating must have an adhesion rating of 4B or better after 

24 hours of recovery. This must be determined on unscribed 

bonderite, in accordance with ASTM D4585-99 and ASTM D3359-

02, incorporated by reference in subsection 8.5.14.
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4.61 Veneer: Thin sheets of wood peeled or sliced from logs for use in the 

manufacture of wood products such as plywood, laminated veneer 

lumber, or other products. 

4.62 Virgin Materials: Materials that contain no post-consumer coatings or 

secondary industrial materials. 

4.63 Volatile Organic Compound (VOC): Any volatile compound containing at 

least one atom of carbon, excluding carbon monoxide, carbon dioxide, 

carbonic acid, metallic carbides or carbonates, and ammonium carbonate, 

and excluding the following: 

4.63.1 methane; 

methylene chloride (dichloromethane); 

1,1,1-trichloroethane (methyl chloroform); 

trichlorofluoromethane (CFC-11); 

dichlorodifluoromethane (CFC-12); 

1,1,2-trichloro-1,2,2-trifluoroethane (CFC-113); 

1,2-dichloro-1,1,2,2-tetrafluoroethane (CFC-114); 

chloropentafluoroethane (CFC-115); 

chlorodifluoromethane (HCFC-22); 

1,1,1-trifluoro-2,2-dichloroethane (HCFC-123); 

2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124); 

1,1-dichloro-1-fluoroethane (HCFC-141b); 

1-chloro-1,1-difluoroethane (HCFC-142b); 

trifluoromethane (HFC-23); 

pentafluoroethane (HFC-125); 

1,1,2,2-tetrafluoroethane (HFC-134); 

1,1,1,2-tetrafluoroethane (HFC-134a); 

1,1,1-trifluoroethane (HFC-143a); 

1,1-difluoroethane (HFC-152a); 

cyclic, branched, or linear completely methylated siloxanes; 

the following classes of perfluorocarbons: 

4.63.1.1 cyclic, branched, or linear, completely fluorinated alkanes; 

4.63.1.2 cyclic, branched, or linear, completely fluorinated ethers 

with no unsaturations; 

4.63.1.3 cyclic, branched, or linear, completely fluorinated tertiary 

amines with no unsaturations; and 

4.63.1.4 sulfur-containing perfluorocarbons with no unsaturations 

and with the sulfur bonds only to carbon and fluorine; and 

4.63.2 the following low-reactive organic compounds which have been 

exempted by the U.S. EPA: 

acetone; 

ethane; 

parachlorobenzotrifluoride (1-chloro-4-trifluoromethyl benzene); 
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perchloroethylene; and 

methyl acetate. 

4.64 VOC Actual: VOC Actual is the weight of VOC per volume of coating and 

it is calculated with the following equation: 

VOC Actual = (Ws – Ww – Wec)

 (Vm) 

Where: 

VOC Actual = the grams of VOC per liter of coating (also known as 

“Material VOC”) 

Ws = weight of volatiles, in grams 

Ww = weight of water, in grams 

Wec = weight of exempt compounds, in grams 

Vm = volume of coating, in liters 

4.65 VOC Content: The weight of VOC per volume of coating. VOC Content is 

VOC Regulatory, as defined in subsection 4.66, for all coatings except 

those in the Low Solids category. For coatings in the Low Solids 

category, the VOC Content is VOC Actual, as defined in subsection 4.64. 

If the coating is a multi-component product, the VOC content is VOC 

Regulatory as mixed or catalyzed. If the coating contains silanes, 

siloxanes, or other ingredients that generate ethanol or other VOCs during 

the curing process, the VOC content must include the VOCs emitted 

during curing. 

4.66 VOC Regulatory: VOC Regulatory is the weight of VOC per volume of 

coating, less the volume of water and exempt compounds. It is calculated 

with the following equation: 

VOC Regulatory = (Ws – Ww – Wec)

 (Vm – Vw – Vec) 

Where: 

VOC Regulatory = grams of VOC per liter of coating, less water and 

exempt compounds (also known as “Coating VOC”) 

Ws = weight of volatiles, in grams 

Ww = weight of water, in grams 

Wec = weight of exempt compounds, in grams 

Vm = volume of coating, in liters 

Vw = volume of water, in liters 

Vec = volume of exempt compounds, in liters 
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4.67 Waterproofing Membrane: A clear or opaque coating that is labeled and 

formulated for application to concrete and masonry surfaces to provide a 

seamless waterproofing membrane that prevents any penetration of liquid 

water into the substrate. Waterproofing Membranes are intended for the 

following waterproofing applications: below-grade surfaces, between 

concrete slabs, inside tunnels, inside concrete planters, and under flooring 

materials. Waterproofing Membranes must meet the following criteria: 

4.67.1 Coating must be applied in a single coat of at least 25 mils (at 

least 0.025 inch) dry film thickness; and 

4.67.2 Coatings must meet or exceed the requirements contained in 

ASTM C836-06, incorporated by reference in subsection 8.5.18. 

The Waterproofing Membrane category does not include topcoats that are 

included in the Concrete/Masonry Sealer category (e.g., parking deck 

topcoats, pedestrian deck topcoats, etc.). 

4.68 Wood Coatings: Coatings labeled and formulated for application to wood 

substrates only. The Wood Coatings category includes the following clear 

and semitransparent coatings: lacquers; varnishes; sanding sealers; 

penetrating oils; clear stains; wood conditioners used as undercoats; and 

wood sealers used as topcoats. The Wood Coatings category also 

includes the following opaque wood coatings: opaque lacquers; opaque 

sanding sealers; and opaque lacquer undercoaters. The Wood Coatings 

category does not include the following: clear sealers that are labeled and 

formulated for use on concrete/masonry surfaces; or coatings intended for 

substrates other than wood. 

Wood Coatings must be labeled “For Wood Substrates Only”, in 

accordance with subsection 6.1.11. 

4.69 Wood Preservative: A coating labeled and formulated to protect exposed 

wood from decay or insect attack, that is registered with both the U.S. 

EPA under the Federal Insecticide, Fungicide, and Rodenticide Act (7 

United States Code (U.S.C.) Section 136, et seq.) and with the California 

Department of Pesticide Regulation. 

4.70 Wood Substrate: A substrate made of wood, particleboard, plywood, 

medium density fiberboard, rattan, wicker, bamboo, or composite products 

with exposed wood grain. Wood Products do not include items comprised 

of simulated wood. 

4.71 Zinc-Rich Primer: A coating that meets all of the following specifications: 

4.71.1 Coating contains at least 65 percent metallic zinc powder or zinc 

dust by weight of total solids; and 
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4.71.2 Coating is formulated for application to metal substrates to provide 

a firm bond between the substrate and subsequent applications of 

coatings; and 

4.71.3 Coating is intended for professional use only and is labeled as 

such, in accordance with the labeling requirements in subsection 

6.1.12. 

5. STANDARDS

5.1 VOC Content Limits: Except as provided in subsections 5.2 or 5.3, no 

person shall: 

5.1.1 manufacture, blend, or repackage for use within the district; or 

5.1.2 supply, sell, or offer for sale for use within the district; or 

5.1.3 solicit for application or apply within the district, any architectural 

coating with a VOC content in excess of the corresponding limit 

specified in Table 1, after the specified effective date in Table 1. 

Limits are expressed as VOC Regulatory, thinned to the 

manufacturer’s maximum thinning recommendation, excluding any 

colorant added to tint bases. 

5.2 Most Restrictive VOC Limit: If a coating meets the definition in Section 

4 for one or more specialty coating categories that are listed in Table 1, 

then that coating is not required to meet the VOC limits for Flat, Nonflat, or 

Nonflat – High Gloss coatings, but is required to meet the VOC limit for 

the applicable specialty coating listed in Table 1. 

With the exception of the specialty coating categories specified in 

subsections 5.2.1 through 5.2.12, if a coating is recommended for use in 

more than one of the specialty coating categories listed in Table 1, the 

most restrictive (or lowest) VOC content limit shall apply. This 

requirement applies to: usage recommendations that appear anywhere on 

the coating container, anywhere on any label or sticker affixed to the 

container, or in any sales, advertising, or technical literature supplied by a 

manufacturer or anyone acting on their behalf. 

5.2.1 Metallic pigmented coatings. 

5.2.2 Shellacs. 

5.2.3 Pretreatment wash primers. 

5.2.4 Industrial maintenance coatings. 

5.2.5 Low-solids coatings. 

5.2.6 Wood preservatives. 

5.2.7 High temperature coatings. 

5.2.8 Bituminous roof primers. 

5.2.9 Specialty primers, sealers, and undercoaters. 

5.2.10 Aluminum roof coatings. 
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5.2.11 Zinc-rich primers. 

5.2.12 Wood Coatings. 

5.3 Sell-Through of Coatings: A coating manufactured prior to the effective 

date specified for that coating in Table 1 may be sold, supplied, or offered 

for sale for up to three years after the specified effective date. In addition, 

a coating manufactured before the effective date specified for that coating 

in Table 1 may be applied at any time, both before and after the specified 

effective date, so long as the coating complied with the standards in effect 

at the time the coating was manufactured. This subsection 5.3 does not 

apply to any coating that does not display the date or date-code required 

by subsection 6.1.1. 

5.4 Painting Practices: All architectural coating containers used to apply the 

contents therein to a surface directly from the container by pouring, 

siphoning, brushing, rolling, padding, ragging or other means, shall be 

closed when not in use. These architectural coating containers include, 

but are not limited to, drums, buckets, cans, pails, trays or other 

application containers. Containers of any VOC-containing materials used 

for thinning and cleanup shall also be closed when not in use. 

5.5 Thinning: No person who applies or solicits the application of any 

architectural coating shall apply a coating that is thinned to exceed the 

applicable VOC limit specified in Table 1. 

5.6 Coatings Not Listed in Table 1: For any coating that does not meet any 

of the definitions for the specialty coatings categories listed in Table 1, the 

VOC content limit shall be determined by classifying the coating as a Flat, 

Nonflat, or Nonflat – High Gloss coating, based on its gloss, as defined in 

subsections 4.21, 4.36, and 4.37, and the corresponding Flat, Nonflat, or 

Nonflat – High Gloss VOC limit in Table 1 shall apply. 

6. CONTAINER LABELING REQUIREMENTS

6.1 Each manufacturer of any architectural coating subject to this rule shall 

display the information listed in subsections 6.1.1 through 6.1.12 on the 

coating container (or label) in which the coating is sold or distributed. 

6.1.1 Date Code: The date the coating was manufactured, or a date 

code representing the date, shall be indicated on the label, lid, or 

bottom of the container. If the manufacturer uses a date code for 

any coating, the manufacturer shall file an explanation of each 

code with the Executive Officer of the ARB. 

6.1.2 Thinning Recommendations: A statement of the manufacturer’s 

recommendation regarding thinning of the coating shall be 
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indicated on the label or lid of the container. This requirement does 

not apply to the thinning of architectural coatings with water. If 

thinning of the coating prior to use is not necessary, the 

recommendation must specify that the coating is to be applied 

without thinning. 

6.1.3 VOC Content: Each container of any coating subject to this rule

shall display one of the following values in grams of VOC per liter 

of coating: 

6.1.3.1 Maximum VOC Content as determined from all potential 

product formulations; or 

6.1.3.2 VOC Content as determined from actual formulation data; 

or 

6.1.3.3 VOC Content as determined using the test methods in 

subsection 8.2. 

If the manufacturer does not recommend thinning, the container 

must display the VOC Content, as supplied. If the manufacturer 

recommends thinning, the container must display the VOC 

Content, including the maximum amount of thinning solvent 

recommended by the manufacturer. If the coating is a multicomponent product, the container must display the VOC content as 

mixed or catalyzed. If the coating contains silanes, siloxanes, or 

other ingredients that generate ethanol or other VOCs during the 

curing process, the VOC content must include the VOCs emitted 

during curing. VOC Content shall be determined as defined in 

subsections 4.64, 4.65, and 4.66. 

6.1.4 Faux Finishing Coatings: Effective January 1, 2010, the labels of 

all Faux Finishing coatings shall prominently display the statement 

“This product can only be sold or used as part of a Faux Finishing 

coating system”. 

6.1.5 Industrial Maintenance Coatings: Effective January 1, 2010, the 

labels of all Industrial Maintenance coatings shall prominently 

display the statement “For industrial use only” or “For professional 

use only”. 

6.1.6 Rust Preventative Coatings: The labels of all rust preventative 

coatings shall prominently display the statement “For Metal 

Substrates Only.” 

6.1.7 Specialty Primers, Sealers, and Undercoaters: Effective 

January 1, 2010, and until January 1, 2012, the labels of all 

specialty primers, sealers, and undercoaters shall prominently 
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display one or more of the descriptions listed in subsection 6.1.7.1 

through 6.1.7.3. 

6.1.7.1 For fire-damaged substrates. 

6.1.7.2 For smoke-damaged substrates. 

6.1.7.3 For water-damaged substrates. 

6.1.8 Reactive Penetrating Sealers: Effective January 1, 2010, the 

labels of all Reactive Penetrating Sealers shall prominently display 

the statement “Reactive Penetrating Sealer”. 

6.1.9 Stone Consolidants: Effective January 1, 2010, the labels of all 

Stone Consolidants shall prominently display the statement “Stone 

Consolidant - For Professional Use Only”. 

6.1.10 Nonflat - High Gloss Coatings: The labels of all Nonflat - High 

Gloss coatings shall prominently display the words “High Gloss.” 

6.1.11 Wood Coatings: Effective January 1, 2010, the labels of all Wood

Coatings shall prominently display the statement “For Wood 

Substrates Only”. 

6.1.12 Zinc Rich Primers: Effective January 1, 2010, the labels of all 

Zinc Rich Primers shall prominently display the statement “For 

Professional Use Only”. 

7. REPORTING REQUIREMENTS

7.1 Sales Data: A responsible official from each manufacturer shall upon 

request of the Executive Officer of the ARB, or his or her delegate, 

provide data concerning the distribution and sales of architectural 

coatings. The responsible official shall within 180 days provide 

information, including, but not limited to: 

7.1.1 the name and mailing address of the manufacturer; 

7.1.2 the name, address and telephone number of a contact person; 

7.1.3 the name of the coating product as it appears on the label and the 

applicable coating category; 

7.1.4 whether the product is marketed for interior or exterior use or both; 

7.1.5 the number of gallons sold in California in containers greater than 

one liter (1.057 quart) and equal to or less than one liter 

(1.057 quart); 

7.1.6 the VOC Actual content and VOC Regulatory content in grams per 

liter. If thinning is recommended, list the VOC Actual content and 

VOC Regulatory content after maximum recommended thinning. If 

containers less than one liter have a different VOC content than 
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containers greater than one liter, list separately. If the coating is a 

multi-component product, provide the VOC content as mixed or 

catalyzed; 

7.1.7 the names and CAS numbers of the VOC constituents in the 

product; 

7.1.8 the names and CAS numbers of any compounds in the product 

specifically exempted from the VOC definition, as listed in 

subsection 4.63.1 or 4.63.2; 

7.1.9 whether the product is marketed as solventborne, waterborne, or 

100% solids; 

7.1.10 description of resin or binder in the product; 

7.1.11 whether the coating is a single-component or multi-component 

product; 

7.1.12 the density of the product in pounds per gallon; 

7.1.13 the percent by weight of: solids, all volatile materials, water, and 

any compounds in the product specifically exempted from the VOC 

definition, as listed in subsection 4.63.1 or 4.63.2; and 

7.1.14 the percent by volume of: solids, water, and any compounds in the 

product specifically exempted from the VOC definition, as listed in 

subsection 4.63.1 or 4.63.2. 

7.2 All sales data listed in subsections 7.1.1 to 7.1.14 shall be maintained by 

the responsible official for a minimum of three years. Sales data 

submitted by the responsible official to the Executive Officer of the ARB 

may be claimed as confidential, and such information shall be handled in 

accordance with the procedures specified in Title 17, California Code of 

Regulations Sections 91000-91022. 

8. COMPLIANCE PROVISIONS AND TEST METHODS

8.1 Calculation of VOC Content: For the purpose of determining compliance 

with the VOC content limits in Table 1, the VOC content of a coating shall 

be determined as defined in subsection 4.64, 4.65, or 4.66. The VOC 

content of a tint base shall be determined without colorant that is added 

after the tint base is manufactured. If the manufacturer does not 

recommend thinning, the VOC Content must be calculated for the product 

as supplied. If the manufacturer recommends thinning, the VOC Content 

must be calculated including the maximum amount of thinning solvent 

recommended by the manufacturer. If the coating is a multi-component 

product, the VOC content must be calculated as mixed or catalyzed. If 

the coating contains silanes, siloxanes, or other ingredients that generate 

ethanol or other VOCs during the curing process, the VOC content must 

include the VOCs emitted during curing. 

8.2 VOC Content of Coatings: To determine the physical properties of a 

coating in order to perform the calculations in subsection 4.64 or 4.66, the 
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reference method for VOC content is U.S. EPA Method 24, incorporated 

by reference in subsection 8.5.9, except as provided in subsections 8.3 

and 8.4. An alternative method to determine the VOC content of coatings 

is SCAQMD Method 304-91 (Revised 1996), incorporated by reference in 

subsection 8.5.10. The exempt compounds content shall be determined 

by SCAQMD Method 303-91 (Revised 1993), BAAQMD Method 43 

(Revised 1996), or BAAQMD Method 41 (Revised 1995), as applicable, 

incorporated by reference in subsections 8.5.8, 8.5.6, and 8.5.7, 

respectively. To determine the VOC content of a coating, the 

manufacturer may use U.S. EPA Method 24, or an alternative method as 

provided in subsection 8.3, formulation data, or any other reasonable 

means for predicting that the coating has been formulated as intended 

(e.g., quality assurance checks, record keeping). However, if there are 

any inconsistencies between the results of a Method 24 test and any other 

means for determining VOC content, the Method 24 test results will 

govern, except when an alternative method is approved as specified in 

subsection 8.3. The District Air Pollution Control Officer (APCO) may 

require the manufacturer to conduct a Method 24 analysis. 

8.3 Alternative Test Methods: Other test methods demonstrated to provide 

results that are acceptable for purposes of determining compliance with 

subsection 8.2, after review and approved in writing by the staffs of the 

District, the ARB, and the U.S. EPA, may also be used. 

8.4 Methacrylate Traffic Marking Coatings: Analysis of methacrylate 

multicomponent coatings used as traffic marking coatings shall be 

conducted according to a modification of U.S. EPA Method 24 (40 CFR 

59, subpart D, Appendix A), incorporated by reference in subsection 

8.5.11. This method has not been approved for methacrylate 

multicomponent coatings used for other purposes than as traffic marking 

coatings or for other classes of multicomponent coatings. 

8.5 Test Methods: The following test methods are incorporated by reference 

herein, and shall be used to test coatings subject to the provisions of this 

rule: 

8.5.1 Flame Spread Index: The flame spread index of a fire-retardant 

coating shall be determined by ASTM E 84-07, “Standard Test 

Method for Surface Burning Characteristics of Building Materials” 

(see section 4, Fire-Retardant Coating). 

8.5.2 Fire Resistance Rating: The fire resistance rating of a fireresistive coating shall be determined by ASTM E 119-07, “Standard 

Test Methods for Fire Tests of Building Construction Materials” 

(see section 4, Fire-Resistive Coating). 
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8.5.3 Gloss Determination: The gloss of a coating shall be determined 

by ASTM D 523-89 (1999), “Standard Test Method for Specular 

Gloss” (see section 4, Flat Coating, Nonflat Coating, and Nonflat - 

High Gloss Coating). 

8.5.4 Metal Content of Coatings: The metallic content of a coating shall 

be determined by SCAQMD Method 318-95, “Determination of 

Weight Percent Elemental Metal in Coatings by X-Ray Diffraction,” 

SCAQMD Laboratory Methods of Analysis for Enforcement 

Samples (see section 4, Aluminum Roof, Faux Finishing, and

Metallic Pigmented Coating). 

8.5.5 Acid Content of Coatings: The acid content of a coating shall be 

determined by ASTM D 1613-06, “Standard Test Method for Acidity 

in Volatile Solvents and Chemical Intermediates Used in Paint, 

Varnish, Lacquer, and Related Products” (see section 4, Pretreatment Wash Primer). 

8.5.6 Exempt Compounds--Siloxanes: Exempt compounds that are 

cyclic, branched, or linear completely methylated siloxanes, shall 

be analyzed as exempt compounds for compliance with section 8 

by BAAQMD Method 43, “Determination of Volatile Methylsiloxanes 

in Solvent-Based Coatings, Inks, and Related Materials,” BAAQMD

Manual of Procedures, Volume III, adopted 11/6/96 (see section 4, 

Volatile Organic Compound, and subsection 8.2). 

8.5.7 Exempt Compounds--Parachlorobenzotrifluoride (PCBTF): The 

exempt compound parachlorobenzotrifluoride, shall be analyzed as 

an exempt compound for compliance with section 8 by BAAQMD 

Method 41, “Determination of Volatile Organic Compounds in 

Solvent Based Coatings and Related Materials Containing 

Parachlorobenzotrifluoride,” BAAQMD Manual of Procedures, 

Volume III, adopted 12/20/95 (see section 4, Volatile Organic 

Compound, and subsection 8.2). 

8.5.8 Exempt Compounds: The content of compounds exempt under 

U.S. EPA Method 24 shall be analyzed by SCAQMD Method 303-

91 (Revised 1993), “Determination of Exempt Compounds,” 

SCAQMD Laboratory Methods of Analysis for Enforcement 

Samples (see section 4, Volatile Organic Compound, and 

subsection 8.2). 

8.5.9 VOC Content of Coatings: The VOC content of a coating shall be 

determined by U.S. EPA Method 24 as it exists in appendix A of 40 

Code of Federal Regulations (CFR) part 60, “Determination of 

Volatile Matter Content, Water Content, Density, Volume Solids, 
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and Weight Solids of Surface Coatings” (see subsection 8.2). 

8.5.10 Alternative VOC Content of Coatings: The VOC content of 

coatings may be analyzed either by U.S. EPA Method 24 or 

SCAQMD Method 304-91 (Revised 1996), “Determination of 

Volatile Organic Compounds (VOC) in Various Materials,” 

SCAQMD Laboratory Methods of Analysis for Enforcement 

Samples (see subsection 8.2). 

8.5.11 Methacrylate Traffic Marking Coatings: The VOC content of 

methacrylate multicomponent coatings used as traffic marking 

coatings shall be analyzed by the procedures in 40 CFR part 59, 

subpart D, appendix A, “Determination of Volatile Matter Content of 

Methacrylate Multicomponent Coatings Used as Traffic Marking 

Coatings” (see subsection 8.4). 

8.5.12 Hydrostatic Pressure for Basement Specialty Coatings: ASTM 

D7088-04, “Standard Practice for Resistance to Hydrostatic 

Pressure for Coatings Used in Below Grade Applications Applied to 

Masonry” (see section 4, Basement Specialty Coating). 

8.5.13 Gonioapparent Characteristics for Coatings: ASTM E-284-07, 

“Standard Terminology of Appearance” (see section 4, 

Gonioapparent). 

8.5.14 Tub and Tile Refinish Coating Adhesion: ASTM D 4585-99, 

“Standard Practice for Testing Water Resistance of Coatings Using 

Controlled Condensation” and ASTM D3359-02, “Standard Test 

Methods for Measuring Adhesion by Tape Test” (see section 4, 

Tub and Tile Refinish Coating). 

8.5.15 Tub and Tile Refinish Coating Hardness: ASTM D 3363-05, 

“Standard Test Method for Film Hardness by Pencil Test” (see 

section 4, Tub and Tile Refinish Coating). 

8.5.16 Tub and Tile Refinish Coating Abrasion Resistance: ASTM 

D 4060-07, “Standard Test Methods for Abrasion Resistance of 

Organic Coatings by the Taber Abraser” (see section 4, Tub and 

Tile Refinish Coating). 

8.5.17 Tub and Tile Refinish Coating Water Resistance: ASTM 

D 4585-99, “Standard Practice for Testing Water Resistance of 

Coatings Using Controlled Condensation” and ASTM D714-02e1, 

“Standard Test Method for Evaluating Degree of Blistering of 

Paints” (see section 4, Tub and Tile Refinish Coating). 
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8.5.18 Waterproofing Membrane: ASTM C836-06, “Standard 

Specification for High Solids Content, Cold Liquid-Applied 

Elastomeric Waterproofing Membrane for Use with Separate 

Wearing Course” (see section 4, Waterproofing Membrane). 

8.5.19 Mold and Mildew Growth for Basement Specialty Coatings: 

ASTM D3273-00, “Standard Test Method for Resistance to Growth 

of Mold on the Surface of Interior Coatings in an Environmental 

Chamber” and ASTM D3274-95, “Standard Test Method for 

Evaluating Degree of Surface Disfigurement of Paint Films by 

Microbial (Fungal or Algal) Growth or Soil and Dirt Accumulation” 

(see section 4, Basement Specialty Coating). 

8.5.20 Reactive Penetrating Sealer Water Repellency: ASTM C67-07, 

“Standard Test Methods for Sampling and Testing Brick and 

Structural Clay Tile”; or ASTM C97-02, “Standard Test Methods for 

Absorption and Bulk Specific Gravity of Dimension Stone”; or 

ASTM C140-06, “Standard Test Methods for Sampling and Testing 

Concrete Masonry Units and Related Units” (see section 4, 

Reactive Penetrating Sealer). 

8.5.21 Reactive Penetrating Sealer Water Vapor Transmission: ASTM 

E96/E96M-05, “Standard Test Method for Water Vapor 

Transmission of Materials” (see section 4, Reactive Penetrating 

Sealer). 

8.5.22 Reactive Penetrating Sealer - Chloride Screening Applications: 

National Cooperative Highway Research Report 244 (1981), 

“Concrete Sealers for the Protection of Bridge Structures” (see 

section 4, Reactive Penetrating Sealer). 

8.5.23 Stone Consolidants: ASTM E2167-01, “Standard Guide for 

Selection and Use of Stone Consolidants” (see section 4, Stone 

Consolidant).
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Table 1 

VOC CONTENT LIMITS FOR ARCHITECTURAL COATINGS

Limits are expressed as VOC Regulatory, thinned to the manufacturer’s maximum 

thinning recommendation, excluding any colorant added to tint bases. 

Coating Category Effective 1/1/2010 Effective 1/1/2012 

Flat Coatings 50 

Nonflat Coatings 100 

Nonflat - High Gloss Coatings 150 

Specialty Coatings

Aluminum Roof Coatings 400 

Basement Specialty Coatings 400 

Bituminous Roof Coatings 50 

Bituminous Roof Primers 350 

Bond Breakers 350 

Concrete Curing Compounds 350 

Concrete/Masonry Sealers 100 

Driveway Sealers 50 

Dry Fog Coatings 150 

Faux Finishing Coatings 350 

Fire Resistive Coatings 350 

Floor Coatings 100 

Form-Release Compounds 250 

Graphic Arts Coatings (Sign Paints) 500 

High Temperature Coatings 420 

Industrial Maintenance Coatings 250 

Low Solids Coatingsa 120 

Magnesite Cement Coatings 450 

Mastic Texture Coatings 100 

Metallic Pigmented Coatings 500 

Multi-Color Coatings 250 

Pre-Treatment Wash Primers 420 

Primers, Sealers, and Undercoaters 100 

Reactive Penetrating Sealers 350 

Recycled Coatings 250 
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Table 1 

VOC CONTENT LIMITS FOR ARCHITECTURAL COATINGS

Limits are expressed as VOC Regulatory, thinned to the manufacturer’s maximum 

thinning recommendation, excluding any colorant added to tint bases. 

Coating Category Effective 1/1/2010 Effective 1/1/2012 

Roof Coatings 50 

Rust Preventative Coatings 250 

Shellacs: 

• Clear 

• Opaque 

730 

550 

Specialty Primers, Sealers, and 

Undercoaters 

 100 

Stains 250 

Stone Consolidants 450 

Swimming Pool Coatings 340 

Traffic Marking Coatings 100 

Tub and Tile Refinish Coatings 420 

Waterproofing Membranes 250 

Wood Coatings 275 

Wood Preservatives 350 

Zinc-Rich Primers 340 

a. Limit is expressed as VOC Actual.