Consumer Products 

Regulations 

Overview and Proposed 

Amendments

September 26, 2013
Overview

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Long Standing ARB Consumer 

Products Program

 Program requirements established in 1988

 Requires maximum feasible reduction in 

VOC emissions 

 Regulations must be necessary to attain 

ambient air quality standards

 Regulations must be technologically and 

commercially feasible 

 Must preserve product forms

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What Are Consumer Products?

 Used by household and institutional 

consumers

 Types of products include:

 Cleaning Products 

 Aerosol Paints

 Antiperspirants and Deodorants

 Household Pesticides

 Personal Care Products 

 Automotive Specialty Products

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Consumer Products Contain VOCs

 Active ingredients

 Solvents for active 

ingredients

 Propellants

 Fragrances

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State Implementation Plan (SIP)

 VOC reductions are needed to attain 

ozone air quality standards

 This rulemaking meets the reductions 

expected from consumer products in the 

2007 SIP

 Consumer products continue to be a 

significant source of VOCs
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Program Implementation 

Activities

 Rule development and interpretation

 Laboratory testing to determine compliance

 Enforcement for noncomplying products

 Review and approval of compliance 

flexibility options

 Emissions inventory development

 Assist other jurisdictions

 Report to the Board
Surveys of the Industry

 Guide regulatory 

development

 Define categories

 Collect information on: 

 Sales 

 VOC ingredients

 Economic information

 Used to build emissions 

inventory

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VOC Control Approaches

 Mass-based 

 Limits on the amount of VOCs 

 Provisions for low vapor pressure VOCs (LVPVOCs)

 Reactivity-based 

 Limits on the types of VOCs

 VOCs have varying abilities to react to form 

ozone
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Low Vapor Pressure-VOCs 

(LVP-VOC)

 Slower evaporating, larger VOC compounds 

 Exempt from compliance with VOC 

standards

 Some may be more volatile and contribute 

to ozone formation

 ARB funded research is underway to 

investigate air quality impacts

 Data will be used to assess whether the LVPVOC exemption should be modified
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Reactivity Considerations

 Reactivity of VOCs quantified and 

compared using the Maximum Incremental 

Reactivity (MIR) scale 

 Proposed amendments to the Aerosol 

Coating Products Regulation

 
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 3% VOC limits for Multi-purpose Solvent 

and Paint Thinner products take effect on 

12/31/2013

 Technical assessment indicates 3% VOC

limit is feasible and can be implemented as 

scheduled 

 Will achieve ~4 tons per day reduction as 

expected 

Assessment of Upcoming Limits
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District Authority

 Districts authorized to adopt consumer product 

standards if ARB has not regulated category 

 District rule remains in effect if it predates ARB 

action

 Only South Coast Air Quality Management 

District (SCAQMD) has exercised this authority

 Regulates few categories

 All but a few categories are regulated on a 

consistent statewide basis
Program Success

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Control Measure Categories

Regulated

Emissions

Reductions Achieved

VOC limits ~130 ~220 tons per day 

Toxic Air

Contaminants* 83 Over 13 tons per day

Greenhouse gases 10

~0.23 million metric

tons of carbon dioxide

equivalents per year

*Methylene Chloride, Perchloroethylene, Trichloroethylene, Para-dichlorobenzene
Proposed Amendments to the 

Consumer Products 

Regulations and ARB Test 

Method 310

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Overview of Proposal

 “General” Consumer Products Regulation

 Antiperspirants and Deodorants 

Regulation 

 Aerosol Coating Products Regulation

 Hairspray Credit Program sunset 

 ARB Laboratory Test Method 310

 Tables of Reactivity (MIR) Values 

 Proposed Modifications 

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“General” Consumer Products 

Regulation

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Consumer Products Amendments

 Lower limits for Aerosol Adhesives 

 Multi-purpose Solvent and Paint Thinner 

Requirements

 Address SCAQMD issues 

 Include aerosols

 Additional proposals

 Update definitions

 Achieves additional 0.4 tons per day VOC 

emission reduction
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 Lower or new VOC limits for three Aerosol 

Adhesive categories

 Prohibit use of three toxic air contaminants

 Limit the types of greenhouse gases used

Aerosol Adhesives Requirements
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Multi-purpose Solvent (MPS) and 

Paint Thinner (PT) Rule Issues

 SCAQMD Rule 1143 in 2009

 ARB Regulation in 2010

 Amendments are being proposed to fully 

achieve expected benefits of these rules
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 Introduction of aerosol forms

 Proliferation of Industrial Maintenance 

Coating Thinners

 Products relabeling to avoid compliance 

with district’s rule

Why Rule Benefits Are Not Fully 

Achieved Now
Label Demonstrates Problem

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A-Z Supplies 

BranD

Odorless

Mineral 

Spirits

Warning:

Instructions

:

Cleanup:

100% From 

Nature:

Front Panel
Label Demonstrates Problem

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A-Z Supplies 

BranD

Odorless

Mineral 

Spirits

Category:

General Purpose 

Degreaser

Warning:

Instructions:

Cleanup:

100% From Nature:

A-Z Supplies Brand 

Odorless Mineral 

Spirits, Great for 

thinning, cleaning, 

stripping, window 

cleaning, Degreasing, 

dissolving gunk, etc. 

Back Panel
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 Specify VOC limits for nonaerosol products 

sold in SCAQMD 

 Set new VOC limits for aerosol products

 Strengthen exemption criteria for Industrial 

Maintenance Coating Thinners

 Extend safety labeling provisions

 Specify that VOC limits for nonaerosol

products apply prior to recommended 

dilution

MPS and PT Proposals 
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 Set new 10% by weight VOC limit, effective 

1/1/2016 

 Prohibit use of three toxic air contaminants

 Limit the types of greenhouse gases used

 Set 1% by weight Aromatic Compound content 

limit

New Requirements for Aerosol 

MPS and PT Products
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 Regardless of claims made on the label, 

nonaerosol MPS or PT products must comply 

with district’s rule

 Establish 25 g/L VOC standard identical to 

SCAQMD’s VOC limit

 All provisions of State’s regulation apply in 

SCAQMD

 Allows district to fully achieve expected 

benefits

Requirements for MPS and PT 

Products Sold in SCAQMD
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 Fuels are not regulated under ARB’s 

consumer products regulation as long as 

they are prominently and predominantly 

labeled as ‘Fuel,’ and no other claims are 

made or implied that the fuel is suitable for 

use as another regulated consumer product 

category

Fuel Products
Label Distinguishes Fuels from 

Consumer Products

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Consumer Product Fuel
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 Request to exempt HFO-1234ze (Trans1,3,3,3-tetrafluoropropene) 

 Exclude from the VOC definition 

 Also exclude from the Antiperspirants and 

Deodorants Regulation

Changes to VOC Definition
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 Prohibit use of three toxic air contaminants in 

Single Purpose Cleaner and Single Purpose 

Degreaser

 Extend effective date for the 10% VOC limit 

for Multi-purpose Lubricant 

Additional Proposals
Aerosol Coating Products 

Regulation

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New Reactivity Limits

 New Reactivity Limits will reduce ozone 

forming potential of VOCs

 Definitions and administrative requirements

 Assignment of MIR values 

 Test methods and compliance verification
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Proposed Reactivity Limits

 New or lower Reactivity Limits for 16 

categories 

 These categories represent over 90% of 

aerosol coating products emissions 

 Reactivity Limits set for very small 

categories designed to ‘cap’ ozone forming 

potential
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Aerosol Coating Products: 

Emissions Benefits

 Equivalent VOC reduction of 3.7 tons per 

day statewide

 1.6 tons per day in SCAQMD 
Changes to ARB Laboratory 

Test Method 310

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Key Changes to ARB Laboratory 

Test Method 310

 Paint Thinner and Multi-purpose Solvent 

products sold in SCAQMD

 Add analytical testing procedures

 Designed to closely align with procedures 

currently used by the SCAQMD

 Aerosol Coating products

 Add Hydrocarbon Solvent(s) analysis procedures
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Impacts
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Environmental Impacts

 VOC reduction of ~4.0 tons per day

 Fully realize benefits from previously 

adopted provisions for Multi-purpose 

Solvent and Paint Thinner products

 Precludes use of certain toxics and types of 

greenhouse gases

 No significant adverse impacts identified
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Economic Impacts

 Average annual increased cost to the 

consumer is $0.10 to $1.60

 Cost-effectiveness is $1.82 per pound of 

VOC reduced which is comparable with 

other consumer products rulemakings

 Manufacturers’ cost is $5.3 million per year 

for 5 years
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Proposed Modifications

 Provide clarification on calculation of VOC 

content for Multi-purpose Solvent and Paint 

Thinner products sold in SCAQMD

 Correct errors in Test Method 310 language
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Recommendation

 Approve adoption of the proposed 

amendments to the Consumer Products 

Regulations and ARB Laboratory Test 

Method 310 with staff’s suggested 

modifications
ARB Agenda Item 13-8-3

Proposed Amendments to the 

Consumer Products Regulations