California Air Resources Board

This website does not supplant, replace or amend any of the legal requirements of the Consumer Products Regulations. Conversely, this website’s omission or truncation of regulatory requirements does not relieve responsible parties of their legal obligation to fully comply with all requirements of the regulation.

Article 3: Regulation for Reducing Ozone Formed from Aerosol Coating Product Emissions (Aerosol Coating Product Regulation)

Link to Article 3

Who is applicable to the Aerosol Coating Product Regulation?

“This article shall apply to any person who sells, supplies, offers for sale, applies, or manufactures any aerosol coating products for use in the State of California, except as provided in section 94523. This means that any aerosol coating product sold, supplied, offered for sale, applied, or manufactured for sale in California must comply with the provisions of this article unless specifically exempted as set forth in section 94523.”

California Code of Regulations, title 17, section 94520 Applicability
(Cal. Code Regs., tit.17, § 94520)

What is an Aerosol Coating Product?

“’Aerosol Coating Product’ means a pressurized coating product containing ‘Pigment’ or ‘Resin’ that dispenses product ingredients by means of a propellant, and is packaged in a disposable aerosol container for hand-held application, or for use in specialized equipment for ground traffic/marking applications. An ‘Aerosol Coating Product’ may include other ‘Coating Solid’ ingredients. ‘Aerosol Coating Product’ does not include products subject to the Consumer Products Regulation, sections 94507-94517 or the Antiperspirants and Deodorants Regulation, sections 94500-94506.5.”

Ref: Cal. Code Regs., tit.17, § 94521(a)(2) Aerosol Coating Product

What is Reactive Organic Compound?

“’Reactive Organic Compound (ROC)’ means any compound containing at least one atom of carbon and that has the potential, once emitted, to contribute to ozone formation in the troposphere.”

Ref: Cal. Code Regs., tit.17, § 94521(a)(67) Reactive Organic Compound

What is Maximum Incremental Reactivity?

“’Maximum Incremental Reactivity’ (MIR) means the maximum change in weight of ozone formed by adding a compound to the ‘Base ROG Mixture’ per weight of compound added, expressed to hundredths of a gram (g O₃/g ROC).” MIR values for individual compounds and hydrocarbon solvents are specified in sections 94700 and 94701, Title 17, California Code of Regulations.

Ref: Cal. Code Regs., tit. 17 § 94521(a)(49) Maximum Incremental Reactivity

What is Product-Weighted MIR (PWMIR)?

“’Product-Weighted MIR’ (PWMIR) means the sum of all weighted-MIR for all ingredients in an ‘Aerosol Coating Product.’ The PWMIR is the total product reactivity expressed to hundredths of a gram of ozone formed per gram of product (excluding container and packaging).” Please refer to Cal. Code Regs., tit. 17 § 94521(a)(64) for the equation utilized to calculate PWMIR.

Ref: Cal. Code Regs., tit. 17 § 94521(a)(64) Product-Weighted MIR

What is a Reactivity Limit?

“’Reactivity Limit’ means the maximum ozone forming potential of ingredients (excluding container and packaging) allowed in an ‘Aerosol Coating Product,’ expressed as the PWMIR.”

Which Aerosol Coating Product categories have an applicable to the reactivity limit?

As stated in Cal. Code Regs., tit. 17 § 94522(a) Reactivity Limits, except as provided in section 94523, any ‘Aerosol Coating Product’ shall comply with the applicable General Coating limit specified in section 94522(a)(2) unless the ‘Aerosol Coating Product’ meets all the requirements for the applicable Specialty Coating that is defined in section 94521. In such cases the Specialty Coating product shall comply with the applicable Specialty Coating limit specified in section 94522(a)(2).

Ref: Cal. Code Regs., tit. 17 § 94521(a)(66) Reactivity Limit

What is a General Coating?

“’General Coating’ means the following aerosol coating products: ‘Clear Coating,’ ‘Flat Coating,’ ‘Fluorescent Coating,’ ‘Metallic Coating,’ ‘Nonflat Coating,’ or ‘Primer.’” Definitions of each category listed previously are listed in Cal. Code Regs., tit. 17 § 94521(a).

Ref: Cal. Code Regs., tit. 17 § 94521(a)(35) General Coatings

What is a Specialty Coating?

“’Specialty Coating’ means any ‘Aerosol Coating Product’ that is not a ‘General Coating’ unless specifically exempted as specified in section 94523. An aerosol coating that does not meet all the criteria for a specific ‘Specialty Coating’ or an aerosol coating that is not defined in this section 94521(a) is a ‘General Coating.’” Definitions of each category listed previously are listed in Cal. Code Regs., tit. 17 § 94521(a).

Ref: Cal. Code Regs., tit. 17 § 94521(a)(73) Specialty Coatings

Where can I find the Reactivity Limit associated with each category in the Aerosol Coating Products Regulation?

The Reactivity Limit for each applicable category is listed in Cal. Code Regs., tit. 17 § 94521(a) Reactivity Limits.

Where can I find MIR values corresponding to chemical compounds?

A table of MIR Values can be found in Cal. Code Regs., tit. 17 § 94700 MIR Values for compounds. MIR values for hydrocarbon solvents can be found in Cal. Code Regs., tit. 17 § 94701 MIR for Hydrocarbon Solvents.

Are there product dating requirements in the Aerosol Coating Products Regulation?

Yes, aerosol coating products subject to section 94522 is subject to the product dating requirements as stated in Cal. Code Regs., tit. 17 § 94524(b)(2). Additional information can be found on the Product Dating page.

Ref: Cal. Code Regs., tit.17, § 94524 Administrative Requirements

Are there other labeling requirements in the Aerosol Coating Products Regulation?

“(1) Each manufacturer of an ‘Aerosol Coating Product’ subject to this article shall clearly display the following information on each product container which is manufactured on or after the earliest effective date for the applicable Reactivity limit for an aerosol coating.

(A) the applicable Reactivity Limit for the product that is specified in section 94522(a); and

(B) the aerosol coating category as defined in section 94521, or an abbreviation of the coating category."

For the other requirements see the Aerosol Coating Products Regulation.

Ref: Cal. Code Regs., tit.17, § 94524 Administrative Requirements

Are there any compounds prohibited in Aerosol Coating Products?

There are prohibitions of methylene chloride, perchloroethylene, trichloroethylene, and ozone depleting substances for “Aerosol Coating Products.” Additional information can be found in Cal. Code Regs., tit. 17 § 94522(e)-(f).

What are Architectural Coatings?

Architectural Coatings are products that are applied to stationary structures and their accessories. They include house paints, stains, industrial maintenance coatings, traffic coatings, and many other products. Additional information about architectural coatings can be found at CARB’s Coatings website.

Where can I learn more about CARB’s Suggested Control Measure (SCM) for architectural coatings?

The Suggested Control Measure (SCM) is a model rule developed by CARB that local air districts can adopt for their architectural coatings rules. The SCM was last updated in 2020. Additional information can be found at CARB’s SCM website.

Where can I learn more about local air district rules for coating and solvents?

A list of local air districts and the applicable coating rules can be found in the Coating Rules in California website. For additional information or questions, please contact helpline@arb.ca.gov or call at 800-242-4450.