California Air Resources Board

The Consumer Products Regulatory Program is an important part of the overall effort to reduce the amount of volatile organic compounds (VOCs), toxic air contaminants (TACs), and greenhouse gases (GHGs) that are emitted from using chemically formulated consumer products.

"Consumer product" means a chemically formulated product used by household and institutional consumers including, but not limited to, detergents; cleaning compounds; polishes; floor finishes; cosmetics; personal care products; home, lawn, and garden products; disinfectants; sanitizers; aerosol paints; and automotive specialty products; but does not include other paint products, furniture coatings, or architectural coatings. "Consumer product" shall also refer to aerosol adhesives, including aerosol adhesives used for consumer, industrial, and commercial uses. 

VOCs that are emitted into the air from consumer products and other sources (motor vehicles, stationary sources, etc.) react with other pollutants under sunlight to form ground-level ozone and particulate matter (PM_2.5), the main ingredients in smog. Reducing VOC emissions from consumer products therefore plays an integral part in CARB's effort to reduce smog in California.

Most Californians Still Breathe Polluted Air

Ozone, the main ingredient of smog, continues to threaten the health of many Californians. Although the state's air is the cleanest it has been in over 30 years, most Californians still live in areas where smog reaches unhealthy levels. Reducing air pollution from cars and businesses has not been enough to meet state and federal air quality standards. Smaller ozone sources also need to pollute less, including consumer products. To achieve these standards, the California Air Resources Board (CARB) mandates limitations and/or restrictions on certain types of chemicals in consumer products that have harmful health effects and cause pollution. This information is published in The California Consumer Products Regulations.

Consumer Product Pollution Adds Up

Deodorants, hair spray, cleaning products, spray paint, and insecticides are examples of common consumer products that are made with ozone-forming chemicals known as volatile organic compounds (VOCs). Although each product only contains a small amount of VOCs, Californians use over half a billion of these items every year. VOCs are an important precursor, or component in the formation of ground level ozone, a major part of California's smog problem. By regulating the amount of VOCs in consumer products, CARB is helping to reduce smog and reduce public exposure to the hazards associated with smog.

For more than thirty years, CARB has taken actions pertaining to the regulation of consumer products. Three regulations have set VOC limits for over 130 consumer product categories. These three regulations have reduced VOC emissions by about 50 percent between 1990 and 2020 relative to uncontrolled levels. 

Despite these existing regulations, consumer product emissions have increased over the past several years as California’s population and associated consumer product usage continue to grow. Without continued attention, consumer product reactive organic gas (ROG) emissions will grow to over 300 tpd statewide by 2040, representing more than 20 percent of statewide emissions.

The Law Requires Cleaner Products

State and Federal law requires that consumer products pollute less. To achieve this, CARB works with industry and other stakeholders to develop requirements that achieve the maximum feasible VOC emission reduction while making sure that the regulations are technologically and commercially feasible and do not eliminate a product form.

• Opinion of the Attorney General on Product Form

Further reductions are still needed. The South Coast Air Basin continues to face the biggest challenge in attaining ozone standards in the nation. In 1990, the entire South Coast region violated the current 8-hour ozone standard of 0.070 ppm for over 180 days with concentrations as high as 0.186 ppm. As of 2019, ozone concentrations in the South Coast have declined 42 percent, and 32 percent of the population there now lives in communities that meet the standard. Nonetheless, South Coast still has the highest ozone levels in the nation.

On September 22, 2022, CARB approved the 2022 State Strategy for the State Implementation Plan (2022 State SIP Strategy), describing the proposed commitment to achieve the reductions necessary from several sources, including consumer products, to meet federal ozone standards over the next 15 years. The State SIP Strategy proposes a suite of regulatory and incentive programs, referred to as State SIP measures, which, in combination with local actions, are designed to achieve the required emission reductions to meet federal air quality standards. The State SIP Strategy requires CARB to develop measures to reduce VOC emissions from consumer products by 20 tpd Statewide and 8 tpd in the South Coast by the year 2037.

Commercial and Technological Feasibility

The California Clean Air Act requires that CARB assures that each new consumer product regulation is commercially and technologically feasible and does not eliminate a product form. To evaluate feasibility, the Consumer Products Program staff conducts surveys to be completed by manufacturers that sell products in California. The purpose of these surveys is to gather current information on VOC emissions from consumer and commercial product categories. This information allows us to determine the feasibility of further reducing consumer product emissions and is used to update our consumer products emission inventory.

Toxics

CARB is also committed to reducing exposure to toxic compounds used in consumer products. To that end, the use of the Toxic Air Contaminants perchloroethylene (perc), methylene chloride, and trichloroethylene, has been prohibited from use in the following categories because these compounds are potential carcinogens:

• Adhesive remover
• Aerosol adhesive
• Aerosol coating
• Air Freshener
• Automotive brake cleaner
• Bathroom and Tile Cleaner
• Carpet/Upholstery Cleaner
• Carb/choke cleaner
• Construction, Panel or Floor Covering Adhesive
• Contact adhesive
• Crawling Bug Insecticide
• Electrical cleaner
• Electronic cleaner
• Electronic Cleaner labeled as energized electronic
• Engine degreaser
• Fabric Protectant
• Footwear or leather care product
• General purpose degreaser - automotive
• General purpose degreaser - non-automotive
• Graffiti remover
• Hair Care Products
• Lubricant
• Metal Polish or Cleanser
• Multipurpose solvent
• Oven or Grill Cleaner
• Paint thinner
• Personal Fragrance Products
• Pressurized Gas Duster
• Sealant or Caulking Compound
• Single Purpose Cleaner
• Single Purpose Degreaser
• Spot Remover

CARB has also approved an Air Toxics Control Measure (ATCM) that prohibits the use of the potential human carcinogen para-dichlorobenzene (PDCB), which has been used in air fresheners and in toilet/urinal deodorant blocks.

• Article 2 of the Consumer Products Regulations

Reactivity

Reactivity is the ozone-forming potential of a particular VOC. Reactivity limits were developed for aerosol coatings based on the maximum incremental reactivity (MIR) scale. This approach increases flexibility for the regulated industries. CARB is continuing to evaluate development of more reactivity limits for other categories on a case-by-case basis. However, achieving mass-based VOC reductions will continue to be our primary approach.

In May 2018, CARB adopted the Proposed Amendments to the Consumer Products Regulation and Method 310.  These Amendments included an alternate compliance option to provide flexibility for manufacturers in meeting the requirements of the 10 percent by weight VOC limit for multi-purpose lubricants (MPL) products. The alternate compliance option would allow manufacturers to comply by meeting a 25 percent by weight VOC limit and a reactivity limit of 0.45 grams of ozone per gram of product.

Greenhouse Gas Prohibitions

Various consumer products may contain GHGs in their formulations. Products containing high GWP GHGs include pressurized containers that utilize nitrous oxide (N₂O) including aerosol cheese and dessert toppings, as well as hydrofluorocarbon (HFC) propellant products such as boat horns, pressurized gas dusters, and tire inflators.

The Consumer Products Program has enacted prohibitions on compounds with high Global Warming Potential (GWP) in several categories. These prohibitions ensure that any product reformulation strategies employed by product manufacturers in response to lower VOC standards do not use high GWP compounds that are otherwise VOC exempt. The use of compounds with a GWP of 150 or greater is prohibited, including in the following categories:

• Aerosol adhesive
• Air Freshener
• Crawling Bug Insecticide
• Flying Bug Insecticide
• Furniture Maintenance Product
• Hair Care Products
• Lubricant
• Metal Polish or Cleanser
• Multi-purpose Solvent
• Paint Thinner
• Personal Fragrance Product
• Pressurized Gas Duster
• Spot Remover
• Wasp or Hornet Insecticide

Flexibility for Cost-Effective Solutions

Innovative Products Provision

Innovative Products Provision (IPE) allows manufacturers to exceed performance standard VOC limits if they can demonstrate alternative ways of lowering emissions. For instance, increasing the amount of "active ingredients" and changing the dispenser can lower the amount of VOC emitted per application.

In addition, the provision allows for Hair Finishing Spray, Dry Shampoo, and aerosol Personal Fragrance Products to be formulated with compressed gas propellants, or other liquified propellants, as long as they reduce greenhouse gas emissions by at least 50 percent with no increase in ozone formation as compared to their representative product.

Visit our IPE page for more information.

Alternative Control Plan

Alternative Control Plan allows manufacturers to average, or "bubble," their emissions from noncomplying products with those from products that more than meet the standard. The resulting total emissions must be less than or equal to the emissions that would result had all the products met the standards.

Variances

Variances provide temporary relief from the VOC limits in the consumer product regulation. A company must demonstrate in a public hearing that they cannot comply for reasons beyond their control.