Consumer Products & Smog
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 in over 30 years, most Californians still live in areas where smog reaches unhealthy levels. Reducing air pollution from cars and businesses hasn't been enough. To meet state and federal air quality standards, many small sources also need to pollute less. This includes consumer products. To achieve these goals, the California Air Resources Board (CARB) mandates limitations and/or restrictions on certain types of chemicals that cause pollution and have harmful health effects in consumer products. 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 129 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 further action, consumer product reactive organic gas (ROG) emissions will grow to almost 300 tpd statewide by 2030, representing about 22 percent of statewide emissions.
The Law Requires Cleaner Products
State and Federal law require 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. Today, standards that reduce VOCs have been established for over 100 categories, but 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 March 7, 2017, CARB released the revised 2016 State Strategy for the State Implementation Plan (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 1-2 tpd by 2023 and by 4-5 tpd by 2031 in the South Coast, and by 8-10 tpd by 2031 Statewide.
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.
CARB is also committed to reducing exposure to toxic compounds used in consumer products. To that end, the use of the Toxic Air Contaminants (TAC) perchloroethylene (perc), methylene chloride (mecl), and trichloroethylene (tce), has been prohibited from use in the following categories because these compounds are potential carcinogens:
- Adhesive remover
- Aerosol adhesive
- Aerosol coating
- Automotive brake cleaner
- Carb/choke cleaner
- Contact adhesive
- Electrical cleaner
- Electronic cleaner
- Engine degreaser
- Footwear or leather care product
- General purpose degreaser - automotive
- General purpose degreaser - non-automotive
- Graffiti remover
- Multipurpose solvent and paint thinner
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.
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 include an alternate compliance option to provide flexibility for manufacturers in meeting the requirements of the 10 percent by weight VOC limit for 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.
Flexibility for Cost-Effective Solutions
Innovative Products Provision 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.
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 emissions average must be less than or equal to the emissions that would result had all the products met the standards.
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.