California Air Resources Board

Background 

Consumer products include chemically formulated products used by both household and commercial users, spanning a variety of categories such as cleaners/degreasers, lubricants, disinfectants, fabric softener-single use dryer products (dryer sheets), air fresheners, and various personal care items. Since 1989, the California Air Resources Board (CARB) has been mandated by the California Clean Air Act to regulate the volatile organic compounds (VOC) found in consumer products as part of its ground-level ozone reduction strategy. This regulatory initiative has led to the adoption of VOC content standards for over 100 categories of consumer products, resulting in a significant reduction of VOC emissions by 50% relative to uncontrolled levels. 

Composition of Consumer Products  

Consumer products are composed of various functional ingredients, including solvents, propellants, functional components, fragrance, and additives. CARB classifies each ingredient chemical into distinct categories such as VOC, low vapor pressure-VOCs (LVP-VOC), exempts, and inorganic compounds. Fragrance ingredients, which are typically VOC and LVP-VOC chemicals, are used solely to give a product odor or scent or to mask undesirable odors in product formulations. Fragrances can range from simple synthesized chemical compounds to complex mixtures derived from natural sources such as flowers, grasses, spices, fruits, wood, leaves, and animal secretions like musk and ambergris.

Use of Fragrance in Consumer Products  

Fragrance ingredients are common in consumer products and present across nearly every product category. Manufacturers typically add fragrance to offset undesirable odors from base ingredients or to enhance the overall scent of the product. Due to its cost, fragrance is often added sparingly to product formulations, with only enough added to achieve the desired effect on a user’s sense of smell. 

Health Effects of Fragrance Exposure  

Exposure to fragrance compounds in consumer products has been associated with health issues, including migraine headaches and respiratory difficulties, as reported by over 34% of surveyed respondents in the United States (Steinemann, 2016). Fragrance chemicals can lead to acute or chronic health effects. Studies indicate they are present in household dust, thereby posing a risk of secondary exposure through inhalation or ingestion, and are of particular concern for young children. Multiple chemical sensitivity, characterized by a range of acute and chronic symptoms, has been linked to exposure to fragrance chemicals in consumer products.

CARB's Efforts to Reduce Fragrance Emissions  

Over the past three decades, CARB has set VOC limits for numerous consumer product categories resulting in reduced fragrance use. For example, VOC limits on cleaning products capped the amount of monoterpenes (which have fragrance as well as solvency properties) in those products. Notably, the Two Percent Fragrance Exemption, which excluded up to two percent of fragrance from VOC content calculations, has also been eliminated for specified product categories. This regulatory change promotes transparency for fragrance ingredients, aligning with the California Fragrance and Flavor Right to Know Act (Senate Bill 574, 2019), which mandates disclosure of toxic fragrance ingredients in cosmetic products. 

Prior to eliminating the Two Percent Fragrance Exemption, fragrance VOC up to a combined level of two percent of the net weight of any consumer product was excluded from the calculation of the VOC content of a product. Fragrance formulation was often not disclosed to manufacturers, so all fragrance was considered VOC. By removing this exemption, fragrance formulators have an incentive to provide consumer product manufacturers with the VOC content of their fragrances resulting in greater transparency about product formulations. The Consumer Products Regulation also provided an exemption for air fresheners that were comprised entirely of fragrance and non-VOCs, and for fragrances that are used in “personal fragrance products.” In 2021, CARB approved amendments to the regulation that sunset these preferential treatments of fragrance ingredients in some consumer product categories including single use fabric softener dryer sheets. 

CARB also set new and lower VOC limits in 2021 for personal fragrance products (perfumes/colognes) and several types of “air freshener” products including automatic aerosol air fresheners, manual aerosol air fresheners, concentrated aerosol air fresheners, and total release aerosol air freshener products.

Federal Food and Drug Omnibus Reform Act of 2022  

In addition to CARB's initiatives, the Food and Drug Omnibus Reform Act of 2022 (FDORA) introduces significant updates to the regulatory framework for cosmetics in the United States. Under FDORA, the Modernization of Cosmetics Regulation Act of 2022 (MoCRA) mandates various requirements for cosmetic companies, including ingredient disclosure, adverse event reporting, and adherence to good manufacturing practices. MoCRA's emphasis on identifying allergens, particularly in fragrance, aligns with FDORA's overarching goal of enhancing product oversight and safeguarding consumer health. 

State and federal regulatory actions aim to increase transparency on fragrance use in consumer products while also enhancing safety standards and protecting public health.