FAQ - 2023 Consumer and Commercial Products Survey
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Frequently Asked Questions
This is a compilation of the most frequently asked questions (FAQs) regarding the 2023 Consumer and Commercial Products Survey (2023 Survey). The questions are based on comments from stakeholder meetings, conference calls, and comments received in response to the public webinar conducted October 29, 2024. If you have questions not addressed here, please send an email with your questions to the 2023 Consumer Products Survey Help Box.
General Questions
# | Question | Answer |
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1 | Is this survey mandatory? What authority does CARB have to request detailed consumer product information? | Yes, the survey is mandatory. Title 17, California Code of Regulations, sections 94500-94528 collectively known as the Consumer Products Regulations, provides CARB the authority to require the reporting of this type of information as part of fulfilling CARB’s mandate to meet State and federal air quality standards. Specifically, language in section 94504(b) of the Regulation for Reducing Volatile Organic Compound Emissions from Antiperspirants and Deodorants, section 94513(a) of the Regulation for Reducing Emissions from Consumer Products, and section 94524(c) of the Regulation for Reducing Ozone Formed from Aerosol Coating Product Emissions provides for reporting detailed consumer product information. The Consumer Products Regulations can be found at Current Regulations | California Air Resources Board. |
2 | Who must complete the survey? | Each company, firm, or establishment (responsible party) listed on the label of a consumer or commercial product that was sold or supplied for use in California during Calendar Year 2023 and falls into a category listed on the 2023 Survey Category List must complete this survey. For more information on how to determine if your company is a responsible party, please contact the 2023 Consumer Products Survey Help Box. |
3 | Why are consumer products relevant to air quality? | Chemically formulated consumer products such as personal care products, household care products, and automotive care products are a significant source of Total Organic Gas (TOG) emissions. There are three classifications under TOG and based on regulatory distinctions of volatility and reactivity:
In combination the added VOC and LVP-VOC emissions are known as Reactive Organic Gas (ROG) emissions. Consumer products are the largest source category of VOC and LVP-VOC emissions in the South Coast and statewide. Through a series of atmospheric reactions, VOCs and LVP-VOCs combine with other compounds in the air to form ozone at ground level (commonly known as smog) and secondary organic aerosols. Regulating the VOC and LVP-VOC emissions from consumer products reduces the amount of smog and ozone-forming chemicals in the environment. CARB has been regulating consumer products for more than 30 years, resulting in VOC limits for nearly 140 consumer product categories, prioritizing categories with high VOC emissions and regulating their VOC content. Despite these existing regulations, consumer product emissions continue to increase as California’s population and associated consumer product usage continue to grow. Without regulatory intervention, consumer products will become the largest source of ozone forming emissions in the state. Although ozone attainment is not possible without significant NOx reductions, ozone modeling has shown thatreductions in these ROG emissions from consumer products remains an effective strategy for control of ozone in certain geographic areas of California, such as the South Coast and other highly populated areas of coastal California. Emission-rich upwind areas in the South Coast contribute to ozone formation further downwind and cause ozone concentrations above the health-based ambient air quality standards. Modeling also shows that for these upwind areas, the effectiveness of ROG reductions declines as ozone concentrations fall with continued NOx reductions. Ozone modeling indicates that much of the South Coast, and particularly its more densely populated western and central areas, will continue to benefit from ROG reductions in the post-2031 timeframe. Given that population tracks closely with consumer product use, further emissions reductions from consumer products would significantly contribute to ozone attainment progress in the South Coast. For more information, please visit Consumer Products Program | California Air Resources Board. |
4 | Has the California Air Resources Board (CARB) conducted surveys like this in the past? | Yes. For over 30 years, CARB has conducted surveys on consumer product categories to understand their VOC composition for use in regulatory updates and inventory tracking. Previous surveys were conducted in 1994/1995, 1997, 2001, 2003, 2006, and 2013/2014/2015. More targeted surveys for select groups of product categories have also been conducted for regulatory purposes. For more information regarding past surveys, please visit Consumer & Commercial Products Surveys | California Air Resources Board. |
5 | What is the timeframe for responsible parties to comply with the 2023 Survey? When is the survey due? | Under the Consumer Products Regulations, upon written notice from CARB, responsible parties must be given at least 90 days to complete the survey. In past surveys, the required time has been extended to 120 days. After working extensively with stakeholders, CARB staff is providing four months to complete the 2023 Survey. The survey began on December 3rd, 2024, and is due on April 8th, 2025. |
6 | What are the next steps in the survey process? | The next steps and timeline are:
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7 | What types of products must be reported? | This survey is intended to collect information about chemically formulated consumer and commercial products used by households and institutions (such as commercial, service, and governmental establishments), and also products used by industrial entities for the maintenance or operation of their facilities. Reportable under this survey are products sold or supplied for use in California during calendar year 2023. For a list of reportable product categories, see Survey Categories - 2023 Consumer and Commercial Products Survey | California Air Resources Board. The list contains product categories that are regulated in the current Consumer Products Regulations, but also product categories that are not regulated. |
8 | Should consumer products that do not contain VOCs be reported and why? | Yes, products that do not contain VOCs should be reported, as in past surveys. Products that do not contain VOCs, but contain lower vapor pressure VOCs, may be as reactive or more reactive than products that contain VOCs. Therefore, products that do not contain VOCs must be reported. |
9 | Will each product category be defined in the survey instructions? | All currently regulated product categories are already defined in the Consumer Products Regulations. For product categories not defined in the Consumer Products Regulations, the category names in the survey should be sufficient for Responsible Parties to choose the appropriate code. For the definitions of regulated product categories, please see Section 94501 of Article 1 and Section 94508 of Article 2 of the regulations found at Current Regulations | California Air Resources Board. |
Outreach and Technical Assistance
# | Question | Answer |
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10 | What outreach is CARB staff planning during this survey process? | During the 2023 Survey reporting period, CARB staff plans to have two additional webinars to answer questions about the CPRT and the survey reporting requirements. The registration links for the webinars will be available at Webinars & Materials - 2023 Consumer and Commercial Products Survey | California Air Resources Board. |
11 | Is CARB staff providing written guidance on how to fill out the survey? | Yes. In addition to this document, CARB staff has posted survey instructions that are applicable to all users. Included in the instructions are step-by-step instructions for each field in the CPRT, as well as appendices with lists of the product categories and chemical ingredients. |
12 | Will CARB staff be available to answer questions about filling out the survey? | Yes. CARB staff is committed to ensuring that the reporting requirements are clear and the process of submitting electronic data to CARB is secure and maintains confidentiality. Please send any questions to the 2023 Consumer Products Survey Help Box. CARB staff is actively monitoring this inbox and will respond to questions in a timely manner. |
Reporting Requirements
# | Question | Answer |
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13 | None of the consumer products that my company sold in 2023 fall into the scope of the 37 categories listed for the 2023 Survey. Do I need to provide a response to CARB indicating that I do not have any products to report? | If the Responsible Party did not offer for sale in California in 2023 any product in the scope of the categories listed on the 2023 Survey Categories webpage, or there were no sales of products in the 37 survey categories, no action, response, or communication with CARB is required from that Responsible Party. |
14 | Will grouping of ingredients be allowed? | Yes, all inorganic compounds are allowed to be aggregated and reported as a total except for several specific inorganic compounds such as water, nitrogen, carbon dioxide, and others that are specifically listed in the survey instructions. Additionally, all organic compounds that are not considered a VOC, exempt VOC, or specifically listed LVP-VOC are allowed to be aggregated and reported as a total. Products can also be grouped by fragrance if the difference in fragrance content between products is less than 0.5 percent by weight. See the survey instructions and Appendix D for more details. Both can be found at Consumer Products Reporting Tool - 2023 Consumer and Commercial Products Survey | California Air Resources Board |
15 | Are examples for how to group reported data provided? | Yes, the survey instructions provide examples for how to appropriately group reported data. This also includes examples for reporting multi-packs and kits. |
16 | What are the reporting requirements for fragrance compounds? Do they need to be specified? | The speciation of fragrance ingredients is not required in the 2023 survey. A focused fragrance survey was conducted as a supplement to the 2013-15 survey, fragrance speciation was deliberated with stakeholders and incorporated as part of the 2020 Consumer Products emissions inventory. The only information on fragrance required in this survey is the total content of fragrance expressed in percent by weight, the name of the fragrance, the assigned sales number from the fragrance supplier, and the contact information of the fragrance supplier. |
17 | What are the requirements for the label submission? | For purposes of reporting, a single representative product label for each product will need to be submitted. If products are allowed to be grouped, only one representative product label for each product will need to be submitted. The entire label must be submitted. For example, for a responsible party that has 50 UPCs that vary only in the type of fragrance used in the final product, only one of the 50 labels must be submitted. The one label is considered representative for the 50 grouped products. Additional details are listed in the survey instructions. |
18 | How can a responsible party decide whether a product belongs to one of the 2023 survey categories that does not have a regulatory definition? Should responsible parties make decisions on whether a product should be reported under a survey category without regulatory definitions by relying on the survey category name? | CARB’s Consumer Products Regulations specify VOC standards for a number of categories and subcategories. The regulations contain definitions for each regulated category and subcategory. CARB definitions typically begin with a sentence that defines the overall product category (i.e., "Product Category A means ...") and end with a clarification of what types of products the category does not include (i.e., "Product Category A does not include ..."). The regulations may also include additional definitions for types of products that are not included in order to clarify the boundaries of the product category. Therefore, non-regulated categories are sometimes defined by default as pre-emptions to regulated categories. VOC standards do not apply to these pre-empted categories. The Consumer Products program encompasses 451 Survey Categories. About 70% of these survey categories have not been regulated and do not have regulatory definitions. New regulatory definitions and new categories have been defined during the history of the Consumer Products Program. This typically occurs during CARB's rule development process when a manufacturer asserts that products within a particular subcategory have specialized uses that require a higher VOC level in order to work properly. If sufficient data is not available for staff to determine if these assertions are accurate, the subcategory may be excluded from a proposed VOC limit for a broader category until sufficient data is collected and staff can establish an appropriate VOC standard for the subcategory. If a subcategory is excluded from a regulatory category in CARB's Consumer Products Regulations, that does not mean that CARB has determined that VOC standards are not appropriate for the subcategory, and CARB may set a VOC standard for the excluded category at a later date. Some products do not fall within the definitions specified for any of the product categories regulated by CARB or identified through definitions as exclusions from the regulated categories but are defined only as survey categories. Survey category names do not provide the clear distinctions found in regulatory definitions. Responsible Parties are encouraged to use their expert opinions in deciding whether their products fall within the scope of the 2023 Survey Categories that are not covered by regulatory definitions and exclusions. Responsible Parties are encouraged to report products even when they are uncertain if the product belongs in a 2023 Survey Category. CARB staff will conduct QA/QC of reported data, review submitted product labels, determine correct reported product categorization, and will remove or recategorize any miscategorized products. CARB staff will publish data summaries of tabulated Company Names and Products for all 2023 Survey Categories for stakeholder review and feedback. |
19 | If a company manufactures products with a net content by count printed on the label (i.e., number of facial cleansing cloths, dryer sheets, or disinfecting wipes) instead of milliliters or grams, what should be entered in the “Container Fill” column? | For such products, in the “Container Fill” data field, report only the mass or volume of liquid (or other substance) in the impregnated substrate (i.e., impregnated wipes/towels/cloths/sheets/pads). In the “Size on Label” data field, report the mass or volume that is listed on the label. The “Container Fill” data field is used to calculate emissions. The “Size on Label” data field is used for label review and will not be used to calculate emissions. Mass or volume should be reported even if count is printed on the product’s label. |
20 | Why is my formula not adding up to 100%, even though it should? | When entering the weight percent for an ingredient in a product’s formulation, only enter the numeric value; do not include the “%” symbol. If the "%" symbol is entered in your CPRT, you will need to redownload the tool and re-enter the data. |
Data Submission and Consumer Products Reporting Tool
# | Question | Answer |
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21 | How is the electronic submission expected to work? | The CPRT was developed to facilitate the submittal of product information electronically. The process will consist of three basic steps: data collection and entry; data processing and checking, and data submittal. All requested information will need to be interactively entered into the CPRT or imported into the CPRT from company databases. Automated data checks will simplify the reported data quality assurance/quality control process. Then, the comma separated values (CSV) files will be transmitted to CARB electronically and securely via Kiteworks. Detailed instructions for the CPRT can be found in the survey instructions. |
22 | How does CARB plan to ensure data confidentiality? | CARB staff understands the concerns associated with submitting confidential business information to a third party. The data will be submitted through the Kiteworks secure file transfer application. Once the data is received by CARB, the files will be encrypted as the data is entered into the database. All CARB staff members that view or manipulate the data are required to fill out a confidentiality agreement. Individual survey data (product sales & formulation, etc.) are not subject to a freedom of information act (FOIA) request. Treatment of Confidential Information by CARB |
23 | How do formulators submit their ingredient information to CARB? | In addition to the CPRT, CARB staff has developed the Consumer Products Reporting Tool for Formulators (CPRTF). When the responsible party has completed entering their data into the CPRT, they will have the ability to export csv files to send to CARB. Their submission will contain the formulator-specific products they make plus the formula name corresponding to each product. The responsible party will submit the csv files to CARB and then CARB will generate individual CPRTF files to each formulator. The formulator will be able to fill out the required information in the CPRTF, export their data into a CSV, and then submit the files directly to CARB through a secure and encrypted mailbox called Kiteworks. For more information on the details of this process, please see the survey instructions or watch CPRTF Module 1: Getting Started. |
If you have any questions about the material posted or have general questions regarding the Consumer Products Program, please contact Moslem Hossein Mardi or the 2023 Consumer Products Survey Help Box.
Consumer Products Program - Consumer & Commercial Products Surveys