California Air Resources Board

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.

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:

1. Volatile Organic Compounds (VOCs) which are the most volatile organic compounds
2. Low vapor pressure volatile organic compounds (LVP-VOCs) are less volatile than VOCs, but not necessarily less reactive towards ozone formation, and
3. Exempt Volatile Organic Compounds (Exempt-VOCs) that have low reactivity and minimal contribution to ozone formation and therefore are exempted from the definition of VOC.

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.

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. 

The next steps and timeline are: 

• December 3, 2024: Official survey launch date

• December 5, 2024: Consumer Products Reporting Tool (CPRT) webinar. Presentation and recording available at Webinars & Materials

• January 14, 2025: Responsible Parties submit Product Formulator Contact Information to CARB

• April 8, 2025: Completed surveys are due to CARB

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.

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 

What are the reporting requirements for fragrance compounds?

Do they need to be specified?

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.

• Time - 10:00 AM PST
• This webinar was conducted via Zoom

• Full Webinar Announcement
• Non-Responding Companies List, Last Updated 8/19/2025
• Presentation
• Webinar Recording
• Survey Analysis Technical Articles
  • A Generalization of Sampling Without Replacement From a Finite Universe
  • Construction of Weights in Surveys: A Review

• Time - 9:00 AM PDT
• This webinar was conducted via Zoom

• Presentation
• Toxicity Ranking Methodology Recording

• Time - 9:00 AM PDT
• This webinar was conducted via Zoom

• Presentations:
  • Response and Updates to the October 29 Webinar Presentation
  • CPRT Presentation
• CPRT Resources
• 2023 Survey Consumer Products Reporting Tool Recording

• Time - 9:00 AM PDT
• This webinar was conducted via Zoom

• Presentation
• Proposed category list
• 2023 Survey Category Selection Recording

• 10115

• 10209

• 10210

• 20103

• 20104

• 20305

• 20311

• 20312

• 20313

• 20321

• 20326

• 20504

• 20513

• 20903

• 20919

• 21003

• 21012

• 21014

• 21018

• 21301

• 21303

• 21405

• 30101

• 30102

• 30201

• 30207

• 30404

• 30411

• 30602

• 30603

• 60203

• 60211

• 60213

• 60214

• 60216

• 60223

• 70117