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California Air Resources Board’s 2015 Data Reporting for the Consumer Products Program Begins

The California Air Resources Board 2015 reporting for the Consumer Products Program began on July 1, 2016 and ends on November 1, 2016. This is the third year of a three year reporting cycle and is mandatory for all “responsible parties” that sold consumer products in California during the 2015 calendar year.

Under the Consumer Products Program, ARB imposes requirements and limits on volatile organic compounds (VOCs), toxic air contaminants (TACs) and greenhouse gases (GHGs) in chemically formulated consumer products. According to ARB, “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 (PM2.5), the main ingredients in smog. Reducing VOC emissions from consumer products therefore plays an integral part in ARB’s effort to reduce smog in California.”

As part of the agency’s efforts, ARB requires “responsible parties” to provide data about the levels of VOCs and other chemicals in consumer products. ARB uses the data to revise existing limits and impose new ones. The term “responsible party” is broadly defined as the company, firm or establishment which is listed on the consumer product’s label. “Consumer product” is equally broad, and 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. Consumer products exempt from the data reporting requirements are found at http://www.arb.ca.gov/consprod/regact/2015surv/exemptcat05102015.pdf.

Ms. Grimaldi maintains a diverse environmental law practice focusing on chemical and product regulation and litigation defense. Her practice areas include Proposition 65, California's Safer Consumer Products Regulations, California's Rigid Plastic Packaging Container Act and the federal Toxic Substances Control Act. Ms. Grimaldi graduated from the University of California Hastings College of the Law magna cum laude and holds a Bachelor of Science Degree in Bacteriology from University of California, Davis. Prior to attending law school, she worked as a research assistant in laboratories at the University of California, San Francisco Cancer Research Institute and at the University of California, San Francisco School of Medicine.