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California Air Resources Board to Initiate Rulemaking for Reducing Emissions from Consumer Products

In February 2019, the California Air Resources Board (CARB) announced its intent to initiate rulemaking to further impose reductions in volatile organic compound (VOC) emissions from consumer products. The forum is scheduled to take place on Friday, April 12, 2019. The meeting is being held to convene stakeholders to discuss and plan emission reduction strategies. Some of the proposals to be evaluated at the upcoming forum include considering categories with higher mass and reactivity, exploring methods for developing near-zero VOC formulations, and analyzing exemptions currently in place.

CARB has engaged in rulemaking with the goal of lowering emissions and reactivity in over 120 categories of consumer products. The regulations imposed by CARB since 1989 have led manufacturers to implement various initiatives to lower concentrations of smog-causing substances and air toxic emissions emanating from consumer products.  The regulations have resulted in reducing VOC emissions by almost 50 percent. 

Despite the success of these regulations in reducing toxic emissions, the state has announced that additional action must be taken to conform to federal air quality standards that may be implemented in the future. To that end, CARB has collected survey data including product sales, chemical composition, and reactivity data. This information has been used, and will continue to be used, by CARB to develop effective and comprehensive policies to reduce emission outputs and meet overall air quality goals.

CARB’s Draft 2013, 2014 and 2015 Survey Data Highlights provides a summary of chemical formulation and emissions for over 400 categories of consumer products over a three year period.  Approximately 150 manufacturers and formulators took part in this survey, which provided relevant information regarding over 300,000 products sold in the state of California. CARB also published a list of the Top 25 consumer product categories across 4 major criteria including product sales, VOC emissions, Total Organic Gas Emissions, and Ozone Forming Potential.  

California has four consumer product regulations in effect.  The first regulation (Article 1) pertains only to antiperspirants and deodorants. The second regulation (Article 2), also known as the “General Consumer Products Regulation” applies to a variety of categories and is the subject of this proposed rulemaking.  Article 3 applies to categories of aerosol coatings. Finally, Article 4 pertains to voluntary emissions for consumer products.

Grimaldi Law Offices has been advising clients for over 20 years on chemical and product law. For knowledgeable advice and in-depth analysis on your chemical regulatory compliance obligations, contact Grimaldi Law Offices at (415) 463-5186 or email us at [email protected].

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.