Of 47 product categories identified for possible emissions reduction, 21 have been presented as part of public work group meetings aimed at reducing VOC emissions.

SAFEGUARDS | Consumer ProductsNO. 086/19

Shampoo

The California Air Resources Board (CARB) is required to regulate consumer products as part of the California Clean Air Act. As part of their responsibility, CARB must provide technologically and commercially feasible solutions to reduce volatile organic carbon (VOC) emissions from consumer products.

With the exceptions outlined in the regulation, a VOC is defined as any compound containing at least one atom of carbon. The current strategy requires additional VOC reductions to consumer products to achieve a goal of 1-2 tonnes per day (tpd) by 2023 in the South Coast region, as well as an 8-10 tpd reduction state-wide by 2031 (including 4-5 tpd reduction in the South Coast).

To identify promising consumer product categories for meaningful emission reductions, CARB conducted a survey consisting of 491 categories, 1400 company respondents, and more than 1 million consumer products. The survey identified 47 categories where VOC reductions may be possible. CARB has held Public Work Group Meetings to present the survey data and liaise with stakeholders on the possible impacts of additional limits on VOCs in consumer products.

The first 21 categories were presented during May and June 2019, and the current and proposed VOC limits are outlined below. Not all the product categories discussed are necessarily going to become the subject of new or additional regulation. Currently, CARB is encouraging stakeholders to take part in the public meetings or meet with them directly to discuss opportunities, challenges and/or regulatory approaches related to these product types.

In addition to discussion surrounding the potential impact on existing formulations if VOC limits are reduced, the subject of the fragrance, its definition and exemption status are also being discussed. To date, CARB has considered fragrance to be made up of 100% VOC and has advised they would continue to work with the industry to better understand the composition of fragrance mixtures. Additionally, as part of the upcoming rulemaking, a monoterpene guidance document intended to clarify the applicability of the fragrance exemption is being considered as it relates to general purpose cleaners and degreasers. The proposed guidance may either confirm that specified monoterpenes are not to be considered within the fragrance exemption, to reduce the fragrance exemption with an allowance for monoterpenes, to eliminate the fragrance exemption and slightly increase VOC limits, or to provide other guidance on this topic.

Consumer Product Category
 Current VOC Limit (%)
 Average Marketed Product
VOC (%) 		Potential VOC
Proposal (%) 		Anticipated tpd Reduction
Hair finishing spray
55
53.2
50
1.00
No rinse shampoo / dry conditioner
None
81.2
5-20
Not determined
Dye, permanent
None
4.31
5
Not determined
Laundry detergent
None
1.89
All Forms: 0.25-2.00 (possible 0.50% for solid, 1.00% for liquid)
1.09-3.77
Liquid fabric softener
None
2.45
1.50
1.00
Dish detergent/soap
None
1.19
0.50
0.61
Aerosol cooking spray
18
17
15
0.26
Air freshener
  • Single phase aerosol
30
9.80
5
Not determined
  • Double phase aerosol
20
19.02
5-15
0.46-1.38
  • Dual purpose/disinfectant
60
62.05
45-55
0.18-0.55
  • Liquid/pump spray
18
54.04
Review fragrance definition & exemption
Not determined
  • Solid/semisolid
3
2.71
0.5-2
0.05-0.31
Bathroom & tile cleaner (aerosol)
7
6.02
5-6
0.06-0.14
General purpose cleaner (non-aerosol)
0.5
1.20
Possible guidance document to clarify fragrance exemption & monoterpenes
Not determined
General purpose degreaser (non-aerosol)
0.5
1.19 (undiluted)
Low priority for consideration
Not determined
Glass cleaner (aerosol)
10
9.46
5-8
0.12-0.31
Aerosol sunscreen
None
63.27
40-75
0.06-1.39
Shampoo
None
0.66
0.2-1
0-0.65
Conditioner without styling claims
None
0.87
0.2-1
0.06-0.82
External analgesic
None
6.32
Low priority for consideration
Low potential for reduction
Topical antifungal
None
57.03
Low priority for consideration
Low potential for reduction

SGS is committed to providing information about development in regulations for consumer products as complimentary services. Through a global network of laboratories, SGS provides a wide range of services including physical/mechanical testing, analytical testing and consultancy work for technical and non-technical parameters applicable to a comprehensive range of consumer products. Please do not hesitate to contact us for further information.

Next step

CARB will continue to evaluate the remaining product categories to identify those with the most promise for VOC emissions reduction.

For enquiries, please contact:

Joseph Scognamiglio
Technical Manager
t: +1 973 461 7937

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