The California Air Resources Board (CARB) continues its efforts to reduce air pollutants from consumer products through amendments to California’s Consumer Products Regulation. Proposed amendments would further lower current volatile organic compounds (VOC) limits for certain consumer products.


The Consumer Product Regulation is an important part of CARB’s effort to reduce the amount of VOCs, toxic air contaminants (TACs), and greenhouse gases (GHGs) emitted when using chemically formulated consumer products. In this context, “consumer product” 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; but does not include other paint products, furniture coatings, or architectural coatings. Consumer product also refers to aerosol adhesives, including aerosol adhesives used for consumer, industrial, and commercial uses.

VOCs emitted into the air from consumer products and other sources (including motor vehicles and stationary sources) react with other pollutants under sunlight to form the main ingredients in smog. Reducing VOC emissions from consumer products by setting VOC limits for numerous categories of consumer products therefore plays an integral part in CARB’s effort to reduce smog in California.

CARB is in the process of amending the Consumer Product Regulation to address the following areas:

  • Tougher restrictions on the six categories of consumer products with the most potential for VOC reduction – personal fragrance products, hair finishing spray, dry shampoo, aerosol air freshener, crawling bug insecticide, and charcoal lighter material;
  • Possible VOC standards for hair shine and temporary hair color;
  • Sunsetting the Consumer Product Regulation’s two-percent fragrance exemption; and
  • Other strategies to improve the consumer product program’s transparency, effectiveness, and enforceability.

Impacts on retailers

As merely a middleman between manufacturers / distributors and the ultimate consumers of the products, retailers are at greater risk of violating the Consumer Product Regulation and facing large penalties through enforcement actions, since they are not in the best position to know the contents of the products they are buying. However, they are in a position to take some level of precautions. Over the past two years, CARB assessed fines from well-known retailers totaling $325,270 for the following types of violations:

  • Selling products labeled “not for sale in California;”
  • Selling private label products that failed to meet the regulations standards; and
  • Importing and selling noncompliant products.

Expanding the regulation will likely increase costs for manufactures due to product reformulations, and put further pressure on retailers to ensure they are selling compliant products.