Aerosol Products
Volatile Organic Compound (VOC) Content Limits & Maximum Incremental Reactivity (MIR) Limits
Introduction
This document summarizes the regulations in several states affecting the content limits of Volatile Organic Compounds (VOCs) and the Maximum Incremental Reactivity (MIR) limits for Aerosol Products. For a quick introduction on how to most easily interpret these pages, please see How to Use the VOC and MIR Rules.
Skip to regulations:
- California Air Resources Board (CARB)
- South Coast Air Quality Management District (SCAQMD)
- Massachusetts
- Texas
- Ozone Transport Commission (OTC) (NY, NJ)
- Lake Michigan Air Directors Consortium (LADCO) (MI, OH, IL, IN)
California Air Resources Board (CARB)
The most comprehensive regulations are issued by the California Air Resources Board (CARB) which has the responsibility for Consumer Products VOC regulations for the state of California. In 2013, CARB tightened regulations on the emissions of VOCs from Aerosols in the Consumer Products and Aerosol Coatings Rules. New tighter regulations go into effect on January 1, in 2015, 2016, and 2017. Many states and jurisdictions have simply adopted the CARB limits as they currently exist in late 2014, as described below.
Summary of the changes for Aerosols in California:
- Aerosols will be regulated by Maximum Incremental Reactivity (MIR) limits. Other Consumer Products will be regulated through VOC content limits.
- Effective 1/1/15, CARB will incorporate the provisions of Rule 1143 Consumer Paint Thinners and Multi-Purpose Solvents enacted by the South Coast Air Quality Management District (SCAQMD) into CARB’s own regulations. The VOC Content Limit will be 25 g/liter for thinners and solvents sold in SCAQMD. Elsewhere in the state, a limit of 3% VOC by weight will apply.
- (Previously SCAQMD Rule 1143 could be avoided by labelling a product to fall under CARB’s previously less restrictive rules. This change removes that loophole).
- Limits for Spray and Mist Adhesives are lowered as of 01/01/2017.
- MIR limits have both been lowered on 3 categories of Aerosols: General Coatings (1/1/17), Specialty Coatings (A) (1/1/17) and Specialty Coatings (B) (1/1/15).
- Aerosol Multi-purpose Solvent and Aerosol Paint Thinner have been defined and regulated with a VOC limit of 10% by weight as of 1/1/2016.
- Prohibitions on Aerosol Adhesives, Aerosol Multi-purpose Solvent and Aerosol Paint Thinners for chlorinated compounds Global Warming Potential Compounds have been added.
- More reporting requirements.
- Definitions have been added or changed to provide clarity.
Tables of VOC changes enacted by CARB:
Source: http://www.arb.ca.gov/regact/2013/cp2013/cp2013froconsumer.pdf
| California Air Resources Board (CARB) | VOC Limits: Section 94509 | ||
| Consumer Products Aerosol - Adhesive | Current Limit % by weight | New Limit % by weight | Effective Date |
| Mist Spray Adhesive | 65 | 30 | 1/1/2017 |
| Screen Printing Adhesive | 55 | 55 | 1/1/2017 |
| Web Spray Adhesive | 55 | 40 | 1/1/2017 |
| California Air Resources Board (CARB) | VOC Limits: Section 94509 | ||
| Consumer Products Aerosol - Solvent and Thinners | Current Limit % by weight | New Limit% by weight | Effective Date |
| Aerosol Multi-purpose Solvent | 30 | 10 | 1/1/2016 |
| Aerosol Paint Thinner | 30 | 10 | 1/1/2016 |
Definitions of different Aerosol Adhesive have been defined more precisely. Note: non-aerosol Multi-purpose Solvent and Paint Thinners have a VOC content limit of 25 g/liter effective 1/1/2015 for Consumer Products sold in SCAQMD. Elsewhere in the state of California, the limit is 3% VOC by weight.
Tables of VOC changes enacted by CARB:
California is taking the lead on introducing the Maximum Incremental Reactivity (MIR) value as a distinct methodology for regulating VOC emissions. Currently, only aerosols are regulated by MIR, however, MIR is expected to be applied to other solvent uses by CARB and the EPA in the near future.
Source: http://www.arb.ca.gov/regact/2013/cp2013/cp2013froaerosol.pdf
| California Air Resources Board (CARB) | MIR Limits: Section 94522 | ||
| Aerosol – General Coatings | Current Limit (g O3/ g Product) | New Limit (g O3/ g Product) | Effective Date |
| Clear Coating | 1.50 | 0.85 | 1/1/2017 |
| Flat Coating | 1.20 | 0.80 | 1/1/2017 |
| Fluorescent Coating | 1.75 | 1.30 | 1/1/2017 |
| Metallic Coating | 1.90 | 1.25 | 1/1/2017 |
| Nonflat Coating | 1.40 | 0.95 | 1/1/2017 |
| Primer | 1.20 | 0.70 | 1/1/2017 |
| California Air Resources Board (CARB) | MIR Limits: | ||
| Aerosol – Specialty Coatings (A) | Current Limit (g O3/ g Product) | New Limit (g O3/ g Product) | Effective Date |
| Auto Body Primer | 1.55 | 0.95 | 1/1/2017 |
| Exact Match Finish, Engine | 1.70 | 0.95 | 1/1/2017 |
| Exact Match Finish, Automotive | 1.50 | 0.95 | 1/1/2017 |
| Exact Match Finish, Industrial | 2.05 | 1.20 | 1/1/2017 |
| Ground Traffic/Marking Coating | 1.20 | 0.85 | 1/1/2017 |
| Electrical/Electronic/ Conformal | N/A | 2.00 | 1/1/2017 |
Definitions of different Aerosol Coatings Product have been defined more precisely.
| Coating+ | |||
| Flexible Coating++ | N/A | 0.08 | 1/1/2017 |
| Mold Release Coating+ | N/A | 1.10 | 1/1/2017 |
| Uniform Finish Coating++ | N/A | 1.30 | 1/1/2017 |
| Two Component Coating++ | N/A | 1.20 | 1/1/2017 |
+ Indicates previously exempt coating category
++ Indicates new coating category “Specialty Coating (B)” categories are small categories of coatings. In these categories staff has determined that reductions are not cost effective, and is proposing to “cap” the Ozone Forming Potential.
| California Air Resources Board (CARB) | MIR Limits: | ||
| Aerosol – Specialty Coatings (B) | Current Limit (g O3/ g Product) | New Limit (g O3/ g Product) | Effective Date |
| Art Fixative or Sealant | 1.80 | 1.75 | 1/1/2015 |
| Automotive Bumper and Trim Product | 1.75 | 1.70 | 1/1/2015 |
| Aviation or Marine Primer | 2.00 | 1.25 | 1/1/2015 |
| Aviation Propeller Coating | 2.50 | 1.40 | 1/1/2015 |
| Corrosion Resistant Brass, Bronze, or Copper Coating | 1.80 | 1.80 | 1/1/2015 |
| Floral Coating | 1.70 | 0.85 | 1/1/2015 |
| Glass Coating | 1.40 | 1.35 | 1/1/2015 |
| High Temperature Coating | 1.85 | 1.85 | 1/1/2015 |
| Hobby/Model/Craft Coating:Enamel | 2.70 | 1.60 | 1/1/2015 |
| Lacquer | 1.45 | 1/1/2015 | |
| Clear or Metallic | 2.70 | 1/1/2015 | |
| Marine Spar Varnish | 1.60 | 1/1/2015 | |
| Photograph Coating | 0.90 | 0.90 | 1/1/2015 |
| Pleasure Craft Finish Primer/ Surfacer/ Undercoater | 1.00 | 0.75 | 1/1/2015 |
| Pleasure Craft Topcoat | 1.05 | 0.90 | 1/1/2015 |
| Polyolefin Adhesion Promoter | 0.60 | 0.60 | 1/1/2015 |
| Rust Converter | 2.50 | 2.50 | 1/1/2015 |
| Shellac Sealer: | 1.10 | 1/1/2015 | |
| Clear | 1.00 | 1.00 | 1/1/2015 |
| Pigmented | 1.00 | 1/1/2015 | |
| Slip-Resistant/Non-Slip Grip Coating | 2.45 | 2.10 | 1/1/2015 |
| Spatter/Multicolor/Stucco Coating | 1.05 | 1.05 | 1/1/2015 |
| Vinyl/Fabric/Leather/Plastic Coating | 1.55 | 1.45 | 1/1/2015 |
| Webbing/Veiling Coating | 0.85 | 0.75 | 1/1/2015 |
| Weld-Through Primer | 1.00 | 1.00 | 1/1/2015 |
| Wood Stain Coating | 1.40 | 0.90 | 1/1/2015 |
| Wood Touch-Up/Repair/Restoration Coating | 1.50 | 1.45 | 1/1/2015 |
CARB is diligent in enforcing its regulations. See CARB Enforcement.
Aerosol Regulations Enacted by Other Jurisdictions
South Coast Air Quality Management District (SCAQMD)
Typically, SCAQMD has the tightest and most comprehensive VOC regulations. However, since Aerosols are considered Consumer Products, they are regulated by CARB. SCAQMD has no additional regulations. However, SCAQMD Rule 1143 has been incorporated into CARB’s regulations but only for the SCAQMD area. Other jurisdictions adopt SCAQMD or CARB regulations by reference.
Here are Aerosol regulations promulgated by other jurisdictions:
Massachusetts
The VOC regulations are published in one long document, 310 CMR 7.00 Air Pollution Control Regulations. Note: these limits appear to be the same as the old limits issued by CARB. It is likely that Massachusetts will follow CARB and enact CARB’s new tougher limits. Source: Table 2. VOC Content Limits for Consumer Products Effective January 1, 2009, starting page 523.
| Consumer Product | VOC Content Limit (% by Weight) |
| Adhesives: | |
| Aerosol: Mist Spray | 65 |
| Aerosol : Web Spray | 55 |
| Special Purpose Spray Adhesives: | |
| Mounting; Automotive Engine Compartment; Flexible Vinyl | 70 |
| Polystyrene Foam and Automobile Headliner | 65 |
| Polyolefin and Laminate Repair/Edgebanding | 60 |
| Air Fresheners: | |
| Single-phase Aerosols | 30 |
| Double-phase Aerosols | 25 |
| Anti-Perspirants: | |
| Aerosol | 40 HVOC + |
| 10 MVOC ++ | |
| + HIGH VOLATILITY ORGANIC COMPOUND (HVOC) means any volatile organic compound that exerts a vapor pressure greater than 80 millimeters of mercury when measured at 20 oC. | |
| ++ MEDIUM VOLATILITY ORGANIC COMPOUND (MVOC) means any volatile organic compound that exerts a vapor pressure greater than two millimeters of mercury and less than or equal to 80 millimeters of mercury when measured at 20 oC. | |
| Bathroom and Tile Cleaners: Aerosol | 7 |
| Carpet and Upholstery Cleaners: Aerosols | 7 |
| Cooking Spray Aerosols | 18 |
| Deodorants Aerosol | 0 HVOC |
| 10 MVOC | |
| Dusting Aids Aerosols | 25 |
| Engine Degreasers Aerosols | 35 |
| Fabric Refreshers Aerosols | 15 |
| Footwear or Leather care Products Aerosols | 75 |
| Furniture Maintenance Products Aerosols | 17 |
| Graffiti Remover Aerosols | 50 |
| General Purpose Cleaners Aerosols | 10 |
| General Purpose Degreasers Aerosols | 50 |
| Hair Styling Products Aerosols and Pump Sprays | 6 |
| Insecticides: | |
| Crawling Bug Aerosols | 15 |
| Flying Bug Aerosols | 35 |
| Laundry Prewash Aerosols | 22 |
| Over Cleaners Aerosols and Pump Sprays | 8 |
| Rubber and Vinyl Protectants Aerosols | 10 |
| Spot Removers Aerosols | 25 |
| Toilets and Urinal Care Products Aerosols | 10 |
| Undercoating Aerosols | 40 |
| Wood Cleaner Aerosols | 17 |
Note: If a product meets more than one of the definitions specified in 310 CMR 7.25(12)(b) for Special Purpose Spray Adhesive, then the VOC limit for the product shall be the lowest applicable VOC limit specified in 310 CMR 7.25(12)(c)1.: Table 2.
Texas
Texas has promulgated a comprehensive set of VOC content limit regulations for many products and processes. Aerosols have not been separated for special regulations.
Ozone Transport Commission (OTC)
The OTC states: Connecticut, Delaware, the District of Columbia, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, and Virginia, have adopted CARB’s current Aerosol emission limits (see table above) in their OTC Model Rule for Consumer Products. (See page 24.) Michigan has also adopted CARB’s limits. The updated regulations which came into effect on January 1, 2014, retained the current, higher CARB limits. Each state also publishes their own regulations.
New York on January 1, 2010, adopted VOC content limits which include the current higher CARB limits for Aerosols.
New Jersey has promulgated VOC content limit regulations for many products and processes. Aerosols have not been separated for special regulations, so would use the OTC Model Rules that specify the current, higher CARB limits.
The Lake Michigan Air Directors Consortium (LADCO)
Indiana, Illinois, Michigan, Wisconsin and Ohio:
Michigan has adopted the OTC Model Rules which include the current higher CARB limits for Aerosols.
Ohio on December 6, 2012, adopted VOC content limits which include the current higher CARB limits for Aerosols.
Illinois, on July 1, 2012 adopted limits for Aerosols that are a compilation of the current higher CARB limits and the Michigan limits in sections 223.205, 223.208 and 223.211. There are special labelling requirements under section 223.265.
Indiana, on June 1, 2011, adopted VOC content limits which include the current higher CARB limits for Aerosols.
Summary Table
The Automotive Specialty Products Alliance (ASPA) published a summary table of VOC emission limits by product and jurisdiction on Jan 29, 2014. It nicely summarizes the data in this document into one comprehensive table, however, it does not include the new tougher limits adopted by CARB described above. Timeline: As many of the new General Coatings limits may be difficult to meet, manufacturers should start re-formulating with TBF environmentally-friendly solvents as soon as possible. The other categories are also time sensitive. To meet the January 1, 2017, deadline to meet the lower limits, manufacturers may wish to consider the following timetable:
| Q1 2017 | Compliance | ||||||||
| Q3 2016 | Sell / Rotate out old product | ||||||||
| Q1 2016 | Begin filling distributor and dealer inventory | ||||||||
| Full Rollout of New Products | |||||||||
| Q4 2015 | Test market new formulations | ||||||||
| Q3 2015 | Pilot production | ||||||||
| Q2 2015 | Test and iterate | ||||||||
| Q1 2015 | Research new formulations | ||||||||
| 2015 | 2016 | 2017 | |||||||
This schedule indicates that manufacturers should be experimenting NOW with new zero VOC or UltraLow VOC solvents manufactured by TBF Environmental Technology to have compliant products on the shelves by January 1, 2017.