The California Air Resources Board Is Considering Further Reductions in Consumer Products’ VOC Content to Reduce California’s Emissions Under the California Clean Air Act – Update from Bick Law, LLP


Wed May 8th, On Environmental Law,
by Kimberly Bick

At its April 12, 2019 public workshop to initiate rulemaking to meet these emission reduction commitments, the California Air Resources Board (“CARB”) proposed to evaluate consumer product survey categories with more than 0.5 (“tpd”) VOC emissions as part of its rule development process. Toward this end, CARB conducted its most comprehensive consumer products survey, with 491 survey categories addressed to 1400 companies and covering over a million products in order to collect information to use in its evaluation of lower VOC limits in certain consumer product categories.

The 2016 State Strategy for the State Implementation Plan (“SIP”) required CARB to develop measures to reduce consumer product volatile organic compound (“VOC”) emissions by 1 – 2 tons per day tpd by 2023 and 4 – 5 tpd by 2031, respectively, in the South Coast Air Basin, and 8 -10 tpd by 2031 Statewide.  The current VOC percentage by weight limit for certain product categories in California is listed in the Table of Standards in the Regulation for Consumer Products, 17 CCR section 94509  (https://www.arb.ca.gov/consprod/regs/2019/article_2_final_2019.pdf).

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