Consumer Products and Smog

This page last reviewed September 24, 2008

Most Californians Still Breathe Polluted Air

Ozone, the main ingredient of smog, continues to hreaten the health of many Californians. Although the state's air is the cleanest in over 30 years, most Californians still live in areas where smog reaches unhealthy levels. Reducing air pollution from cars and businesses hasn't been enough. To meet state and federal air quality standards, many small sources also need to pollute less. This includes consumer products.

Consumer Product Pollution Adds Up

Deodorants, hair spray, cleaning products, spray paint, and insecticides are examples of common consumer products that are made with ozone-forming chemicals known as volatile organic compounds or VOCs. Although each product only contains a small amount of VOCs, Californians use over half a billion of these items every year.

In 2005, consumer products account for about 245 tons per day (tpd) of VOC emissions, which is about 10 percent of the total VOC emissions statewide. If consumer products had never been regulated, we calculate emissions would have exceeded 400 tons per day by 2005. Thus, ARB's efforts have already resulted in projected emissions reductions of over 40%. Even though these significant reductions have been achieved, population growth will erode some of these reductions such that consumer product emissions are projected to increase unless more is done.

The Law Requires Cleaner Products

State and Federal law require that consumer products pollute less. To achieve this, California's Air Resources Board (ARB) works with industry and other stakeholders to develop requirements that achieve the maximum feasible VOC emission reduction while making sure that the regulations are technologically and commercially feasible and do not eliminate a product form. Today, standards that reduce VOCs have been established for over 100 categories, but further reductions are still needed.

On October 23, 2003, the ARB adopted the Proposed 2003 State and Federal Strategy for the California State Implementation Plan (Statewide Strategy), which reaffirms the ARB's commitment to achieve the health-based air quality standards through specific near-term actions and the development of additional longer-term strategies. It also sets into motion a concurrent initiative to identify longer-term solutions to achieve the full scope of emission reductions needed to meet federal air quality standards in the South Coast and San Joaquin Valley by 2010. These strategies address meeting the federal one-hour ozone standard.

On June 15, 2004, however, the new eight-hour ozone standards became effective, causing a transition from the one-hour ozone standard, 0.12 parts per million (ppm), to the more health-protective eight-hour ozone standard, 0.08 ppm (averaged over 8 hours). Strategies to meet this new standard will be due in 2007. ARB expects that California will need to reduce emissions beyond the existing commitments.

Reductions in the consumer products element of the Statewide Strategy are an essential part of California's effort to attain the air quality standards. To address this element, three measures were developed.

· Measure CONS-1: The ARB committed to develop a measure, to be implemented by 2006, that would achieve a VOC emission reduction from consumer products of at least 2.3 tpd in the South Coast Air Basin, and 5.3 tpd statewide, in 2010.
  • To fulfill this commitment, in June 2004, the Board approved amendments to the Consumer Products Regulation to satisfy Measure CONS-1. These amendments established VOC limits for 15 product categories that will achieve an estimated emission reduction of 6.0 tpd in California, including 2.8 in the South Coast, by December 31, 2006.
· Measure CONS-2: The ARB committed to develop a measure, to be implemented by 2008 and 2010, that would achieve VOC emission reductions from consumer products of 8.5 - 15 tpd in the South Coast Air Basin in 2010. Statewide, this measure would achieve 20 - 35 tpd in emission reductions in 2010. · Further Reductions from Consumer Products: In addition, it is expected that further emission reductions will be needed from all source categories, including consumer products, to meet the long-term emission reduction targets included in the South Coast SIP. More reductions will also be needed to satisfy the new 8-hour ozone standard. As such there is an ongoing commitment to pursue additional technologically and commercially feasible reductions in consumer product emissions.

Commercial and Technological Feasibility

The California Clean Air Act requires that the ARB assure that each new consumer product regulation is commercially and technologically feasible and does not eliminate a product form. To evaluate feasibility, the Consumer Products Program staff conducts surveys to be completed by manufacturers that sell products in California. The purpose of these surveys is to gather current information on VOC emissions from consumer and commercial product categories. This information allows us to determine the feasibility of further reducing consumer product emissions and is used to update our consumer products emission inventory.


The ARB is also committed to reducing exposure to toxic compounds used in consumer products. To that end, the use of the Toxic Air Contaminants (TAC) perchloroethylene (perc), methylene chloride (mecl), and trichloroethylene (tce), has been prohibited from use in the following categories because these compounds are potential carcinogens:

· Adhesive Removers - including subcategories (effective 12/31/06)
· Aerosol Adhesives
· Aerosol Coatings
· Automotive Brake Cleaners
· Carb/Choke Cleaners
· Contact Adhesives (effective 12/31/05)
· Electrical Cleaners (effective 12/31/06)
· Electronic Cleaners (effective 12/31/05)
· Engine Degreasers
· Footwear or Leather Care Products (effective 12/31/05)
· General Purpose Degreasers - automotive
· General Purpose Degreasers - non-automotive (effective 12/31/05)
· Graffiti Removers (effective 12/31/06)

ARB has also approved an Air Toxics Control Measure (ATCM) that prohibits the use of the potential human carcinogen para-dichlorobenzene (PDCB), which is used as air fresheners and in toilet/urinal deodorant blocks. An ATCM that eliminates the TACs, hexavalent chromium and cadmium, from automotive aerosol coatings has also been adopted.


Reactivity is the ozone-forming potential of a particular VOC. Reactivity limits were developed for aerosol coatings based on the maximum incremental reactivity (MIR) scale. This approach increases flexibility for the regulated industries. The ARB is continuing to evaluate development of more reactivity limits for other categories on a case-by-case basis. However, achieving mass-based VOC reductions will continue to be our primary approach.

Flexibility for Cost-Effective Solutions

The average cost of reducing pollution from consumer products is comparable to other VOC regulations-about 25 to 85 cents for every pound of VOC emissions prevented. California's consumer product regulations give manufacturers the flexibility to find the most cost-effective approach.

Performance Standards set allowable VOC content for a product category. Companies can choose how to modify their product formulas to reduce VOC content.
Innovative Products Provision allows manufacturers to exceed performance standard VOC limits if they can demonstrate alternative ways of lowering emissions. For instance, increasing the amount of "active ingredients" and changing the dispenser can lower the amount of VOC emitted per application.
Alternative Control Plan allows manufacturers to average, or "bubble," their emissions from noncomplying products with those from products that more than meet the standard. The resulting emissions average must be less than or equal to the emissions that would result had all the products met the standards.
Variances provide temporary relief from the VOC limits in the consumer product regulation. A company must demonstrate in a public hearing that they cannot comply for reasons beyond their control.

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