Starting January 1, 2017 new requirements for various consumer product and aerosol coating categories will be effective.  The specific regulatory requirements are codified in Title 17, California Code of Regulations, Sections 94507-94517 (Regulation for Reducing Emissions from Consumer Products) and Sections 94520-94528 (Regulation for Reducing the Ozone Formed from Aerosol Coating Product Emissions).

The following product categories will be affected beginning January 1, 2017:

  • As set forth in sections 94509(a) and 94509 (n) of Article 1 – Regulation for Reducing Emissions from Consumer Products (Article 1), aerosol adhesives with GWP 150 or higher will be subject to VOC standards (percent VOC by weight).
  • As set forth in section 94509(m)(1) of Article 1, use of methylene chloride, perchloroethylene, and trichloroethylene is prohibited in aerosol adhesives used in screen printing, single purpose cleaner and single purpose degreaser.
  • Pursuant to Article 2 – Regulation for Reducing the Ozone Formed from Aerosol Coating

Product Emissions sections 94522(a), certain general coatings and specialty coating products will be subject to reactivity limits.  To help facilitate the transition period, both regulations provide "sell-through" provisions which allow for the sale or supply of noncomplying products for up to three years (i.e. up to January 1, 2020), provided that the products were manufactured prior to January 1, 2017.  For more information regarding the "sell-through" provisions and compliance with these regulations, click here or please contact Trinity Irvine office at (949) 567-9880.