California’s air pollution rules for consumer products—always a trap for the unwary out-of-state business— just got tougher. On November 18, 2010, the California Air Resources Board (“CARB”) adopted revisions to its Consumer Products Regulation for 11 categories of products, including general purpose cleaners and degreasers, glass cleaners, oven and grill cleaners, and insect sprays. Three categories of products, grill cleaners, special-purpose lubricants and spot removers used in industrial dry cleaning, are restricted for the first time. The regulations take effect on December 31, 2012 for some products, and on December 31, 2013 for others.

These new restrictions may come as a surprise to manufacturers, distributors and retailers, especially for those products regulated for the first time. The regulations are part of CARB’s efforts over the last 20 years to restrict air emissions from consumer products. To date, the agency has set limits for volatile organic compounds (“VOC”) for 127 consumer product categories. These new regulations are anticipated to reduce air emissions by seven tons per day. The adopted limits for all categories, when fully effective, are expected to reduce VOC emissions by about 225 tons per day, an overall 50 percent reduction as compared to 1990 levels.

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