Volatile Organic Compounds, commonly known as VOCs, can be emitted from certain solid and liquid products such as fuels and building materials. They can also be found in items commonly located in household cleaning products and paints. 

As VOCs may have an adverse effect on human health, the federal EPA regulates VOCs in aerosol coatings, architectural coatings, automobile refinish coatings and certain consumer products under the Clean Air Act (CAA). Additionally, some states have also regulated them to stricter standards.

WERCSmart has expanded states that require specific VOC data – identified as grams per Liter – for products that fall within Architectural Coating VOC regulation.

This article reviews:

1.   VOC regulated states for Architectural Coating products

2.    How WERCSmart collects and manages VOC data

3.    How it may impact your product registrations

VOC regulated states for Architectural Coating products

Current States that require collection of VOC data – indicated as grams per Liter (g/L)

In addition to the country of Canada, the following US States currently require the collection of VOC data:

•    California (CA)

•    Delaware (DE)

•    Maryland (MD)

Additional States that require collection of VOC data – indicated as grams per Liter (g/L)

•    Colorado (CO)

•    Connecticut (CT)

•    Indiana (IN)

•    Maine (ME)

•    Massachusetts (MA)

•    New Hampshire (NH)

•    New Jersey (NJ)

•    New York (NY)

•    Pennsylvania (PA)

•    Rhode Island (RI)

•    Utah (UT)

•    Virginia (VA)


How WERCSmart collects and manages VOC data

Based upon your type of registered product, WERCSmart collects VOC data in units of:

•    grams per Liter (g/L) – as in the case of architectural coating products,

•    percentages (%), or

•    grams Ozone per gram product (g O3 / g product)

Data is collected in order to identify the VOC threshold of the product. As part of the registration process, you are presented with a comparison of your product’s VOC to those at the Federal, State, and Canada levels, illustrating if the VOC exceeds, or does not exceed, the limits set forth in various regions. 

Upon review of this data, you are to acknowledge within your registration that the VOC entry exceeds, or does not exceed, the limits displayed in the table. Also, when a product type is under VOC regulations, you are prompted to also provide a product label in addition to the product’s Safety Data Sheet (SDS). The label contains information on the VOC, and this is reviewed by our assessment team professionals. Validation of the exceed, or does not exceed, may be included as data provided to the recipient or retailer. This ensures proper handling and commerce in various regions when the product is in the recipient or retailer’s possession.

How it may impact you product registrations

The impact to existing registrations that validate the Architectural Coating VOC data with regard to exceeding, or not exceeding, the stated limits per State and Country will be that the acknowledgement will need to be revisited.

Auto-Recertification at times of forwarding registrations, or editing UPC data on a registration, will occur to ensure the expanded States are indicated and acknowledge for exceed / does not exceed the limits.

 As UL continues to work with clients on safety, Volatile Organic Compounds are part of the spectrum for compliance in North America. By providing, and validating, VOC data within a registration, we can all work together to ensure compliance and safety within the supply chain.

Questions and assistance

If you would like to learn more about how upcoming VOC requirements may impact your product registration, assistance is available by using the WERCSmart Live Chat feature located in the lower right corner of your screen.

The WERCSmart program provides a secure, permission-based platform that facilitates the safe exchange of product information between manufacturers and retailers with the highest standards of confidentiality and service.