Canada publishes VOC regulations for certain products
Modified on: Wed, 23 Feb, 2022 at 10:07 AM
Under the new Volatile Organic Compound Concentration Limits for Certain Products Regulations, a VOC is defined as “a volatile organic compound that participates in atmospheric photochemical reactions and that is not excluded under Item 65 of Schedule 1 to the Canadian Environmental Protection Act, 1999.” VOCs are of a concern as they are precursors to the formation of ground-level Ozone and particulate matter which are two main components of smog. Smog has detrimental human health as well as environmental impacts.
Although Canada already has established VOC regulations for automotive refinishing products and for architectural coatings, the voluntary guidelines for consumer product categories have not been sufficient for Canada to meet both its national and international commitments. On 5 January 2022, the Government of Canada published new regulations addressing this gap. The Regulations establish maximum VOC concentration limits for approximately 130 products and sub-categories of products. The regulations apply to manufacturers and importers of these products as both the manufacture and import of the designated products with VOC limits in excess of the established limits will be prohibited, unless a permit is granted.
The new regulations target products that are used in households as well as in the institutional, industrial and commercial sectors. Product groups that will now be regulated include “personal care products; automotive and household maintenance products; adhesives; adhesive removers; sealants and caulks; and other miscellaneous products.”
The complete list of regulated product groups and sub-categories are found in the Table for Schedule 1, along with the maximum VOC Concentration. Some more specific examples are provided as follows:
Product Category – Personal Care Products
Antiperspirant and deodorants, both aerosol and non-aerosol
Heavy-duty hand cleaner or soap (with exceptions)
Nail polish remover
Personal fragrance products (with exceptions)
Product Category – Maintenance Products
Automotive wax, polish, sealant or glaze
Automotive wash (except for those used exclusively for aircraft of locomotives), non-aerosol
Windshield water repellant
Air fresheners, including those with disinfecting properties (with exceptions), single-phase aerosols, double-phase aerosols, liquid or pump spray, solid or semi-solid forms included
Bathroom or tile cleaner both aerosol and non-aerosol
Graffiti remover, both aerosol and non-aerosol
Laundry detergent or sizing or finishing products
Spot removers, both aerosol and non-aerosol
Toilet or urinal cleaning or deodorizing products, both aerosol and non-aerosol
Product Category – Adhesives, Adhesive Removers, Sealants and Caulks
Structural waterproof adhesive
Product Category – Miscellaneous Products
Non-stick aerosol cooking spray
Highlights of the regulations include:
Currently, there is no required testing or general reporting requirements. However, the burden is on the manufacturer and/or importer to ensure that the products that they manufacture and/or import meet the regulatory requirements.
Testing for VOC concentrations and/or emission potentials for a product must be carried out by an accredited lab as defined in the regulations.
All regulated products must be labelled with the date of manufacturer or a representative code. The explanation of the code must be disclosed to the Canadian Government, if requested.
If a permit is granted, clear directions for use must be in both French and English.
If a product falls into more than one category, the most stringent limit must be used. Limited exceptions do apply.
Records must be maintained with information dependent on whether the entity is a manufacturer or an importer.
Any information submitted to the Canadian Government must be maintained, along with a copy of any supporting documentation.
Records must be maintained for a minimum of five years.
There are three “alternative compliance options” with their own individual requirements. They are:
VOC Compliance Unit Trading System
Permit – Products Whose Use Results in Lower VOC Emissions
Permit – Technical or Economic Non-Feasibility
Coming into force dates for regulations and prohibitions:
January 1, 2023 – regulations in force
Allows for permit applications, ensuring compliance of units, etc. from the time of publication of the regulations (5 January 2022) to coming into force of the product limits
January 1, 2024 – VOC Limits and Emission Potentials for the manufacture and import of products in force
For all products listed in the Schedule, except Item 31 – Disinfectants
January 1, 2025 – VOC Limits and Emission Potentials in force for Disinfectants
Allows for potential reformulation and/or reapproval by the government
The reader is strongly encouraged to read the full text of the regulations for complete details.
Recommended action items
• Review your product line and determine if any products fall under the Regulated Categories/Sub-Categories.
• Determine current VOC concentration limits versus newly established limits.
• Note the timelines for implementation of prohibitions:
o January 1, 2023 – Coming into force of Regulations
o January 1, 2024 – Coming into force of Maximum VOC Limits and Emission Potentials for all products listed in Schedules, except disinfectants.
o January 1, 2025 – Coming into force for Disinfectants category (Item 31 of the table in Schedule 1)
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