Under the 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.” 


Although Canada had already 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.”


TABLE OF CONTENTS

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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

    • Acoustical sealant

    • Structural waterproof adhesive

    • Adhesive removers

  • 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:

    • 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.