VOC Limits for Consumer and Industrial Products

Summary#

The Volatile Organic Compound Concentration Limits for Certain Products Regulations (SOR/2021-268) set maximum volatile organic compound (VOC) levels for about 130 product categories. The rules were registered on December 21, 2021 and take effect in stages, with the main prohibitions starting on January 1, 2024 (limits) after an initial administrative start on January 1, 2023; disinfectant limits have an extra year (see below).

What it does#

• Creates category-by-category VOC concentration ceilings for roughly 130 product types (personal care, household and automotive maintenance, adhesives, sealants, etc.).
• Prohibits manufacturing or importing products that exceed those VOC limits after the limits come into force, unless:
  • the product is sold diluted so it meets the limit when used, or
  • the company holds an approved permit.
• Gives specific start dates:
  • Regulations come into force on January 1, 2023 for administrative provisions (permit applications, record keeping).
  • VOC concentration limits come into force on January 1, 2024.
  • Disinfectant product limits come into force on January 1, 2025.
• Sets up alternative compliance options:
  • A VOC Compliance Unit Trading System (companies can generate, trade, and use “compliance units” if they reformulate some products below the limits).
  • Temporary permits for products that cannot meet limits for technical or economic reasons (short-term authorizations).
  • Permits that allow a higher-VOC product if, by design or use instructions, it produces lower overall VOC emissions than a compliant alternative.
• Adds requirements for makers/importers:
  • Keep records for at least 5 years and make them available in Canada.
  • Show the product’s manufacture date (or code) on the container.
  • Use accredited labs for VOC testing when tests are done.
  • Submit annual reports (permit-holders and compliance-unit participants must report by March 1 each year).
• Aligns most limits with California standards (the California Air Resources Board (CARB)), with some adjusted limits for Canadian conditions.

Who's affected#

• Mainly manufacturers and importers of the covered products. Retailers can sell existing stock until it’s gone but are not the primary target of the rules.
• The regulations cover many everyday items: deodorants and hairsprays, cleaners and disinfectants, air fresheners, solvents and thinners, adhesives, automotive products, electronics cleaners, and more.
• The government’s analysis estimated about 1,950 manufacturers/importers affected, of which about 1,285 are small businesses.
• The regulations are national. They apply to products manufactured in Canada or brought into Canada (imported), and to a wide range of commercial, industrial and consumer products.

Why it matters#

• VOCs help form ground-level ozone and fine particles (smog). Reducing VOCs improves air quality and public health.
• The government estimates the rule will cut about 25 kilotonnes of VOCs per year (roughly 250 kilotonnes from 2024–2033). Those changes were modelled to produce health benefits valued at about $886 million over the analysis period.
• Estimated costs to industry and government are summarized in the regulatory analysis: industry compliance costs around $228 million, government administrative costs about $6 million, for a net-benefit estimate of about $651 million over the modelling period.
• The rules create flexibility (trading system and permits) to help companies, including small businesses, meet the limits while keeping some product options available.
• The Regulations also help Canada meet national and international air-quality commitments, including obligations under the Ozone Annex of the United States–Canada Air Quality Agreement.

If you make, import, or sell any of the named product types, or use them in a business, those are the parts to watch: new limits, record-keeping, labelling, and permit or trading options.