Mike Rogge

CARB Survey with significant non-reporting penalty

By Mike Rogge

Capitol Update, Jan. 23, 2015 Share this on FacebookTweet thisEmail this to a friend

The California Air Resource Board (CARB) has posted materials on their website pertaining to a Consumer and Commercial Products Survey that was apparently announced in September. There are four to six times more products included than previously surveyed. As many as 2,000 cleaning, personal care and other consumer products manufacturers and 300,000 products will be captured.

The survey is part of CARB’s effort to control ozone pollution by limiting emissions of volatile organic compounds (VOCs), which promote ozone formation. CARB says that this data will enable them to maintain an accurate inventory of products containing VOCs. However, companies must complete the survey even if their products contain low or no VOCs.

Any company listed on the label of a chemically formulated consumer or commercial product sold or supplied for used in California must complete the survey if their product falls into one of the following seven product categories:

1.     Adhesives, sealants and related product;

2.     Household and institutional products;

3.     Personal care products;

4.     Pesticide products;

5.     Solvents and thinning-related products;

6.     Vehicle and marine vessel aftermarket products; and/or

7.     Aerosol coating products.

More specifically, the survey involves dozen of types of everyday products, such as air fresheners, arts and crafts supplies, cleaners and degreasers, dishwashing and laundry products, fuels and lighter materials, garden and lawn care products, office supplies, leather care products, antiperspirants and deodorants, cosmetics, hair products, nail polish, herbicides, insecticides, antimicrobial agents, solvents, and spray paint and other aerosol coatings. 

Companies are required to report their products, ingredients, formulations and chemical suppliers as well as their 2013 sales volumes by March 2, 2015.

Failure to report by March 2nd carries a $10,000/day penalty. CMTA is concerned about CARB’s outreach and has found a high percentage of manufacturers who have never heard of this reporting requirement. If you produce products that you believe fall under this requirement and you believe you may have trouble meeting the March 2nd deadline, please contact Mike Rogge at CMTA (mrogge@cmta.net).

CARB held a webinar on the subject mid-December and will hold an additional webinar on February 4, 2015 from 10:00 am to 1:00 pm PST to answer questions related to the 2013 survey.

Sign up for the webinar here.

You can find more details on the survey here.

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