Your company may be required to report data to CARB through the agency's Consumer Products Reporting Tool (CPRT) on CARB's website by Nov. 1, 2016. CARB held a 2015 Reporting Requirements webinar on June 29.
CARB's data collection effort focuses on commercial products, and aerosol coatings sold in or supplied to California. The surveys will require manufacturers' and suppliers' participation in a multi-year data collection, whereby sales and product ingredient data, including information on volatile organic compound (VOC) content, will be required. CARB will use the information provided through these surveys to update the state's inventory of emissions of VOCs and low-vapor-pressure VOCs (LVP-VOCs), after which it will determine the feasibility of further reducing VOC emissions. The survey is part of CARB's effort to control ozone pollution by limiting VOC emissions, and CARB stated that such data is necessary to establish the scientific basis for the clean air plans and related rulemakings to address the stricter national standards for ozone and fine particulates.
Notably, for the 2015 calendar year, several categories are exempt and do not require any reporting. These categories include:
- 10101 Arts and Crafts Adhesive
- 10102 Automobile Headliner Adhesive
- 10103 Automotive Engine Compartment Adhesive
- 10108 Fabric/Textiles Adhesive
- 10109 Flexible Vinyl Adhesive
- 10112 Laminate Repair/Edgebanding Adhesive
- 10113 Mist Spray Adhesive
- 10114 Mounting Adhesive
- 10116 Polyolefin Adhesive
- 10117 Polystyrene Foam Adhesive
- 10119 Screen Printing Adhesive
- 10121 Tackifying Agent (semi-permanent)
- 10122 Temporary/Removable Adhesive
- 10123 Thread Locking Compound
- 10124 Wallpaper Adhesive
- 10125 Web Spray Adhesive
- 10201 Cold Process Roof Cement (aerosol only)
- 10203 Floor Seam Sealer
- 10205 Painter's Putty
- 10206 Pipe Thread Sealant/Pipe Joint Compound
- 10207 Plumber's Putty
- 10208 Rubberized Sealant
- 10212 Tile and Grout Sealer
- 10213 Window Glazing Compound
- 20201 Artist Solvent and Thinner
- 21016 Rubber and Vinyl Protectant (aerosol)
- 21017 Rubber and Vinyl Protectant (non-aerosol)
- 30906 Nail Glue or Adhesive
- 30909 Nail Polish Thinner
- 30911 Nail Treatment Product
- 70109 Paint and Surface Cleaner
- 70110 Paint and Surface Protectant (including antifouling products)
- 80101 – 80399 All Aerosol Coatings Products
Please note that if a company's products are on the exempt list, an abbreviated submission is still required, but sales and formula data do not need to be included.
CARB is not only using the survey reports for data collection and analysis, but also using this information to determine whether reporting companies are in compliance with the regulations. Consequently, if they discover that a company is not in compliance with a particular limit, they will forward the survey response information to ARB's Enforcement Division.
CARB's data collection effort is now in its third year. For the 2013 calendar year, 1,800 Data Collection survey responses are complete; over 302,000 products were included in these responses; and over 135,000 label files were submitted. For the Data Collection for 2014 calendar year, approximately 1,550 survey response are complete; over 250,000 products reported; and over 45,000 label files submitted.