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Kalium Solutions

Article 2/2 on VOC regulations

Kalium Solutions
18 december 2022

On January 1st, 2023, the Volatile Organic Compound Concentration Limits for Certain Products Regulations will come into force. In this new regulation, approximately 130 categories of consumer products have been assigned a VOC concentration limit. These categories include several personal care products such as antiperspirants, hair products and scented products. It also includes automotive and household maintenance products, and adhesives.

 

However, the VOC concentration limits, and maximum emission potentials will come into force on January 1st, 2024 for all categories except for disinfectants which will be given an additional year before entering into force on January 1st, 2025. If a company cannot meet the concentration and emission potential requirements, the regulation provides three alternative compliance options. Companies will be able to use the year 2023 to take the necessary steps to benefit from one of these options.

 

 

The options available to businesses are:

 

  • A two-year temporary permit with evidence of technical or economic non-feasibility to meet the requirements for their product. The applicant will also be required to provide a plan identifying measures to ensure compliance with the limits once the permit expires.

     

  • A permit renewable every 4 years for products whose use results in lower VOC emissions. This permit is designed for innovative products.  Specifically, this permit applies to products with a maximum VOC concentration above the limit, but the use of which, in accordance with the manufacturer's written instructions, results in lower VOC emissions than would result from the use of a compliant product in the same category. The applicant will be required to provide evidence for the obtention and renewal of the permit.

     

  • A VOC compliance unit trading system. Companies will need to obtain a permit for their products exceeding the regulatory limit. They will have to submit a plan to compensate for the excess VOCs. Offsetting can be done either by creating compliance units from other compliant products or by exchanging units with another company. Companies wishing to use this option will be able to take advantage of 2023 to apply for permits, submit notices of intent to create compliance units and create them.

For more information, please consult the Regulatory Fact Sheet.

 

Important dates to remember:

 

January 1st, 2023:

  • Coming into force of the Volatile Organic Compound Concentration Limits for Certain Products Regulations
  • Choice of compliance option and permit applications if applicable

January 1st, 2024:

  • Coming into force of VOC limits for all categories listed in Schedules except for disinfectants

January 1st, 2025:

  • VOC limits for disinfectants comes into force

If you need help calculating and identifying the VOCs / low vapor pressure VOCs of your products, do not hesitate to contact the Kalium team at 450 906-6999.

Brigitte Charpentier

About the author

Brigitte Charpentier

Brigitte Charpentier is the founder of Kalium Solutions, a regulatory affairs and health and safety consulting firm in Quebec. With a technical degree in biochemistry and a bachelor's degree in chemistry from the University of Quebec in Montreal, she is recognized as an expert in several regulatory fields as well as an expert witness in court. Passionate about her work and thanks to her leadership, she has developed a relationship of trust with several hundred companies both in Canada and abroad. She has surrounded herself well in order to develop high-performance software in terms of drafting regulatory documents and the safe management of chemical products. Brigitte and her team are therefore able to offer a diverse range of support to companies, ranging from one-off consulting, to training in transportation, WHMIS, etc., to the overall management of its regulatory processes, including the rental of various software adapted for the management, drafting of SDSs and safe storage of chemical products. Kalium has built a reputation as a leader in the field, one client at a time, always following the same guiding principle: Rigor, precision, and compliance. Because everyone's safety is at the heart of the approach.

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