Canada’s VOC Regulations
By Dana Mladin, SR. TECHNICAL CONSULTANT, email
On January 5, 2022, Environment and Climate Change Canada (ECCC) published regulatory changes to the Canadian Environmental Protection Act, 1999 by adopting the Volatile Organic Compound Concentration Limits for Certain Products Regulations.
Canada’s VOC regulations establish concentration limits and emission potentials for volatile organic compounds (VOCs). These maximum VOC limits apply to both manufacturers and importers of 130 product categories and subcategories. These product categories include personal care products, automotive and household maintenance products, adhesives, adhesive removers, sealants and caulks, as well as other miscellaneous products.
Maximum VOC Concentration Limits
Canada’s environmental regulations now establish VOC limits and maximum emissions potential for a variety of consumer products, such as household chemicals like cleaners. They apply to approximately 130 product categories and sub-categories which can be found in Schedules 1 and 2 of the regulations.
Additionally, these regulations set out requirements for record keeping, product labelling, and for an accredited laboratory to perform analyses for the purpose of the regulations.
If you manufacture or import consumer products in Canada, Dell Tech can help you with VOC consumer products regulations compliance.
Canadian Environmental Protection Act 1999
To read the regulations, please visit the Volatile Organic Compound Concentration Limits for Certain Products Regulations Canadian Environmental Protection Act Registry. Unlike in the US where state regulations like in California certain products can have a different VOC content limits than the once stipulated by the US Environmental Protection Agency and the Ozone Transport Commission, these regulations are federally enforceable in Canada.
Alternative Compliance Options
Canada’s alternative compliance options provide for economic considerations; the government does not want to adversely impact companies too strongly. Dell Tech can assist you with navigating the following alternatives:
Permit – Technical or economic non-feasibility
- valid up to 2 years
- renewable only once for up to another 2 years
- renewal request must be submitted 90 days prior to expiry.
Permit – Products whose use results in lower VOC emissions
- valid up to 4 years
- no limit on renewal
- renewal request must be submitted 90 days prior to expiry.
VOC compliance unit trading system
- earned compliance units can be used for 2 calendar years
- trades must be applied for jointly to the Minister
- required to report by March 1 of the year following when a permit is active, compliance units are generated, or compliance units are used.
Frequently Asked Questions about VOC Regulations
What is VOC-Definition?
VOC stands for Volatile Organic Compound. Volatile Organic Compounds are organic chemical compounds that can easily evaporate into the air at room temperature. They are found in various products and can contribute to air pollution and negative health effects when released into the atmosphere. Canada is joining the United States’ Environmental Protection Agency (EPA) in regulating personal care products and other product categories with the aim to reduce VOC emissions.
Why are VOCs a concern?
Volatile Organic Compounds are a concern due to their role in air quality and pollution. When released into the atmosphere, VOC emission can react with other pollutants to form smog and ground-level ozone, leading to environmental damage. Prolonged exposure to VOCs indoors can also contribute to indoor air quality issues and adversely impact human health.
How do VOCs contribute to air pollution and smog formation?
VOCs contribute significantly to air pollution and smog formation. This is due to the role that volatile organic compounds play in atmospheric chemistry. Here’s how VOCs contribute to:
- Formation of Ground-Level Ozone
- Photochemical Smog Formation
- Particulate Matter Formation
- Regional and Global Air Quality
Efforts to control VOC emissions and reduce their contribution to pollution and smog include the implementation of federal level and state VOC regulations, promoting low VOC content coatings and other products , and using pollution control technologies in various industries and transportation sectors.
What are VOC regulations?
VOC regulations are government-imposed rules and standards designed to limit the emission of volatile organic compounds (VOCs) into the environment. These regulations vary by region and industry but typically involve setting emission limits for specific VOC sources such as industrial processes, transportation, and consumer products like paints, solvents, and cleaning agents.
Compliance with these regulations often requires the use reasonably available control technology, adoption of low-VOC formulations, and the implementation of pollution control measures (air pollution control equipment). Such regulations aim to reduce pollution, improve air quality, mitigate health risks, and protect the environment by curbing the release of harmful VOCs and their contribution to smog and ozone formation.
Are there exemptions or special considerations for certain industries?
These regulations do not apply to products designed to be used solely in manufacturing or processing.
Manufacturing or processing are defined as activities whereby any goods, products, commodities or wares:
- are made, fabricated, processed or refined out of any raw material or other substance or combination thereof,
- are converted or rebuilt, but not repaired, or
- are made by causing any raw material or other substance to undergo a significant chemical, biochemical or physical change including change that preserves or improves the keeping qualities of that raw material or other substance but excluding change by growth or decay.
The regulations do not restrict sale. Products manufactured and imported prior to the coming into effect dates have no limit on sell-through.
What is the international collaboration on VOC regulations, if any?
International collaboration on VOCs primarily occurs through agreements and initiatives aimed at addressing air quality and environmental issues. Organizations such as the United Nations Environment Programme (UNEP) and regional bodies like the European Union work to harmonize and establish standards for VOC emissions.
The Montreal Protocol, initially created to address ozone-depleting substances, also indirectly influences the regulation of VOCs by promoting alternatives that are less harmful to the environment.
Additionally, international agreements on climate change, such as the Paris Agreement, can indirectly impact regulations as reducing VOC emissions can contribute to greenhouse gas mitigation. These collaborative efforts help coordinate global responses to VOC-related environmental challenges.
Do Canada’s regulations align with other jurisdictions?
Most of Canada’s product categories align with the California Air Resources Board’s (CARB) the Regulation for Reducing VOC Emissions from Antiperspirants and Deodorants and Regulation for Reducing Emissions from Consumer Products (2010 versions). As a general rule, if a product is already compliant in California, it is likely that it will be compliant in Canada too.
How Dell Tech Can Help with Canada’s VOC Regulations
Talk to our team today for more information on our consumer product compliance services. Our team can determine if your product is subject to compliance with Canada’s new VOC regulations; complete your product’s VOC concentration calculations; walk you through options for exemption or compliance; and consult on general questions about these regulations.
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