Canada’s regulations for volatile organic compounds (VOCs) continue to be an important compliance consideration for companies that manufacture or import certain consumer products.
Under the Canadian Environmental Protection Act, 1999 (CEPA), Environment and Climate Change Canada (ECCC) introduced the Volatile Organic Compound Concentration Limits for Certain Products Regulations. The regulations establish maximum VOC concentration limits and emission potentials for approximately 130 product categories and subcategories.
For manufacturers and importers, understanding which products are covered, and the applicable compliance options, is essential to maintaining regulatory compliance in the Canadian market.
What Products Are Covered by Canada’s VOC Regulations?
The regulations apply to a broad range of consumer and commercial products, including:
- Personal care products
- Automotive maintenance products
- Household maintenance products
- Adhesives and adhesive removers
- Cleaners and other household chemical products
- Other miscellaneous products
The specific regulated product categories and applicable requirements are set out in Schedules 1 and 2 of the regulations.
Maximum VOC Concentration Limits
Canada’s VOC regulations establish maximum VOC concentration limits and, for certain products, maximum emission potentials.
These limits are product-specific, so determining whether a product is compliant requires reviewing the applicable product category, formulation, and regulatory requirements.
In addition to meeting applicable VOC limits, manufacturers and importers may have obligations related to:
- Product record keeping
- Product labelling
- VOC concentration calculations and supporting documentation
- Laboratory analysis performed by an accredited laboratory, where required
Companies should evaluate their products against the applicable requirements before manufacturing or importing them into Canada.
What Is the Canadian Environmental Protection Act?
The Canadian Environmental Protection Act, 1999 (CEPA) provides the federal legislative framework for preventing pollution and protecting the environment and human health.
The Volatile Organic Compound Concentration Limits for Certain Products Regulations were made under CEPA and establish federally enforceable requirements for specified products sold in Canada.
This differs from the U.S. regulatory landscape, where VOC requirements can vary between federal and state jurisdictions. For example, California has its own consumer product VOC requirements administered by the California Air Resources Board (CARB).
Alternative Compliance Options
Canada’s VOC regulations include alternative compliance mechanisms for certain circumstances. These options can provide manufacturers and importers with flexibility when meeting a prescribed concentration limit that may not be technically or economically feasible, or when an alternative approach can achieve lower VOC emissions.
Are there exemptions or special considerations?
The regulations do not apply to products designed to be used solely in manufacturing or processing.
For the purposes of the regulations, manufacturing or processing includes activities in which goods, products, commodities, or wares are:
- Made, fabricated, processed, or refined from raw materials or other substances
- Converted or rebuilt, other than repaired
- Produced through a significant chemical, biochemical, or physical change to a raw material or other substance, including changes that preserve or improve its keeping qualities, but excluding changes caused by growth or decay
There are also provisions addressing products manufactured or imported before the applicable coming-into-force dates. The regulations do not restrict the sale of those products through the supply chain.
Because applicability depends on the product and its intended use, companies should review the regulatory requirements for each relevant product rather than assuming that a general exemption applies.
How Dell Tech Can Help
Determining whether a product falls within Canada’s VOC regulations, and then identifying the appropriate compliance pathway, can require a detailed review of the product formulation, intended use, and applicable regulatory category.
Dell Tech can help manufacturers and importers:
- Determine whether products are subject to Canada’s VOC requirements
- Identify the applicable product category and VOC limit
- Complete VOC concentration calculations
- Assess potential exemptions and alternative compliance options
If you manufacture or import consumer products in Canada, contact Dell Tech to discuss your VOC compliance requirements, and determine what steps may be needed for your products.
Blog Author
Alison Senyi
Alison completed her B.Soc.Sc. from the University of Ottawa, and an Honours Certificate of Occupational Safety and Health from Algonquin College. Prior to joining Dell Tech, Alison had over 5 years of experience working in the product safety industry. With her extensive knowledge of regulatory compliance, she can assist with guidance on regulations relating to consumer and industrial products.
