Regulations targeting many automotive products sold and distributed by CAWA members including brake cleaners, windshield wiper fluids, engine degreasers and carburetor and injection cleaners will take effect 1/1/09.  New Volatile Organic Compound (VOC) content changes require a reduction in the amount of VOC’s in these specified products. 

To assist CAWA members in complying with these changes we have provided specific VOC content information and effective dates for these products below.

It is important to note that these "Consumer Product Regulations" apply to any person who sells, supplies, offers for sale, or manufactures consumer products for use in the state of California.  These regulations specifically state that "no person shall sell, supply, offer for sale, or manufacture for sale in California any consumer product which, at the time of sale or manufacture, contains volatile organic compounds in excess of the limits specified in the following "Table of Standards" after the specified effective dates."

Brake Cleaners

Must contain no more than 20% VOC after 12/31/08

Must contain no more than 10% VOC after 12/31/10

Carburetor and Injector Cleaners

Must contain no more than 20% VOC after 12/31/08

Must contain no more than 10% VOC after 12/31/10

Engine Degreasers (Aerosols)

Must contain no more than 10% VOC after 12/31/10

Automotive Windshield Washer Fluids

Must contain no more than 25% VOC after 12/31/08

In Type "A" areas*

Type "A" areas include only the following:

Del Norte, Shasta and Trinity Counties ; the Great Basin Valley , Lake Tahoe, Mountain Counties and Northeast Plateau Air Basins

Sell Through Period
Generally speaking, there is a three-year sell through period if the product is date stamped.
CA Code of Regulation Title 17 Section 94509 specifies:
(c) Sell-through of products.
(1) Sell-through period.   Notwithstanding the provisions of Section 94509(a) or 94509(j), a consumer product manufactured prior to each of the effective dates specified for that product in the Table of Standards may be sold, supplied, or offered for sale for up to three years after each of the specified effective dates.

This subsection (c) does not apply to:

(A) any consumer product that does not display on the product container or package the date on which the product was manufactured, or a code indicating such date, or

(B) any consumer product on which the manufacturer has used a code indicating the date of manufacture that is different than the code specified in section 94512(b)(2), but an explanation of the code has not been filed with the ARB Executive Officer by the deadlines specified in section 94512(c)(1) or section94512(c)(2)

More to Come

There are more changes to these regulations in the works and will address tire and wheel cleaner, windshield water repellant and motor vehicle wash.  These changes have not fully cleared the administrative law process, but are expected to in the next six-nine months.  When enacted, these subsequent changes will take effect 12/31/10.

More Information

For detailed information about these new VOC reduction regulations on all consumer products affected including these specified automotive products visit: www.arb.ca.gov.consprod/regs/cp.pdf or contact CAWA's Director of Government Affairs, Jennifer Zins at 916.871.0603.

Founded in 1955, CAWA is a nonprofit trade organization representing automotive jobbers, warehouse distributors, retailers, manufacturers and manufacturer representatives in California, Nevada and Arizona.  CAWA's mission is to provide communications, education, legislative and regulatory advocacy and group purchasing of services for its members while promoting the automotive aftermarket industry.

For more information about CAWA and the latest in industry news, visit www.cawa.org .