State VOC Limits for Cleaning Products – Opora Supply

Who this is for

This guide is for procurement staff, facility managers, and BSC chemical program managers who purchase or specify cleaning chemicals in states with active consumer and commercial product VOC regulations. It is particularly relevant if your operations span multiple states, if you are managing a GSA or institutional account with environmental compliance requirements, or if a distributor has recently told you a product is being reformulated or discontinued due to regulatory changes.

The regulatory framework: four rule systems you need to know

VOC limits for cleaning products in the United States are not set at the federal level for commercial products. They are set by state or regional air quality agencies, and they apply to products sold and used within those jurisdictions. Four regulatory frameworks cover most of the institutional purchasing market:

CARB (California Air Resources Board)

CARB’s Suggested Control Measure (SCM) for Consumer Products and the Aerosol Coatings regulations set VOC limits for cleaning product categories sold in California. CARB has historically led VOC regulation nationally; its limits are often the most stringent and are adopted by other states through the OTC Model Rule. CARB’s Phase III updates for commercial/industrial category products have created compliance pressure specifically on solvent-based degreasers, floor polishes, and general-purpose cleaners. Products sold by national distributors are increasingly formulated to meet CARB limits to avoid maintaining separate California-only SKUs.

SCAQMD (South Coast Air Quality Management District)

The SCAQMD, covering the Los Angeles basin, applies additional limits below CARB statewide rules for facilities operating within the district. SCAQMD Rule 1171 (Solvent Cleaning Operations) and Rule 1143 (Consumer Products) impose stricter limits on solvents used in industrial cleaning operations. Facilities in Los Angeles, Orange, Riverside, and San Bernardino counties must verify against SCAQMD rules in addition to CARB statewide limits.

Michigan Consumer Products Rule (CPR)

Michigan adopted its Consumer Products Rule aligned with CARB standards, making it the most significant non-California state VOC regulation for commercial cleaning products. The Michigan CPR applies to products sold in Michigan, affecting national distributors serving the Midwest. Floor polishes, degreasers, and general-purpose cleaners are the most affected categories.

OTC Model Rule Phase IV

The Ozone Transport Commission (OTC) Model Rule, adopted in various forms by northeastern and mid-Atlantic states, sets VOC limits that states can adopt into their own regulations. Phase IV updates tightened limits on several commercial cleaning product categories. States that have adopted Phase IV provisions include Connecticut, Delaware, Maryland, New Jersey, New York, Pennsylvania, and Virginia, among others. Specific effective dates vary by state; verify current adoption status with each state’s environmental agency.

Product categories with the most active compliance pressure

Solvent-based degreasers

Solvent degreasers face the tightest limits across all four regulatory frameworks. Products with VOC content above 3% by weight are likely non-compliant in California and many OTC states for general-purpose use. High-VOC solvent degreasers remain available for specific industrial exemptions, but these exemptions have documentation requirements and do not cover general janitorial application. If you are purchasing solvent degreasers for facilities in regulated states, verify the product’s VOC content against the specific category limit — category definitions (e.g., “general purpose degreaser” vs. “specialty degreaser”) affect which limit applies.

Floor polishes and floor finishes

Floor finish products — particularly high-gloss commercial floor polishes — historically contained solvent carriers that are now above current CARB and Michigan CPR limits. The regulatory pressure has accelerated the shift to water-based floor finish formulations. Most national-brand floor finishes have been reformulated for multi-state compliance, but specialty products and older inventory in regional distribution may not meet current standards. Verify the VOC content on the SDS Section 9 against the applicable state limit for the floor polish or floor finish category.

General-purpose cleaners and degreasers

The “general-purpose cleaner” category under most state VOC rules has a VOC limit of 0.5% to 1% by weight. Most commercial neutral cleaners and many alkaline degreasers formulated since 2020 meet this threshold. However, concentrate products require attention: the VOC limit applies to the ready-to-use solution in most jurisdictions, not the concentrate. A concentrate with 8% VOC content diluted 1:10 to 0.8% meets a 1% limit. Verify whether the applicable rule uses RTU or concentrate VOC content as the regulatory basis — this varies by state.

How to verify compliance for your product portfolio

Three steps provide sufficient verification for most institutional procurement programs:

Step 1 — Pull SDS Section 9 for each product. The VOC content (grams per liter or percent by weight) is listed in the physical and chemical properties section. If it is not listed, request a California Air Resources Board VOC compliance statement from the manufacturer.
Step 2 — Identify the product category under applicable state rules. VOC limits vary by category, and the category definitions differ between CARB, OTC states, and Michigan CPR. A product that is a “general purpose degreaser” under CARB may be classified differently under the OTC rule. Manufacturer VOC compliance documentation should specify the category used.
Step 3 — Use a compliance tracking tool for multi-state operations. The VOC Compliance Checker cross-references product VOC content against applicable state limits by category and provides a current compliance status across the major regulatory frameworks.

Common mistakes

Assuming national products automatically comply everywhere. Manufacturers formulate to meet the most restrictive markets they choose to serve. A product available nationally may still be non-compliant in SCAQMD districts or in states with recent Phase IV adoptions if the manufacturer has not prioritized those markets in reformulation.

Using concentrate VOC content when the rule specifies RTU VOC content. This error can cause a compliant product to appear non-compliant (or vice versa). Always confirm which basis the applicable state rule uses before making a compliance determination.

Not tracking effective dates for phased regulations. Several state VOC rules have staggered effective dates by product category. A product that was compliant in January 2024 may have fallen out of compliance under a Phase IV provision effective January 2025. Build a calendar review into your procurement cycle for regulated categories.

Quick checklist

Identify which states your facilities or accounts are located in and which regulatory framework applies
Pull VOC content from SDS Section 9 for all degreasers, floor polishes, and general-purpose cleaners in your current portfolio
Confirm whether applicable rules use RTU or concentrate VOC content as the compliance basis
Verify product category classification under applicable rules — categories differ between CARB, Michigan CPR, and OTC states
Build a phased-regulation calendar to track effective dates for new limits
Request current California Air Resources Board VOC compliance documentation from distributors for any product without SDS Section 9 VOC data