VOC Compliance Tracker
VOC limits by chemical category (CARB, OTC, SCAQMD) with sample tracking template and verification routine.
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Jurisdictions with consumer / institutional cleaning-product VOC rules
Where to look first when procuring cleaning chemicals for a multi-state operation. Limits change; verify current rule with the agency cited before issuing PO language.
| State / Jurisdiction | Rule citation | Scope / status notes | Agency |
|---|---|---|---|
| California | 17 CCR §94509 | Consumer + institutional cleaning products; most restrictive in U.S. | CARB |
| New York | 6 NYCRR Part 235 | Updated 2022 — tighter limits across multiple categories. | NYSDEC |
| Maryland | COMAR 26.11.32 | Adopts OTC model rule with state amendments. | MDE |
| Delaware | 7 DE Admin §1141 | OTC model rule baseline. | DNREC |
| Ohio | OAC 3745-112 | OTC-equivalent VOC limits for consumer products. | Ohio EPA |
| Connecticut | RCSA §22a-174-40 | OTC model rule; coordinated with OTC member states. | CT DEEP |
| New Jersey | NJAC 7:27-24 | OTC model rule; updated for 2018 OTC Phase V. | NJDEP |
| Rhode Island | Air Pollution Control Reg. 31 | OTC model rule. | RIDEM |
| Pennsylvania | 25 Pa. Code §130 | OTC model rule applies in ozone nonattainment counties. | PA DEP |
| Virginia | 9 VAC 5-45-720 | OTC model rule; some categories phased in. | VA DEQ |
| New Hampshire | Env-A 4100 | Amended 2017; some limits stricter than OTC baseline. | NH DES |
| Vermont | Air Pollution Control Reg. §5-253 | OTC model rule. | VT DEC |
| D.C. | DCMR §20-742 | OTC model rule. | DOEE |
| Illinois | 35 IAC Part 223 | Adopted CARB/OTC equivalent for cleaning categories. | IL EPA |
| Michigan | Mich. Admin Code R 336.1660 | Categories aligned with OTC model. | EGLE |
| Indiana | 326 IAC 8-15 | OTC-aligned limits in nonattainment areas. | IDEM |
| Utah | Utah Admin Code R307-357 | CARB-aligned for select categories. | Utah DEQ |
| Colorado | 5 CCR 1001-9 §XII | Front Range counties; consumer products rule effective 2024. | CDPHE |
OTC member states (Ozone Transport Commission): CT, DE, MD, NH, NJ, NY, PA, RI, VT, VA, and D.C. Several non-OTC states adopt the OTC model (OH, IL, MI, IN, CO). Default assumption when shipping into any OTC jurisdiction: follow the OTC Phase V (2018) consumer-products limits unless the state has issued tighter rules.
Product category VOC limits (% by weight)
Limits expressed as percent VOC by weight unless noted. Use as a first-pass screen; confirm the most current value with the agency cited before issuing a PO. CARB uses g/L for some categories — convert with product density before comparing.
| Product category | EPA federal | CARB (CA) % | NY 2022 % | OTC / other states % | Notes |
|---|---|---|---|---|---|
| Bathroom & tile cleaner (non-aerosol) | — | 1.0 | 1.0 | 1.0 | Bathroom-specific products; not general-purpose. |
| Bathroom & tile cleaner (aerosol) | — | 7.0 | 7.0 | 7.0 | |
| General-purpose cleaner (non-aerosol) | — | 0.5 | 4.0 | 4.0 | Most jurisdictions; CARB is strictest. |
| General-purpose cleaner (aerosol) | — | 8.0 | 8.0 | 10.0 | |
| General-purpose degreaser (non-aerosol) | — | 0.5 | 3.0 | 3.0 | Some states 4%. Verify. |
| General-purpose degreaser (aerosol) | — | 10.0 | 10.0 | 10.0 | |
| Glass cleaner (non-aerosol) | — | 3.0 | 4.0 | 4.0 | |
| Glass cleaner (aerosol) | — | 12.0 | 12.0 | 12.0 | |
| Oven/grill cleaner (non-aerosol) | — | 4.0 | 4.0 | 4.0 | |
| Disinfectant (non-aerosol) | — | 1.0 | 1.0 | 1.0 | EPA-registered; check label compliance. |
| Disinfectant (aerosol) | — | 70.0 | 70.0 | 70.0 | High limit; check fire codes for storage. |
| Sanitizer (non-aerosol) | — | 1.0 | 1.0 | 1.0 | |
| Furniture polish (non-aerosol) | — | 3.0 | 3.0 | 3.0 | |
| Floor wax (wood, non-aerosol) | — | 90.0 | 90.0 | 90.0 | Solvent-based wood floor wax exempt category. |
| Floor polish/wax (resilient/non-resilient) | — | 1.0 | 1.0 | 1.0 | Water-based floor finishes. |
| Carpet/upholstery cleaner | — | 0.1 | 0.1 | 7.0 | CARB / NY drastically tighter than OTC. |
| Multi-purpose solvent | — | 3.0 | 3.0 | 30.0 | CARB/NY 3%; many states unregulated. |
Procurement language
Paste into RFP / PO:
“All cleaning, sanitizing, and disinfecting products supplied under this contract shall comply with the VOC content limits established by the most restrictive jurisdiction in which product will be used, including but not limited to:
• California Code of Regulations Title 17, §94509 (CARB Consumer Products);
• 6 NYCRR Part 235 (NY consumer products, as amended 2022);
• The Ozone Transport Commission Phase V Model Rule, as adopted by relevant states.
Supplier shall provide upon request: (a) current Technical Data Sheet (TDS), (b) Safety Data Sheet (SDS), and (c) a Certificate of Compliance or Certificate of Analysis (CoA) stating VOC content as percent by weight per applicable jurisdiction. Supplier shall notify Buyer in writing within 30 days of any reformulation that changes VOC content.”
“All cleaning, sanitizing, and disinfecting products supplied under this contract shall comply with the VOC content limits established by the most restrictive jurisdiction in which product will be used, including but not limited to:
• California Code of Regulations Title 17, §94509 (CARB Consumer Products);
• 6 NYCRR Part 235 (NY consumer products, as amended 2022);
• The Ozone Transport Commission Phase V Model Rule, as adopted by relevant states.
Supplier shall provide upon request: (a) current Technical Data Sheet (TDS), (b) Safety Data Sheet (SDS), and (c) a Certificate of Compliance or Certificate of Analysis (CoA) stating VOC content as percent by weight per applicable jurisdiction. Supplier shall notify Buyer in writing within 30 days of any reformulation that changes VOC content.”
Verification workflow
- Pull TDS for every active product; locate VOC % by weight (sometimes on SDS Section 9).
- Compare against the strictest applicable jurisdiction in your operating footprint.
- If TDS doesn’t list VOC %, request CoA from supplier in writing.
- Flag mismatches; replace or restrict use by jurisdiction.
- Re-verify every 12 months — reformulations are common.
• Quaternary disinfectants in aerosol form can hit 70% VOC limit. Check fire code storage.
• Solvent-based wood floor wax (90% exempt category) is heavily regulated for ventilation — verify SDS Section 8.
• CARB measures some categories in g/L; convert using product density before comparing to % by weight columns elsewhere.
Sources: CARB Consumer Products Regulation (17 CCR §94509); NY 6 NYCRR Part 235 (2022 update); OTC Phase V Model Rule for Consumer Products (Nov 2018); ISSA Summary of VOC Limits (industry compilation); individual state agency rule pages. Always confirm against the live rule — some categories carry phased effective dates and small-business exemptions not shown here.
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