Aerosol coatings are the only coatings category to be regulated by reactivity principles. In the early 1990’s, both EPA and California sought to significantly reduce the VOC content of aerosol coatings to the point where to do so would essentially eliminate the product. However, reactivity principles allow the substitution of higher reactive solvents for lower reactive solvents and both California and U.S. EPA have since adopted regulations for aerosol coatings based upon reactivity principles.
Manufacturers of aerosol coatings are currently in the process of reformulating products in order to comply with the most recent changes to the California Air Resources Board’s (CARB) regulation for aerosol coatings. Until 2015, the standards in the California rule and the standards in the U.S. EPA regulation were the same. While many provisions in the U.S. EPA regulation continue to mirror that in the California rule, some definitions have been added, deleted and changed along with the reactivity standards, necessitating efforts to comply with both of these regulations.
Note also that two historical VOC regulations, in California’s Bay Area Air Quality Management District (BAAQMD) and in the Portland Metro area of Washington state, are still maintained.