On March 27, the Household & Commercial Products Association (HCPA), Fragrance Creators Association (FCA) and Personal Care Products Council (PCPC) (Allied Trade Associations) filed a joint letter respectfully requesting that the California Air Resources Board (CARB) maintain the current two percent fragrance exemption that applies to almost all of the 130 consumer product categories regulated by CARB.
In summary, the letter explained that manufacturers have relied on the exemption to include fragrance in products that comply with CARB’s stringent volatile organic compound (VOC) limits while meeting important consumer needs and signaling proper product use. If this provision is eliminated, many product manufacturers would be forced to expend a significant amount of time, money and effort to reformulate products that were developed with the reasonable expectation that this long-standing exemption would remain in effect. Moreover, eliminating the exemption would likely cause manufacturers to reduce the quantity of fragrance in consumer products, which could cause consumers to use a greater amount of product per use in order to achieve the intended effect. The Allied Trade Associations expressed appreciation of CARB staff’s transparency and open communication throughout this rulemaking process and requested a meeting to discuss our members’ significant concerns about this issue.