20 JOURNAL OF COSMETIC SCIENCE
VOLATILE ORGANIC CARBON REGULATION
Volatile Organic Compounds (VOCs) have been a concern for public health agencies in the
United States, with California being at the forefront of regulating their use in consumer
products, including cosmetics. The California Air Resources Board (CARB) enforces VOC
emission limits and has the power to impose fines and penalties for non-compliance.
Since 1989, California has restricted the use of VOCs in several personal care product
categories to reduce ground-level ozone. These categories include hair finishing spray,
aerosol sunscreen, dry shampoo, deodorant body spray, and antiperspirant/deodorant. New
limits have been implemented as of January 1, 2023, for most product categories, with the
remaining categories to follow in 2029 as seen in Figure 12.
To comply with these regulations, products in these categories are not allowed to use four
solvents that are considered to have “significant adverse health impacts”: perchloroethylene,
trichloroethylene, methylene chloride, and pchloro-α-,α,αtrifluorotoluene. Additionally,
compounds with a GWP over 150 CO
2 equivalents will also be prohibited.
Spray sunscreens and antiperspirants were in the original proposal, but because both
are over-the-counter drugs and controlled by federal monographs, the CARB board has
Figure 11. Physiochemical properties of emollients.
Figure 12. California Air Resources Board (CARB) has set new limits to lower existing limits for volatile
organic compound emissions from consumer products by 2023.

21 Bottle Your Sustainability Goals – Minimize
excluded these applications from their 2023 limits on VOCs due to the advocacy by the
Personal Care Product Council and the Personal Care industry.
The GWP is a metric that enables comparisons of the warming impacts of various gases. It
measures the amount of energy that the emissions of one ton of gas will absorb over a specific
period, relative to the emissions of one ton of carbon dioxide (CO
2
)over that period, with
one hundred years being the typical time frame used for GWPs. GWPs provide a common
unit of measure, allowing analysts to combine emissions estimates of different gases and
policymakers to compare emissions reduction opportunities across sectors and gases.
In the personal care industry, the four common VOC solvents used are ethanol, isobutane,
propane, and butane. Carbon dioxide is used as the common unit of measure. As we have
seen with esterification, the feedstock utilized influences the Global Warming Potential.
For instance, ethanol, which is commonly used in aerosol applications, can have a GWP
ranging from 0.5 to 5.5 CO
2
equivalents, depending on the initial feedstock and production
process. (Figure 13)
SPRAY SUNSCREEN CASE STUDY
The sunscreen sprays depicted in Figure 14, EK-6127-1254 (62% VOC) and EK-6127-1255
(55% VOC), were formulated using a filter composition comprising Homosalate (10%),
Figure 13. VOC examples are affected by feedstocks.
Figure 14. Spray sunscreen.