EPA Gets Serious About Spray Paint Chemistry for Cleaner Air
Published Date: 1/17/2025
Rule
Summary
The EPA is updating rules for aerosol spray paints to cut down harmful smog-causing chemicals called VOCs. These changes affect companies making or selling aerosol coatings by tightening limits, updating testing, and adding new deadlines starting January 17, 2025. The goal? Cleaner air with smarter, less polluting spray paint formulas—while keeping businesses in the know and on track.
Analyzed Economic Effects
9 provisions identified: 2 benefits, 7 costs, 0 mixed.
New and Tightened PWR Category Limits
The EPA updated product-weighted reactivity (PWR) limits and adopted CARB category names and limits. New combined categories and six new specialty categories were added with numeric limits: Hobby/Model/Craft = 1.6 g O3/g VOC; Shellac Sealers = 1.00 g O3/g VOC; Electrical/Electronic/Conformal = 2.00 g O3/g VOC; Flexible Coatings = 1.60 g O3/g VOC; Mold Release = 1.10 g O3/g VOC; Rust Converter = 1.10 g O3/g VOC; Two Component Coating = 1.20 g O3/g VOC; Uniform Finish = 1.30 g O3/g VOC.
Estimated Reporting Burden and Costs
EPA estimates 47 respondents, an annual total burden of 9,562 hours, and total estimated cost of $740,520 per year for the information collection related to this rule (EPA ICR Number 2289.06; OMB control number 2060-0617). The ICR has been submitted to OMB and the information collection requirements are not enforceable until OMB approves them.
New and Updated Reactivity Factors
The EPA is adding 17 new compounds to table 2A (including trans-1-chloro-3,3,3-trifluoropropene (HFO-1233zdE), CAS 102687-65-0, RF = 0.04 g O3/g VOC, and diethyl carbonate, CAS 105-58-8, RF = 0.71 g O3/g VOC) and updating RFs for other compounds to align with CARB values. Two isomer-related assignments were explicitly listed (dipropylene glycol monomethyl ether and 2-[2-methoxypropoxy]-1-propanol assigned RF = 2.58 g O3/g VOC).
Default Reactivity Factor Reset to 18.50
The EPA reset the default reactivity factor (RF) for VOCs not listed in table 2A to 18.50 g O3/g VOC. Regulated entities must include the name and CAS number of all VOCs for which they use the default RF and, if an isomer is listed, use the RF of the isomer (or the highest RF if multiple isomers are listed).
Change to Low‑Reactivity Exclusions
The rule retains the exclusion for compounds that comprise less than 0.1 percent of product weight (these are excluded from product mass-weighted reactivity) but removes the prior exclusion for low-reactivity compounds that comprise more than 0.1 percent but less than 7.3 percent of product weight. This amendment is finalized in 40 CFR 59.505.
Mandatory Electronic Reporting via CEDRI
Regulated entities must submit nine required notifications and reports (Temporary Variances; Initial Notification; Change to Information in Initial Notification; Response to Written Notification; Exemption Claim Initial Notification; Exemption Claim Annual Report; Notice of Certifying Entity to Maintain Records; Notice Rescinding Certification; Triennial Report) electronically through EPA's Central Data Exchange (CDX) using the CEDRI spreadsheet templates. The rule allows owners/operators to seek extensions for outages or force majeure events.
Updated Test Methods Required
When verifying compliance via testing, regulated entities must use the updated CARB Method 310 (May 25, 2018) for VOC/speciated ingredient determination and ASTM D523-08 for specular gloss. Entities electing to use updated RFs and limits before the compliance date must also use the updated test methods.
Effective and Compliance Deadlines
The final rule is effective January 17, 2025. Regulated entities may elect to comply with the amended limits and RFs upon that effective date, but all regulated entities must be in full compliance with all provisions by July 17, 2025 (181 days after the effective date).
RFA Certification: No Significant Small Entity Impact
EPA certified under the Regulatory Flexibility Act that this action will not have a significant economic impact on a substantial number of small entities, concluding there is no net regulatory burden for directly regulated small entities and anticipating long-term reduction in burden from electronic reporting.
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