The California Air Resources Board, or CARB, remains the global benchmark for aerosol VOC regulations. When CARB moves, the rest of the world tends to follow.
The next phase of aerosol VOC controls comes into effect in January 2027. For brands and manufacturers who haven’t yet mapped out their compliance strategy, the time to start is now.
What is CARB and Why Does it Matter Globally?
CARB is the California Air Resources Board, the regulatory body responsible for controlling air quality emissions in California. For the aerosol industry, it sets the most stringent VOC limits anywhere in the world, and because California represents one of the largest consumer markets on the planet, most brands selling into the US must comply.
Its influence extends well beyond California’s borders. CARB standards have consistently become the de facto benchmark for aerosol VOC regulation globally, with other markets and regulatory frameworks moving in the same direction over time. Brands that build compliance into their product development now are better positioned regardless of where they sell.
How CARB Measures VOC Emissions
Under CARB, aerosol products are assessed on their total VOC content. This is not just within the solvent system, but the entire formulation including propellant. Every VOC-contributing ingredient in the can is part of the calculation.
Products currently fall into three broad bands:
Low VOC formulations at 10% or below cover cleaners, gels and many deodorant systems.
Mid-range products sitting between 10% and 40% include insecticides, adhesives and air care.
High VOC products such as hair sprays and legacy solvent-based systems, can sit anywhere between 40% and 80%.
The January 2027 update is expected to lower VOC caps across multiple categories. Hair spray limits are anticipated to drop from around 55% to 45%. Fragrance thresholds are likely to tighten from 75% to somewhere between 50% and 65%. Critically, the regulation is also shifting away from simple percentage-based controls toward reactivity-based measurement.This would assess not just how much VOC is present, but how harmful it is in terms of ozone formation.
This is a significant change in approach. It means reformulation strategies that have worked in the past may no longer be sufficient.
What are the CARB 2027 Compliance Options?
The aerosol industry currently has three primary routes to CARB compliance:
Direct Reformulation
This would involve rebuilding the product system to sit within the new limits. This typically means moving away from ethanol-driven solubility toward water as the primary carrier, using emulsifiers, stabilisers and low-volatility structuring agents to maintain performance without the VOC contribution.
It is the most straightforward path but requires genuine R&D investment and, in many cases, a willingness to change an established formulation.
Alternative Control Plan (ACP)
Under an ACP, manufacturers can sell some non-compliant products provided they over-comply elsewhere in their portfolio, keeping net emissions below an assigned cap. This requires CARB approval, detailed emissions reporting, forecasting and ongoing compliance tracking.
It is used primarily by large multinationals with broad product portfolios and the administrative infrastructure to manage it. For most brands, it is not a practical long-term strategy.
Innovative Product Exemption (IPE)
This allows genuinely novel delivery technologies to apply for temporary exemption where they can demonstrate equal or lower real-world emissions. The bar for approval is high and the exemption is typically time-limited.
Our innovative Eco-Valve™ was used as the basis for an IPE by Native deodorant at its original US launch. This was an early demonstration of how alternative propellant technology can open regulatory pathways that conventional formulations cannot.
What CARB Means Beyond 2027
The 2027 CARB update is not an endpoint, it is just another step towards a more environmentally friendly industry. Over the next five years, CARB’s stated direction is continued tightening of VOC and reactivity limits.
For manufacturers, that means compliance is no longer a reformulation exercise. It becomes a continuous operational pressure, seeing rising raw material costs, increasing R&D and testing requirements and shifts to lower reactive chemistries.
In the mid-term, compliant products will carry a commercial premium. Brands that have previously built low-VOC, low-reactivity formulations will be better placed to maintain margin and capitalise on the premiumisation of genuinely clean-format products.
Where Future Propellant Technology Fits In
For brands currently using LPG or ethanol-based systems, the path to CARB compliance almost always runs through propellant change. Both are significant VOC contributors, therefore removing them from the equation is the most effective lever available.
In comparison, nitrogen valve technology is exempt from VOC classification. As a propellant, it contributes zero to the VOC total, which creates meaningful headroom for brands working within tightening limits.
Salvalco’s Eco-Valve™ is specifically designed to deliver the performance that LPG-based systems currently provide, consistent atomisation, formulation compatibility across water, powder, resin, oil and emulsion systems, without the VOC burden and without requiring changes to existing filling lines.
For brands building a CARB compliance roadmap, making the switch to nitrogen propellants is the logical place to start the conversation.
The direction in which CARB 2027 will push the industry is clear. Brands that act early, reformulate thoughtfully and invest in the right delivery technology will be in a stronger position both commercially and regulatorily.
To discuss how Eco-Valve™ can support your CARB compliance strategy, get in touch with our team today.