For many of you, responding to the 2013 California Air Resources Board consumer products survey was a real challenge. Unfortunately, the Board doesn’t plan to give you much time to recover from the trauma. The 2014 survey data entry period begins on July 1, with all data due by November 1.
Responsible Parties will have to report product specs, sales data, and ingredient information, including the volatile organic compound (VOC) composition, for impacted consumer products sold in California in 2014. Impacted products range from air fresheners to antiperspirants to hair care products to home improvement products.
ARB will host a webinar on July 1 from 10:00 am to 1:00 pm PST.
As a quick refresher:
Reporting
A Responsible Party is the company listed on the product label (i.e., the company the product is “manufactured for” or “distributed by”). ARB has developed an applicability questionnaire to assist in determining Responsible Parties.
Responsible Parties must submit the following information through ARB’s online reporting tool for Survey submissions.
Impacted Products
The consumer product categories covered by the Survey include:
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Failure to comply
The Survey is mandatory for Responsible Parties, with failure to respond subject to fines and civil penalties of up to $1,000 per violation. If reported information shows that a consumer product does not comply with the applicable VOC limit, ARB may also impose fines or penalties for that violation. I am not aware of any ongoing enforcement with regard to the 2013 survey, as ARB appeared to be more focused on obtaining information and dealing with logistics than punishment – but it may not be the same for 2014, since Responsible Parties have already gone through this once.