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PLZ Aeroscience greatly values your business! We work hard to provide you with high quality, compliant products.

Many states have restrictions on the volatile organic compounds or ‘VOCs’ that may be contained in products. Most of our products are VOC compliant in all 50 states, however, some PLZ products are prohibited for sale in certain states and customers must only resell those products in states where they are compliant.

To find state-by-state compliance information for PLZ-branded products, visit the VOC Compliance Guides below. Find the PLZ product on the matrix to determine in which states the product can be sold and where it is not compliant.

For more information on VOC regulations, please refer to PLZ’s VOC Technical Brief

PLZ hopes that this information helps you navigate the complex state regulations that apply to our products. If you have any questions, please contact your salesperson.

Thank you for your continued business!

History:

The aerosol industry moved to the use of HFC-134a propellant as a non-flammable alternative to Freon 22, which was being phased out due to ozone depleting potential.  Since then, HFC-134a has been used for many applications that call for a non-flammable propellant, such as air dusters, electronic and electrical cleaners and non-flammable adhesives.

In 2016, the U.S. EPA published the Significant New Alternatives Policy (SNAP) rules that would have severely limited the use of HFC-134a to only uses it considered essential.  The Federal SNAP rules were halted due to legal challenges and never became law.  Since that time, several States have enacted their own rules that are similar to the EPA SNAP rule.  California was the first to do so and other states have also followed suit.

Why are restrictions being imposed?

The short answer is that the Global Warming Potential (GWP) of HFC-134a is significant and there are replacement gases available that have less environmental impact.  The EU has banned most uses of HFC-134a.

What is our purpose in providing this information?

This Technical Brief is intended to make sure that our customers are aware of the rules restricting the use of HFC-134a so that measures can be taken to restrict sales where necessary.

Even for products that are allowed under the exempted uses, compliance actions in some states may be required.  For example, some of the states require that 134a be listed on the product Safety Data Sheet (SDS) in Section 3.  The State of Washington requires that 134a be included on the product label as well as the SDS.

The states of Colorado, Delaware, Maryland and Massachusetts require an explanation of the date coding system be submitted.

Learn More: HFC134a Technical Brief 

Lilial or BMHCA is a widely used fragrance ingredient  that currently must be labelled as an allergen in the EU if present at greater than 0.01% in rinse-off products and 0.001% in leave-on products.  Its scent is described as a Lily of the Valley aroma, and is used synthetically in a variety of beauty products, including perfumes, shampoos, deodorants, tanning lotions and hairstyling products as well as non-cosmetic products, such as household cleaners and detergents.

 

What new restrictions are being imposed?

Lilial recently went through a Carcinogenic, Mutagenic, toxic to Reproduction (CMR) reclassification.  It was listed on Annex VI as a reprotoxic category 1B substance.

Article 15 of the EU Cosmetic Products Regulation (CPR) prohibits substances classified as  CMR under the Classification, Labeling and Packaging (CLP) Regulation from being used in cosmetic products, unless a specific exemption is granted.  Lilial does not meet the criteria for exemption.

Subsequently,  the EU Commission will include Lilial on Annex II (prohibited substances) of the Cosmetic Product Regulation via the fourth CMR Omnibus Regulation, expected to apply from 1 March 2022.  All products containing Lilial must be off the shelf by this date.

The International Fragrance Association (IFRA) tried to limit the ban unsuccessfully and, so far, this restriction does not apply in the US.

Recent studies have shown that Florosa can replace Lilial for the formulation of daily fragrances, and the synthesis of Florosa is the simplest and environmentally friendly alternative. There are other replacements on the market as well.

Learn More: EU Ban on the use of Butylphenyl Methylpropional