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Odor Remover

Odor Remover/Elimination Category or Claim??. CARB has traditionally identified product categories by product purpose:Air freshener

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Odor Remover

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    1. Odor Remover/Eliminator Bryan Ruble Dial Corporation CSPA Household Products Technical Seminar For California Air Resources Board July 27, 2006

    2. Odor Remover/Elimination Category or Claim?? CARB has traditionally identified product categories by product purpose: Air freshener … “sprays, wicks, powders, and crystals, designed for the purpose of masking odors, or freshening, cleaning, scenting, or deodorizing the air.” General Purpose Cleaner… “product designed for general all-purpose cleaning, in contrast to cleaning products designed to clean specific substrates in certain situations.”

    3. Odor Remover/Elimination Category or Claim?? (cont.) Fabric Refresher… “product labeled to neutralize or eliminate odors on non-laundered fabric including, but not limited to, soft household surfaces, rugs, carpeting, draperies…does not include “soft household surface sanitizers…disinfectant…”

    4. PRODUCT STATEMENT OF IDENTITY Federal Trade Commission Consumer Product Safety Commission Environmental Protection Agency

    5. Consumer Products with Odor Removal/Elimination Claims Odor removal/elimination is a specific product benefit/feature, regardless of the product category or form 7/19/06 Proposed Category Definition for odor removal/elimination does not acknowledge the distinction between the category and the specific claim

    6. Consumer Products with Odor Removal/Elimination Claims Categories of products currently making odor removal/elimination/neutralization claims: Air freshener—all forms Fabric Refresher Bathroom and Tile Cleaner General Purpose Cleaner Disinfectant Sanitizers Dual purpose Air Freshener/ Toilet/Urinal Care Disinfectant Carpet and Upholstery Cleaners

    7. Consumer Products with Odor Removal/Elimination Claims These categories are currently regulated by CARB, with the exception of disinfectants and sanitizers (which are included in the CONS-2 proposal) Most restrictive limit, Section 94512 (a), requires that if a product has more than one purpose, the most restrictive VOC limit will apply (does not apply to general purpose cleaners)

    8. Current VOC Limits Air freshener Double phase 25% Single phase 30% Liquids/pump spray 18% (0.5% proposed) Solids/semisolid 3% Bathroom and Tile Cleaner Aerosol 7% (5% proposed) All other forms 5% (1% proposed) Carpet and Upholstery Cleaners Aerosols 7% Non-aerosols (dilutables) 0.1% Non-aerosols (RTU) 3%

    9. Current VOC Limits Disinfectant Aerosol 70% proposed Liquid 5% proposed Dual purpose Air Freshener/Disinfectant—60% Fabric Refresher Aerosol 15% Non-aerosol 6% Sanitizer Aerosol 70% proposed Liquid 5% proposed

    10. Current VOC Limits Toilet/Urinal Care Aerosols 10% Non-aerosols 3% With the application of the most restrictive limit, all of these products would be required to reduce to 0.5%, which is technically infeasible for all of these products

    11. 2003 Survey Data 2003 survey data does not include a significant percentage of products currently on the market using an “odor remover” or “odor eliminator” claim (most likely because there was no definition, and most products are already regulated) Most of the products in the 2003 survey would be in the air freshener category and would be exempt based on the proposed definition End result: A significant number of products on the most recent list should be moved to other categories

    12. Recommendations Therefore, CSPA proposes eliminating the proposed category of “odor remover/ eliminator” Justification: virtually all the products making such claims are already regulated by CARB have already achieved significant reductions Odor remover/eliminator is a claim NOT a category

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