CARB 2% Fragrance Exemption Survey
CARB has requested that industry stakeholders complete the following survey about the proposed elimination of the existing 2% fragrance exemption by 2031

ICMAD will compile the responses of our Members and present the results to CARB.  

CARB regulates cosmetic and personal care products containing VOCs (Volatile Organic Compounds). 

The current rulemaking proposals cover several categories: hair finishing spray, hair shine spray, dry shampoo, and personal fragrance products. If you have any questions about the CARB VOC proposals, please contact Meredith Petillo: mpetillo@icmad.org
 
Manufacturer Survey - Sunset of 2% Fragrance Exemption in 2031

The California Air Resources Board (CARB)'s volatile organic compound (VOC) standards for most categories do not apply to fragrances up to a combined level of 2% by weight (Consumer Product Regulation Section 94510 9(c)). At public meetings on November 7, 2019 , March 10, 2020, and April 14, 2020, CARB staff proposed sunsetting this 2% fragrance exemption for most categories in 2031 as part of CARB's Consumer Product Regulation amendments to help California meet its air quality and public health goals. Your completion of this survey will inform CARB 's analysis of potential  technical challenges and economic costs of this draft proposal as part of our regulatory amendment process.

To the greatest extent possible, please complete this form to provide CARB staff with the requested information. Where information is used in our public rulemaking documents, CARB will summarize the data we receive in aggregated form without individual company identification. Please note that you do not necessarily have to fill out the entire survey; you may choose to submit information for some questions and not others. You are also welcome to provide the requested information, or any additional cost information, in other formats (such as MS Excel, Word, etc.). This survey covers three potential cost scenarios for elimination of the fragrance exemption:

* A company must identify the VOC content of fragrance in a product, but no reformulation is necessary to continue to meet the applicable VOC content standard;

* A company must reformulate a product, and does not anticipate significant technical feasibility challenges to meet the applicable VOC content standard without the fragrance exemption; and

* A company must reformulate a product, and anticipates significant technical feasibility challenges to meet the applicable VOC content standard without the fragrance exemption.
 
1.
Person/Company completing this survey:

First Name:
Last Name:
Company Name:
Work Phone:
Email Address:
emailaddress@xyz.com
State/Province
(US/Canada):

2.

Does your company utilize the 2% fragrance exemption for consumer products sold in California?

YES
NO
NOT SURE
3.

Does your company typically know the VOC content of fragrances it uses in consumer products?

YES
NO
4.

Do you believe your fragrance suppliers are (or would be) willing to share the VOC content of their fragrances with you?

YES
NO
UNKNOWN
Cost to Obtain Fragrance VOC Content Information (No Reformulation Necessary)


 
5.

What do you anticipate would be the cost (in personnel time, computer support, or any other cost) of obtaining the VOC content of fragrances from your fragrance suppliers?

N/A
$0 - $500
$501 - $1,000
$1,001 - $5,000
>$5,000 (please specify amount)
  • Comment:

  • 500 characters left.
Cost for a Product where Elimination of the 2% Fragrance Exemption Would Not Pose Technical Feasibility Challenges

Please identify the anticipated range of additional cost to reformulate an existing product (or formulate a new product) without the 2% Fragrance Exemption in categories where this is unlikely to pose technical feasibility challenges.
 
6.

Product Development: If the fragrance exemption is eliminated in 2031, what would be the anticipated cost to reformulate an existing product, or the additional cost to develop a new product that meets the applicable VOC standard?  This includes additional cost to reformulate the contents and specify the packaging and raw materials. 

N/A
$0 - $1,000
$1,001 - $5,000
$5,001 - $10,000
>$10,000 (please specify amount)
  • Comment:

  • 500 characters left.
7.

Testing: What would be the anticipated cost of additional stability, efficacy, or safety testing for a given product due to fragrance exemption elimination?

N/A
$0 - $1,000
$1,001 - $5,000
$5,001 - $10,000
>$10,000 (please specify amount)
  • Comment:

  • 500 characters left.
8.

Market Research and Advertising: What would be the anticipated cost of additional focus group testing, surveys, advertising, and development of other new marketing materials for a given product due to fragrance exemption elimination?

N/A
$0 - $1,000
$1,001 - $5,000
$5,001 - $10,000
>$10,000 (please specify amount)
  • Comment:

  • 500 characters left.
9.

Other Costs: PLEASE SPECIFY

N/A
$0 - $1,000
$1,001 - $5,000
$5,001 - $10,000
>$10,000 (please specify amount)
  • Comment:

  • 500 characters left.
Cost for a Product Where Elimination of the 2% Fragrance Exemption Would Pose Technical Feasibility Challenges


 
10.

Are there product categories (such as Hair Finishing Sprays) for which you anticipate technical feasibility challenges meeting the applicable VOC content standard if the 2% Fragrance Exemption is eliminated in 2031?  


If so, please identify them below:

 

1000 characters left.
11.

Would you be willing to discuss with CARB staff your company's potential reformulation challenges for the product categories identified in response to the above question?

YES
NO
Please identify the anticipated range of additional cost to reformulate an existing product (or formulated a new product) without the 2% Fragrance Exemption in categories where this would likely pose a significant technical feasibility challenge.


 
12.

Product Development: If the fragrance exemption is eliminated, what would be the anticipated cost to reformulate an existing product, or the additional cost to develop a new product that meets the applicable VOC standard? This includes reformulating the contents and specifying the packaging and raw materials.

N/A
$0 - $1,000
$1,001 - $5,000
$5,001 - $10,000
$10,001 - $25,000
>$25,000 (please specify amount)
  • Comment:

  • 500 characters left.
13.

Testing: What would be the anticipated cost of additional stability, efficacy, or safety testing for a given product due to fragrance exemption elimination?

N/A
$0 - $1,000
$1,001 - $5,000
$5,001 - $10,000
$10,001 - $25,000
>$25,000 (please specify amount)
  • Comment:

  • 500 characters left.
14.

Market Research and Advertising: What would be the anticipated cost of additional focus group testing, surveys, advertising, and development of other new marketing materials for a given product due to fragrance exemption elimination?

N/A
$0 - $1,000
$1,001 - $5,000
$5,001 - $10,000
$10,001 - $25,000
>$25,000 (please specify amount)
  • Comment:

  • 500 characters left.
15.

Other Costs: PLEASE SPECIFY

N/A
$1 - $1,000
$1,001 - $5,000
$5,001 - $10,000
$10,001 - $25,000
>$25,000 (please specify amount)
  • Comment:

  • 500 characters left.
16.
If the 2% fragrance exemption sunsets, how do you anticipate this will impact existing or new product formulations? Select all that apply.
Utilize less fragrance
Utilize less non-fragrance VOCs
Not sure
Other  
  • Comment:

  • 500 characters left.
17.

Does your business fit the definition of a small business below?


A small business is defined as a business that is all of the following:

(1) independently owned and operated;

(2) not dominant in its field of operation and;

(3) has fewer than 100 employees

YES
NO
18.

Is there any other information you would like to provide?

 

1000 characters left.