Volatile Organic Compounds (VOCs) are a large group of organic chemicals that have high vapour pressure at room temperature. This characteristic allows them to evaporate easily into the atmosphere, contributing to air pollution and potentially causing health issues. VOCs are found in many everyday products, including cosmetics, paints, and cleaning agents. In the context of cosmetic products, VOCs are typically ingredients that can evaporate during application or use, such as fragrances, solvents, and preservatives. These compounds can affect indoor air quality and may have adverse effects on human health, including respiratory issues and skin irritation.
The main motivation for controlling them is that they are a key component of smog, which is probably why the place with the strongest regulations is California, which has the kind of geography that lends itself to smog production and lots of cars. The levels used in cosmetics don’t really contribute to this problem, but regulations are regulations and can’t be ignored.
The first step is to decide what a VOC actually is and whether your product contains any. Here are some examples that might help characterise them.
- Butane – Propellant in aerosols like hairsprays and deodorants.
- Propane – Another propellant in aerosol products.
- Ethyl Acetate – Solvent in nail polish and fragrance products.
- Benzyl Alcohol – Used as a preservative and fragrance in creams and lotions.
- Formaldehyde – Restricted as a preservative, often found in hair treatments and nail hardeners.
- Methanol – Rare in cosmetics but can be found in trace amounts in some denatured alcohols.
- Toluene – Historically used in nail polish, though less common now due to safety concerns.
- Cyclopentasiloxane – A conditioning agent in hair and skin care products.
- Limonene – Fragrance ingredient often found in citrus-based products.
- Hexane – Sometimes used in manufacturing but rarely in finished cosmetics.
At present, the EU Cosmetics Regulation ((EC) No 1223/2009) does not set specific limits for volatile organic compounds (VOCs) in cosmetic products. However, it does require that all cosmetic products are safe for human health when used as intended or in reasonably foreseeable ways. This means that any VOCs used in cosmetics should not pose a health risk to consumers.
Some VOCs are regulated through ingredient restrictions. For example, formaldehyde and certain preservatives that release formaldehyde are restricted due to concerns about their potential to cause cancer or allergic reactions.
In the UK, the same rules apply, as the UK continues to follow the EU Cosmetics Regulation. However, the UK government has indicated that the situation is under review, which could potentially lead to the introduction of specific VOC limits for cosmetics in the future.
Switzerland, however, does levy a tax on products containing volatile organic compounds (VOCs). This tax is known as an “incentive tax” and is applied to substances and products that contain VOCs due to their potential negative environmental impact, such as contributing to ground-level ozone formation. The tax rate is set at 3 Swiss francs per kilogram of VOCs. This tax is levied on imports into Switzerland, and there are specific regulations regarding which substances and products are subject to this tax. Products with a VOC content not exceeding 3% or those not included on the positive list are exempt from the tax. For a personal care product even with a high level of VOCs this isn’t a huge duty but it does mean you’ll need to declare their level. This is a bit time consuming, but their positive list indicating the chemicals that they consider to be VOCs that helps a bit.
In the United States, regulations regarding Volatile Organic Compounds (VOCs) in cosmetic products are primarily governed by the Environmental Protection Agency (EPA) and the Food and Drug Administration (FDA). The EPA focuses on the environmental impact of VOCs, while the FDA ensures the safety of cosmetic products for consumers. The EPA’s regulations on VOCs are part of the Clean Air Act, which aims to control air pollution on a national level. The Act mandates that states develop State Implementation Plans (SIPs) to meet the National Ambient Air Quality Standards (NAAQS). These plans often include limits on the VOC content in various consumer products, including cosmetics, to reduce ozone formation and improve air quality. The FDA, under the Federal Food, Drug, and Cosmetic Act (FD&C Act), oversees the safety and labelling of cosmetics. While the FDA does not have specific regulations solely targeting VOCs in cosmetics, it requires that all ingredients, including VOCs, be safe for use and properly labelled. Manufacturers must ensure that their products do not contain harmful levels of VOCs that could pose risks to consumers.
In addition to federal regulations, individual states may impose their own restrictions on VOCs in cosmetic products. California, for instance, has stringent VOC regulations under the California Air Resources Board (CARB). CARB sets specific VOC limits for various categories of consumer products, including personal care items, to mitigate air pollution and protect public health. Compliance with these regulations requires cosmetic manufacturers to carefully monitor and control the VOC content in their products. This often involves reformulating products to reduce VOC levels, using alternative ingredients, and implementing advanced manufacturing processes. Companies must also stay updated with both federal and state regulations to ensure their products meet all legal requirements. The rationale behind these regulations is to balance the need for effective and appealing cosmetic products with the necessity of protecting public health and the environment. High levels of VOCs can contribute to the formation of ground-level ozone and smog, which have adverse effects on air quality and respiratory health. By regulating VOC content, authorities aim to minimise these impacts while still allowing for innovation and consumer choice in the cosmetics industry.
CARB’s regulations on VOCs in cosmetics are detailed in the California Code of Regulations, Title 17, Section 94500-94575. These rules set specific VOC limits for various categories of consumer products, including personal care items such as hair sprays, deodorants, and nail products. For instance, hair sprays in California must not exceed a VOC content of 55% by weight. Nail care products, including nail polish and nail polish removers, are another focus of CARB’s regulations. Nail polish removers, for example, are restricted to a maximum VOC content of 1% by weight. This helps to reduce the inhalation risks associated with VOCs, which can have adverse health effects.
These rules do seem a bit exiguous, and it is hard to see them making much impact on environmental problems or health when think about the volume of cosmetic products produced and consumed compared to the vast scale of the transportation industry. But the other way of looking at it is that products whose sole role is making people look better doesn’t really justify doing any damage in the process.
If you need help with VOC compliance, get in touch.
References
RS 814.018 Ordonnance du 12 novembre 1997 sur la taxe d’incitation sur les composés organiques volatils (OCOV)
