Article by: Perry Romanowski

californiaEnvironmental rules are often strange. Here is a story where L’Oreal was fined over $160,000 for selling a product that contained 55% volatile organic compounds (VOC). According to California law companies are restricted in the amount of VOC that they can have in their formulas.

While the folks at L’Oreal thought they were complying with the law they weren’t. It wasn’t because of their formula but because of what they claimed about their formula. The products were sprayable starch and according to regulations they can only have 6% VOC content, not the 55% VOC content which is the regulations for hair styling sprays. Since they didn’t list anywhere on their packaging the claim “finish, maintain or hold previously styled hair” they are subject to the 6% level. Oops.

VOC levels

This is something that many people don’t realize. Even products that are not sprays are subject to VOC limits according to the California regulations. So if you have the idea of using alcohol (ethanol) as your primary preservative, you may be in violation of VOC rules.

Here are VOC limits for some common products. You can find more limits here.

Astringent / toner = 35% VOC
Nail polish remover = 1% VOC
Insect Repellant = 65% VOC
Temporary hair color = 55% VOC
Shaving cream = 5% VOC
Shaving gel = 4% VOC
Fragrance (less than 20% fragrance) = 75% VOC
Fragrance (more than 20% fragrance) = 65% VOC
Hair styling product = 6% VOC
Hair finishing spray = 55% VOC
Hair shine spray = 55% VOC
Hair Mousse = 6% VOC
General purpose cleaners (body wash, shampoo, etc) = 0.5% VOC

As you can see it can get a bit complicated. If you have questions about it this is one of those things that are best to consult an expert in the regulatory matters of California.


  1. Avatar
    Dr Harriette Smithers

    solved: not selling our products in california anymore

    1. Avatar
      Perry Romanowski

      Well, you have to hope that none of your products get accidentally diverted to California and put on sale. They’ll come after you.

  2. Avatar
    Tony Beckerman

    I’m amazed at how many formulators are not aware of these VOC rules. Good info.
    Perhaps a product development consultant is required. I’m available

  3. Avatar

    Interesting post. Can you do a blog post on how to determine VOCs in your final product? I know there are several methods out there (CARB, SCAQMD 304, 313, etc).

    1. Avatar
      Perry Romanowski

      Good idea. I’ll work on putting one together.

  4. Avatar

    Interesting. Does this mean you can’t make a hairgel with 10% EtOH in the US?

    1. Avatar
      Perry Romanowski

      You can make it in the US, you just can’t sell it in California.

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