EPA Publishes Amendments to National Aerosol Coatings Rule in Response to ACA Petition

On Jan. 17, the U.S. Environmental Protection Agency (EPA) published amendments to the national aerosol coatings rule. EPA’s national rule establishes reactivity-based emission standards for the aerosol coatings category (aerosol spray paints) under the Clean Air Act.

This action ensures a consistent regulatory framework and aligns with the California Air Resources Board’s aerosol coatings rule, which will help aerosol coatings manufacturers with streamlined compliance.

EPA’s final amendments are the direct result of three petitions for rulemaking submitted by ACA, and an eight-year advocacy campaign on behalf of the coatings industry to convince EPA to adopt changes to the national rule so that it largely matches the CARB rule and is informed by the most up-to-date and accepted science. This final action will minimize the undue compliance burdens that the divergent regulatory schemes have created for the aerosol coatings industry. Until these amendments were adopted, manufacturers were required to comply with different standards in California and use different Maximum Incremental Reactivity (MIR) values in order to calculate compliance.

Notably, the final rule features the following changes, for which ACA advocated:

• Updated product-weighted reactivity limits by coatings category that align completely with CARB’s coatings categories (see Table 1);
• Updated MIR values for several aerosol coatings compounds that align with CARB’s Table of MIR Values (see Tables 2A, 2B & 2C);
• New compounds and reactivity factors in Tables 2A, 2B & 2C to align with CARB’s Table of MIR Values;
• Revised default reactivity value (18.50 g O3/g VOC);
• New and updated definitions to better align with CARB’s rule (when appropriate and feasible); and
• Addition of electronic reporting provisions.

The compliance date for the final amended rule is July 17, 2025; however, ACA is seeking clarification on any implied sell-through provisions associated with the rule, as well as any potential impact from President Trump’s Jan. 20 Executive Order pertaining to a federal regulatory freeze. Please note that ACA and others consistently advocated for a 2-year sell-through period to comply with the new requirements.

EPA notes that in the interim six months, all regulated entities are subject to the national aerosol coatings rule in its current form but may elect to start complying with the amended aerosol coatings rule. This means that regulated entities, including those that are currently in compliance with CARB’s aerosol coatings rule, may elect to begin complying immediately with the new limits, corresponding reactivity factors, and other rule provisions.

In the coming weeks, ACA will host a webinar on the amendments and provide additional written analysis of the amendments to aid member understanding and compliance.