The Mariposa Blog
Tuesday December 9, 2014
A Big Lump of Coal from CARB
Please see notification from the California Air Resources Board.
I can not even begin to express the nightmare this will be for our customers. And failure to comply, $10,000 per day?
What will it be next?
December 9, 2014
CARB is requiring all consumer and commercial product companies, including personal care product companies to complete a 2013 Consumer and Commercial Products Survey
The California Air Resources Board (CARB) is requiring all consumer and commercial product companies, including personal care product companies, whose names appear on product labels (a "Responsible Party") to complete a 2013 Consumer and Commercial Products Survey. The Survey requires Responsible Parties to report detailed information for each product sold or supplied for use in California during Calendar Year 2013, including product formulas and unit sales. For Companies that do not have data on the number of units sold in 2013, the Survey allows for various methods of estimating the number of units.
In the past, CARB surveys have been limited to VOC (Volatile Organic Compounds) emitting products, such as hairsprays and styling products. The 2013 Survey, however, applies to all products sold or supplied for use in the state of California, including cosmetic and personal care products. Justification for this broader approach, as well as additional information about the Survey, is available at:
A single representative label for each product must be submitted with the Survey. The Survey allows for grouping of ingredients and products under certain circumstances. Instructions and examples of grouping are in the Survey instructions, available at: http://www.arb.ca.gov/consprod/regact/2013surv/cprt/cprt_instructions.pdf.
Specification of fragrance ingredients are not required. Because formulators of end use products often do not possess specific chemical composition of the fragrance, the Responsible Party is only required to submit the total content of fragrance expressed in percent by weight, the name of the fragrance, fragrance supplier sales number assigned to the fragrance, and fragrance supplier contact information.
Survey responses must be filed electronically using a new electronic Consumer Products Reporting Tool (CPRT). The CARB staff has also developed a Consumer Products Reporting Tool for Formulators (CPRT-F). After entering their data into the CPRT, Responsible Parties will have the ability to export files to send to their formulators. More information on the details of the reporting process are available in the Survey instructions.
Completed 2013 Surveys are due by March 2, 2015. Failure to file a Survey may result in significant fines of $10,000 per violation, per day. CARB staff is currently developing tools for reporting 2014 and 2015 consumer product data. The timing for 2014 and 2015, and their respective reporting requirements, can be found here: http://www.arb.ca.gov/consprod/regact/2013surv/cprt/2013_survey_letter.pdf.
CARB staff will conduct a webinar to go over the CPRT data upload on December 15, 2014.Registration for the webinar is available at https://www1.gotomeeting.com/register/111660040.
For general and Survey related questions, contact David Edwards at (916) 323-4887 firstname.lastname@example.org.
For Survey and CPRT related questions, send an email to email@example.com.
And for specific questions respecting personal care products, you can contact Terri Edwards, (916) 445-3238, firstname.lastname@example.org.
How To Comply with CARB Requirements
January 6 at 4:00p.m. (EST)/1:00p.m. (PST)
$25 per company
Join ICMAD's experts as they explain the requirements for completing the CARB's 2013 Consumer and Commercial Products Survey.
Register online or contact the ICMAD office at 800-334-2623 for more information.
Director of Business Development
Mariposa Labs LLC