Early in 2020, Environment and Climate Change Canada presented the results of a study that compared the actual VOC content in products sold in Canada to various models used in the United States, including CARB 2019 and OTC Phase II. At the time, CPCA submitted comments recommending a phased-in adoption of OTC Phase II limits, stating that it took several years for all U.S. states to officially move from OTC I to OTC II, but noting that not all U.S. states have yet done so. Additionally, CPCA noted that most of the impact of adopting U.S. CARB rules will be on specialty products such as maintenance enamels and specialty primers that serve specific needs, and are difficult and costly to reformulate.
In December 2020, government officials shared their intent to adopt CARB 2019 VOC limits, mainly because OTC indicated they would be moving forward to adopt CARB-2019 limits in Phase 3. This was done as studies showed that alignment with CARB 2019 would provide significant reductions of up to 7.7Kt of VOC emissions in Canada. A formal consultation of the proposed amendment to Canada’s Architectural VOC Regulations is planned later in the Spring of 2021. Regulators specifically asked CPCA to provide more detailed information on all product categories that would present problems for the paint industry under the proposed new limits; and to further explain how formulators expect their conversion to lower VOC limits will be technically challenging. CPCA subsequently distributed a survey to members and compiled the technical information from several architectural members pointing to roughly 18 category limits deemed to be particularly problematic for the coatings industry. This feedback was shared with regulators, and CPCA held a meeting in March to discuss these, and other issues, with officials before the formal consultation takes place.