Turning a batch into a product
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Decide which category it is
The VOC limits are set by product category, and the categories are defined by intended use in the regulation. A product that could be described two ways may face two different limits, so settling what it is for is the first regulatory decision rather than a marketing one.
Decide whether it is sold diluted or concentrated
Because the limit applies after the minimum recommended dilution. A concentrate with a clear dilution instruction is measured differently from a ready-to-use product, and that changes what the formula may contain.
Write the dilution instruction carefully
It is the thing the limit is applied to. An instruction with a range in it, or one suggesting concentrated use for stubborn marks, interacts with the rule in ways that need thinking about rather than improvising.
Pick the sprayer against the formula
A trigger sprayer has a viscosity range and the parts that touch the product have to resist it. Solvents and silicones attack some materials, and the failure shows up weeks later as a sprayer that has gone stiff or leaks.
Then the label
Net quantity, ingredients where required, the responsible party, hazard information where the product is hazardous, and the directions. For a chemical product the safety data sheet accompanies it.
Test the assembled, filled unit
Real formula, real bottle, real trigger, sprayed until the bottle is empty and then left for a few weeks. Almost every failure in this property shows up in that test and almost none shows on a bench.
The order of these decisions matters
Category, then dilution, then claims, then closure. Taken in that order each answer narrows the next; taken backwards you choose a sprayer, discover the formula attacks it, and reopen a question you thought was closed. Writing the decisions down as you make them is what keeps the sequence from unravelling.