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Turning a batch into a product

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Three things decide the shape of a detailing product before the formula does: which category it is in, whether it is diluted, and what sprays it.

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.

References

40 CFR 59.203, Standards for consumer products, within subpart C, the National Volatile Organic Compound Emission Standards for Consumer Products. Paragraph (a) sets the table 1 VOC and table 2 HVOC limits from December 10, 1998; paragraph (b) applies them only after the minimum recommended dilution; paragraph (c) gives FIFRA-registered products a different compliance date. law.cornell.edu
40 CFR 59.202, the definitions for that subpart, which set the product categories by intended use: automotive windshield washer fluid, engine degreaser, general purpose cleaner, laundry prewash and the rest. law.cornell.edu
29 CFR 1910.1200, Hazard Communication, which sets what a shipped container of a hazardous chemical carries and requires a safety data sheet. law.cornell.edu
Written from federal regulation, not from a formulation bench. VOC limits are federal and several states, California notably, run their own consumer product programs on top. Anything here is a starting point rather than clearance for a specific formula or label.