The check, before the formula is final
Updated
On this page8
One: which category is this product in?
The VOC limits are set per category and the categories are defined by intended use in 40 CFR 59.202. Write down which one you believe applies and why, because that decision sets the number you are formulating against.
Two: is it diluted before use, and does the label say so?
If it specifically states the product should be diluted, the limit applies after the minimum recommended dilution. If you intend to rely on that, the instruction has to be clear and you must not undercut it with a note about neat use on stubborn marks.
Three: does anything claim to act on microorganisms?
Sanitizes, disinfects, antibacterial, kills germs. On a surface that is an EPA antimicrobial pesticide claim, and it brings registration with it. Check the website and the listings, not just the bottle.
Four: will the sprayer survive the formula for a year?
Not for an afternoon. Gasket, piston, dip tube and spring all meet the product, and chemical attack is a slow failure that reaches customers. Fill it, use it, and leave it standing for a month before deciding.
Record the answers with the formula
Category, dilution, claims and closure, kept together. If any one of them changes later, the others have to be rechecked, and a written record is what makes that possible rather than theoretical.
Re-run it when anything moves
A reformulation, a new size, a change of sprayer supplier or a new marketing line. The check costs minutes and the failures it catches cost a production run.
Four questions, one page, kept with the formula
None of them needs a laboratory and three of them are about words. That is the whole point: the failures in this category are overwhelmingly decisions about category, dilution and claims, made quickly and then built on for a year.