VOC limits

The dilution rule, and why your instruction matters

Updated October 2026

On this page8

What it says Which means a concentrate is measured diluted And the minimum dilution is the one that counts The exception closes the obvious loophole Which makes the instruction a compliance document And it has to be stated specifically Treat the instruction as a controlled document References

This is the provision that makes this property unusual: the limit is applied to the product after dilution, so what you tell people to do is part of the measurement.

What it says

Where the label, packaging or accompanying literature specifically states that the product should be diluted before use, the VOC content limits apply to the product only after the minimum recommended dilution has taken place.

Which means a concentrate is measured diluted

A product sold at ten times strength with a clear instruction to dilute is assessed as the diluted liquid, not as what is in the bottle. That is a genuine and intended consequence, and it is why concentrates are common in this category.

And the minimum dilution is the one that counts

If you recommend a range, the weakest dilution in it is the relevant one. The regulation is measuring the most concentrated way you told somebody to use the product, which is the conservative reading and the right one.

The exception closes the obvious loophole

Minimum recommended dilution expressly does not include recommendations for incidental use of a concentrated product on limited special applications such as hard-to-remove soils or stains. So a note saying to use it neat on stubborn marks does not reset the calculation.

Which makes the instruction a compliance document

Changing a dilution ratio on the label, or adding a line about using it stronger for tough jobs, can change where the product stands. That makes label copy something to review against the formula rather than tune for marketing.

And it has to be stated specifically

The provision applies where the label specifically states the product should be diluted. A vague suggestion is not the same as an instruction, and a product relying on this provision needs the instruction to be clear and prominent.

Treat the instruction as a controlled document

If the limit applies after the minimum recommended dilution, then the wording of that instruction is part of the compliance position and not marketing copy. Changing a ratio, adding a stronger-mix suggestion or simplifying the directions all change the number the product is measured against.

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

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.