VOC limits

Which category you are in, and why the description decides it

Updated October 2026

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The definitions are specific So two descriptions can mean two limits Multi-purpose products are the awkward case The description lives in more places than the label FIFRA products sit differently again Write down which category you believe you are in When two categories could fit References

The limits are per category and the categories are defined by what the product is for, which makes your own description a regulatory input.

The definitions are specific

Section 59.202 defines the terms: automotive windshield washer fluid means a liquid designed for use in a motor vehicle windshield washer system, engine degreaser means a cleaning product designed to remove grease and grime from the external surfaces of an engine, general purpose cleaner means a product designed for general all-purpose cleaning. Each turns on intended use.

So two descriptions can mean two limits

A product described as a general purpose cleaner and the same product described as an engine degreaser may face different numbers. That is not a loophole to exploit so much as a reason to be clear and honest about what you are selling.

Multi-purpose products are the awkward case

A detailing spray marketed for wheels, trim, engine bays and interiors is inviting several categorizations at once. Narrowing the claimed use is often the simpler path, and it usually makes for better marketing anyway.

The description lives in more places than the label

Packaging and accompanying literature are named in the dilution provision, and a product description on a website or a listing is how most buyers encounter it. Consistency across all of them is worth maintaining deliberately.

FIFRA products sit differently again

The regulation gives consumer products registered under FIFRA a different compliance date for the VOC standards. If a product is both a pesticide and a consumer product, that interaction is worth establishing early.

Write down which category you believe you are in

With the reasoning, kept with the formula. It is the question somebody will ask, and a recorded decision is a better answer than reconstructing one later.

When two categories could fit

A product that cleans an engine bay and the wheels around it can read as either an engine degreaser or a general purpose cleaner. The definitions turn on intended use, so the use you market is the use that decides, and writing down which one you chose is what makes the decision reviewable later.

References

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

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.