CPCA Discusses Federal VOC Reduction Agenda for the CASE Sector

Introduction

The Canadian Paint and Coatings Association (CPCA) has submitted comprehensive industry comments on the Canadian government’s recently published discussion paper on the Federal Agenda for Reduction of VOC Emissions from Consumer and Commercial Products (2021-2028).  The Discussion Paper identifies potential measures to be pursued by the Government towards achieving further VOC reductions in certain key consumer and commercial products. Among the targeted categories, CPCA’s comments are focused on the segments below which impact the paint, coatings, adhesives, and sealants market. The Government’s estimated VOC emissions from those categories are given in kilotonnes (kT) of volatile organics.

• • • Architectural Coatings (19.1 Kt) (Incorrect value – see below)
    • Industrial Adhesives (10 Kt)
    • Industrial Aerosol Coatings (9.1 Kt) (Incorrect value – see below)
    • Automotive Refinish Coatings (4 Kt)
    • Cars, Vans, Light Trucks Assembly & Auto Parts Coatings (3 Kt)
    • Plastic, Rubber, Leather and Glass Coatings (2 Kt)

Following consultations on the Agenda, the Government intends to publish a notice of intent describing proposed additional control measures to reduce VOC emissions from these products. These measures would be developed and implemented by 2028.

In addition to concerns related to the estimated VOC emission figures above which incorrectly portray the relative contribution of some coatings sectors, the Discussion Paper does not consider the continuing and considerable efforts already taken by the North American and Canadian coatings industry to reduce VOC emissions in multiple product categories. CPCA developed detailed comments addressing the proposed approach for each of the sectors in question above.

Architectural Coatings

The architectural sector is the largest contributor to VOC emissions among coatings categories, however the 19.1 kT number stated in the Agenda is inaccurate. CPCA pointed out that the correct number is 11.7 kT in 2018 as determined by a government contractor’s own estimate which was shared with CPCA in early 2020. Furthermore, the Discussion Paper fails to acknowledge the fact that significant VOC reductions have been continuously achieved by the Architectural sector (1.1 kt/year between 2015 and 2020) in the absence of any additional regulatory pressures. These reductions are a direct result of producers’ individual efforts to supply low or zero-VOC products to consumers in response to current market demand and consumer trends.

This trend means that before the revised Architectural VOC regulations are expected to come into effect in Canada (2023-2024), an additional 4.3 Kt of VOC emissions reductions is expected to be achieved completely independently of any further government action. Overall, 8.6 kt of VOC emissions is expected to have been eliminated between 2014 and 2024. This performance exceeds the 7 Kt in VOC emissions reduction that ECCC hopes to achieve by adopting strict CARB 2019 VOC limits. On this evidence, it makes little sense for Government to proceed with further restrictions on the Architectural sector.

CPCA also reiterated yet again that California-based CARB rules are not suitable for Canada’s much colder climate and will lead to freeze-thaw performance issues for multiple solvent-borne product categories. Furthermore, 2019 CARB SVOC limits for have yet to be implemented by any California Air Districts and only 5 US States have adopted the OTC Phase II Model rule (which is based on the 2007 CARB limits. These States have not even considered as of yet adopting OTC Model III which would be similar to CARB 2019. In proposing to adopt CARB 2019, Environment Canada is jumping far ahead of Canada’s largest trading partner which will cause significant misalignment and negatively affect cross-border trade.

Industrial Adhesives and Sealants

Industrial adhesives and sealants were estimated to emit approximately 10kT of VOCs in 2018, the second largest source following architectural coatings. Canada currently has no instrument in place to limit the VOC content in industrial sectors using adhesives and sealants such automotive, aeronautics, electronics, packaging, wood, furniture and plastics.

Environment Canada (ECCC) is proposing to implement the 2006 OTC Model Rule for Adhesive and Sealant Applications that limits VOC emissions from industrial and commercial adhesives, sealants and primers, which is also implemented in 12 US member states. In the absence of current instruments, CPCA members support the adoption of OTC rules provided that ECCC work closely with the Caulks, sealants and adhesives manufacturing segment of the coatings industry in Canada and in the US to ensure an OTC rule consistency that is optimum for the Canadian industry in terms of technical capabilities and timeline.

Industrial Aerosol Coatings

In this segment, similar to Architectural coatings, CPCA pointed out serious inaccuracies in the ECCC’s stated figure for VOC emissions in 2018. A 2012 report from ECCC’s own contractor, stated that the entire aerosol coatings market amounts to 4kT supplied to Canada. Given that the industrial aerosol segment is approximately 20% of the entire market, a value of 1kT would be expected in 2018 since the market has not grown or decreased significantly in those six years. Instead, the Discussion Paper states a value of 9 kT which must be explained before moving forward with any regulatory approach.

Furthermore, the same 2012 Government report showed that a high percentage of Canadian commercial and industrial aerosol paint products sold on the market were already compliant with the US CARB aerosol rules and that there were no significant VOC reductions expected from the adoption of CARB VOC regulations in Canada. CPCA questioned why ECCC believes that the current situation in Canada would be any different now, especially since the Canadian aerosol coatings market is still largely dominated by products originating from the US and the fact that US EPA adopted the CARB model in 2012. CPCA recommended that ECCC concentrate its efforts on monitoring and regulating other consumer and commercial sectors where they might actually achieve meaningful VOC emissions reduction going forward.

Automotive Refinish Coatings

As indicated in the Discussion Paper, the Auto Refinish (AR) paint sector does not emit more than 4 kt of VOCs. Again, this is a value that represents less than 1% of Canada’s total emissions from all sources. CPCA reminded ECCC that 90% of all AR paint sales in Canada are done by 5 multinational manufacturers based in the United States. US rules are based on the 2011 OTC Model Rule for Mobile Equipment Repair and Refinishing (MERR).  

CPCA also pointed out that this sector has seen a significant downturn during the pandemic with reductions in capacity and sales volume. CPCA made two recommendations to ECCC regarding the AR sector:

• Further refine the potential VOC emissions reduction from the AR sector prior to deciding to proceed with the implementation of OTC MERR 2011 in Canada.
• Delay conducting a study until 2022 when companies will have had more time to recover from the pandemic downturn and delay final publication of any amended VOC AR regulations until 2024 or later should they be deemed implementing.

Cars, Vans, Light Trucks Assembly & Auto Parts Coatings

According to the Discussion Paper 8 kt of VOCs were emitted from vehicle manufacturing (engines, parts, assembly, painting); of these, 3 kt were specifically associated with parts coatings. CPCA clarified that VOC content for automotive OEM and parts formulations are generally the same in US and Canada.  For the most part, paint companies do not formulate based on a destination in the US or Canada, but rather on the specific OEM (ex. car manufacturer) and site.

Therefore, any proposed approach needs to look at total VOC emissions originating from automotive OEM paint applications and emission control techniques in automobile and light-duty assembly plants in order to determine the path forward. Many US guidelines may be largely implemented in Canadian assembly plants and a phased-approach or an environmental performance agreement with individual assembly plants may be a more effective path forward to ensure further VOC emission reductions rather than federal/provincial guidelines.

CPCA also pointed out that a significant amount of lead time is required for new OEM/parts formulations in order to test for quality and durability.  This timing will also need to be considered when developing the federal/provincial VOC emission control approach for this sector.

Plastic, Rubber, Leather and Glass Coatings

ECCC’s proposed actions are to gather information on the current state of provincial requirements to control VOC emissions from plastic, rubber, leather and glass product coatings. As these sources are typically regulated by provincial jurisdictions, ECCC plans to engage in discussions with provincial authorities to gauge the need and interest in developing a federal measure.

CPCA supports the proposed approach but once again highlighted that any emissions reductions from this sector would be minimal as admitted by ECCC in the Discussion Paper which estimated the total 2018 emissions at only 2 kT out of a total of 482 kT in Canada from all sources.

Conclusion

CPCA was pleased to have an opportunity to comment on the discussion paper describing Government’s approach to reducing VOC emissions from consumer and commercial products. Many issues were identified which need to be addressed before the federal government can give any consideration to moving forward with new VOC limits for coatings in Canada. CPCA’s comments highlight the fact that industry continues to achieve significant VOC emission reductions in the absence of additional unnecessary regulatory pressures. CPCA also pointed out several inaccurate data points reported in the Agenda and asked ECCC to explain the incorrect numbers erroneously used as justification for stricter limits.  Technical challenges associated with aligning with CARB regulations for architectural coatings were yet again re-stated and CPCA also pointed out that several categories identified in the Agenda such as automotive refinishing, auto-parts coating and plastic/rubber coatings would not lead to significant VOC reductions even if they are to be controlled under new or amended future regulations.

CPCA and its members have cooperated with federal government initiatives and regulations to reduce VOC emissions from paints and coatings products in Canada for over four decades. Considerable VOC reductions have resulted from this cooperation and both industry and government should be commended. However, we believe that some of the main directions and timelines expressed in the proposed agenda need to be revised or redirected in accordance with the above recommendations based on the relevant, factual data and real industry concerns expressed herein.

 CPCA members fully support the Government’s intent to harmonize Canadian regulations with some specific US regulations that are aligned and applicable in Canada, as long as existing technologies and alternatives remain reasonably available, accessible and cost-effective. Our members operate on both sides of the border and would particularly benefit from the Government of Canada aligning its future Federal VOC regulations or guidelines with those of the United States, while also ensuring a level-playing field for all in terms of the VOC limits linked to those specific regulations and guidelines.