Short answer
California limits the volatile organic compounds (VOCs) in perfume through the Air Resources Board's consumer products regulation. A "personal fragrance product" — perfume, cologne, body mist, body spray, scented lotion or powder — may contain only a set percentage of VOC by weight, and the fragrance itself does not count toward it: in practice the limit is on the ethanol and other volatile solvents. For non-aerosol products made from 2023 to 2030 the limit is 75% VOC above 7% fragrance and 70% at 7% or less; from January 1, 2031 it is 75% above 10% fragrance and 50% at 10% or less. A classic eau de parfum at 80% ethanol does not comply; a body mist will need far less alcohol from 2031.
What the rule covers
The rule is in Title 17 of the California Code of Regulations, sections 94507–94517, administered by the California Air Resources Board (CARB). It applies to consumer products sold, supplied, offered for sale or manufactured for use in California. Its definition of a personal fragrance product is any product applied to the human body or clothing for the primary purpose of adding a scent or masking a malodor — including cologne, perfume, aftershave, toilet water, lotion, powder, body mist and body spray. It excludes deodorants (which have their own CARB regulation), soaps and shampoos, skin-care products for dryness or irritation, and fragrance products for animals.
A deodorant body spray — a personal fragrance product with 20% or less fragrance designed to be applied all over the body — stays a personal fragrance product unless its packaging says it can be used on the underarms, in which case it is a deodorant under CARB's definitions.
What counts as VOC, and what does not
- VOC is any compound containing carbon, minus a list of exclusions (methane, acetone, certain halogenated compounds and others). Ethanol is a VOC; so are isopropanol and most denaturants.
- The fragrance is exempt. Section 94510(j) says the VOC limits do not apply to any VOC which is a fragrance in a personal fragrance product. CARB defines fragrance as a substance or mixture of aroma chemicals, essential oils and other functional components with a combined vapor pressure of no more than 2 mm Hg at 20 °C, whose sole purpose is to impart an odor or counteract a malodor.
- Low-vapor-pressure compounds ("LVP-VOCs" — broadly, below 0.1 mm Hg at 20 °C, or larger molecules meeting the definition's tests) are exempt too, under section 94510(d).
- Water is not a VOC.
VOC content is the weight of VOC as a percentage of the product's weight, excluding the container. Because the fragrance is exempt, the number to control in a perfume is essentially the ethanol (and denaturant) content by weight.
The limits
| Manufactured | Product | Limit |
|---|---|---|
| Before January 1, 2023 | 20% fragrance or less | 75% |
| More than 20% fragrance | 65% | |
| January 1, 2023 – December 31, 2030 | Aerosol | 70% |
| Non-aerosol, 7% fragrance or less | 70% | |
| Non-aerosol, more than 7% fragrance | 75% | |
| On or after January 1, 2031 | Aerosol | 50% |
| Non-aerosol, 10% fragrance or less | 50% | |
| Non-aerosol, more than 10% fragrance | 75% |
The table also carries footnotes pointing to further requirements for some personal fragrance products, including a ban on certain chlorinated solvents and on parachlorobenzotrifluoride in the lower-fragrance groups (section 94509(m)(1)(B)). Read the current official text before relying on any figure here; CARB amends the regulation from time to time, and the 2031 limits are already written into it.
Worked examples
All figures are by weight, assume the alcohol is ethanol with no other VOC, and treat the fragrance as exempt. They are invented examples, not compliance determinations.
An eau de parfum
- Formula: fragrance 18 g, ethanol 77 g, water 5 g — 100 g.
- VOC = 77 ÷ 100 = 77%. Fragrance is above 7% (and above 10%), so the non-aerosol limit is 75%. Over by 2 points.
- Fix: ethanol 74 g, water 8 g → VOC 74%. Check that 8% water keeps the perfume clear (how much water in perfume).
A body mist
- Formula: fragrance 5 g, ethanol 70 g, water 25 g — 100 g. VOC 70%.
- Made in 2026: 7% fragrance or less, limit 70% — at the limit, with no margin for weighing tolerance.
- Made in 2031: 10% fragrance or less, limit 50%. Ethanol must fall to 50 g or less per 100 g, so water rises to about 45 g — enough to cloud most fragrances without a solubilizer (solubilizing fragrance in water), or a move to a higher fragrance level and the 75% group.
Counting the alcohol you actually buy
Perfumer's alcohol is not pure ethanol. A 95% by volume grade contains water — about 92–93% ethanol by weight — and its denaturant is usually a VOC as well. Take the composition from the supplier's specification and count each component; see perfumer's alcohol. Measuring the finished product's alcohol is covered in measuring alcohol content.
Air fresheners and home fragrance
Room sprays and other air fresheners are a separate category with much lower limits: 18% VOC for liquid and pump sprays, 3% for solids and semisolids, and specific limits for aerosol types (for example 10% for manual aerosols made from 2023, falling to 5% from 2027). Fragrance in these products is exempt only up to 2% of the product by weight for products made before 2031, and 0.25% after; air fresheners made entirely of fragrance (less non-VOC and exempt compounds) are outside the limits. A water-based room spray is the usual answer; see room spray formula and the home fragrance guide.
Other states
Several other US states and regional air-quality bodies have consumer-product VOC rules modeled on California's, with their own categories and dates. A brand selling nationally should check each state where it sells, not only California. The broader picture of perfume rules is in perfume regulations by market.
Records
- For each product: fragrance percentage, the CARB category it falls in, and the date of manufacture of each batch.
- The VOC calculation, with the composition of the alcohol and any other solvent.
- The supplier specification for the alcohol, and any exempt-compound determination.
RUŌOD Lab's production targets give the concentrate and alcohol for an amount of product at a chosen concentration; the VOC check against California's table is a calculation you keep alongside it.
Sources
- California Code of Regulations, title 17, § 94508 (definitions: personal fragrance product, fragrance, VOC, LVP-VOC, VOC content), § 94509 (VOC limits; last amended 2022) and § 94510 (exemptions), as published by the Legal Information Institute; read October 11, 2026.
- California Air Resources Board — Consumer Products Program.
Frequently asked questions
Does the fragrance oil count as VOC?
Not in a personal fragrance product: section 94510(j) exempts any VOC that is a fragrance in such a product. The ethanol and other solvents count.
Does this apply if I sell online from another state?
The regulation covers products sold, supplied or offered for sale in California, which includes sales to California customers. Take advice if you are unsure whether your sales are covered.
Is a scented body lotion a personal fragrance product?
It can be: the definition includes lotion when its primary purpose is to add a scent. A lotion sold mainly to treat dry skin is excluded. Most lotions contain little VOC either way.
Written and reviewed by the RUŌOD Lab team. This article is general education about perfume formulation and record-keeping; it is not legal, regulatory or safety advice, and the examples are illustrations, not validated commercial formulas. How we write and check these guides.