Canada, California and Congress: The Three C’s of New North American Regulatory Concern

July 30, 2008 | Contact Author | By: David C. Steinberg, Steinberg & Associates
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“When I use a word,” Humpty Dumpty said, in rather a scornful tone, “it means just what I choose it to mean—nothing more and nothing less.”

“The question,” replied Alice, “is whether you can make words mean so many different things.”

Combine this example taken from the classic children’s book, which plays on words and changing their meanings, with the old adage, “Don’t confuse me with facts, my mind is made up,” and it produces an end result much like that of recent political actions concerning cosmetics in North America.

VOCs: On April 26, 2008, Canada released new Volatile Organic Compounds (VOCs) requirements. These requirements are aligned with the current California Air Resources Board (CARB) requirements in which companies that emit VOCs are required to register and maintain VOC records for five years. These must be sent to the Canadian Minister of Environment upon request. Cosmetic products subject to these new requirements are listed in Table 1.