The California Air Resources Board (CARB) is currently gathering data for its Technical Assessment for Personal Fragrance Products (PFPs). The technical assessment has a mandatory reporting requirement with a deadline of March 31, 2026, and is directly related to CARB’s long-term VOC standards for personal fragrance products.

CARB sets some of the strictest Volatile Organic Compounds (VOCs) standards in the country, aiming to reduce ozone concentrations. Ground-level ozone is a major component of smog, which poses significant environmental and public health issues in California. Smog remains a persistent issue in the state given its topography, the amount of sun it receives, and the large volume of traffic on any given day.

The technical assessment is directly related to CARB’s long-term VOC plan. By Jan. 1, 2031, non-aerosol and aerosol PFPs with 10% or less fragrance concentration must comply with a 50% VOC standard. CARB has announced that the technical assessment is intended to determine if manufacturers can continue to achieve the 50% VOC standard using current or new technology. 

For R&D teams, this deadline is significant. Any company whose name appears on the product label and that is responsible for placing the product into California commerce (i.e., Responsible Parties) must submit product and formulation data using CARB’s Personal Fragrance Products Reporting Tool (PFP-RT), as well as a written report describing research and development efforts undertaken to achieve the 50% VOC standard. 

If the product formulations are not developed in-house, CARB will request ingredient and R&D information directly from product and fragrance formulators. This means formulation strategies, carrier systems, and fragrance VOC content become part of the regulatory record. Also, technology development efforts aimed at VOC reduction are explicitly reportable, and innovation claims must be supported by structured, validated data. In effect, the reporting format requires R&D teams to organize formulation data in a way that aligns with CARB’s evaluation of technical feasibility.

CARB has also indicated that the information provided as part of the PFP Technical Assessment will be considered confidential information under Title 17 of the California Code of Regulations and the California Public Records Act, including trade secret protection.

For the fragrance and formulation teams, the question is simple. Are current development efforts and VOC reduction plans being recorded in a manner that accurately reflects technical capability as of March 31, 2026?