Volatile Organic Compound Concentration Limits for Certain Products Regulations - Alternative compliance options
Disclaimer
This material has been prepared for convenience of reference and accessibility and does not have an official character. It is of a general nature only. For all purposes of interpreting and applying the regulations, users must consult the consolidated version on the Justice Laws Website and seek their own legal advice as appropriate.
On this page you will find information related to the alternative compliance options available under the Volatile Organic Compound Concentration Limits for Certain Products Regulations.
The information includes 3 alternative compliance options for the regulations. These voluntary alternative compliance options are:
- Permit - Technical or economic non-feasibility (TENF)
- Permit - Products whose use results in lower VOC emissions (PULE)
- VOC Compliance Unit Trading System (CUTS)
For more information on how to apply, or to request an application or annual reporting form, please refer to the contact information below.
Permit – Technical or Economic Non-Feasibility
The regulations include a provision for temporary relief for companies unable to meet the regulatory VOC limits for technical or economic reasons. These temporary permits for Technical or Economic Non-Feasibility (TENF permits) allowed regulated parties to continue manufacturing or importing products for up to a maximum of four years if the conditions outlined in the regulations are met, including a plan to show how the products will be brought into compliance.
TENF permit applications are no longer accepted as regulatory timelines for issuing new permits have passed.
Permits issued – Technical or Economic Non-Feasibility
TENF permits were granted to the following organizations for the specified products.
- Guardian Chemicals Inc. (expired December 31, 2025)
- Hydrosol (various sizes)
- Greensol Solvent Degreaser (various sizes)
- Pentrax Solvent Degreaser (various sizes)
- Breakaway Hybrid Multi Purpose Solvent Degreaser (various sizes)
- Terrasol Hybrid Multi Purpose Solvent Degreaser (various sizes)
- Henkel Canada Corporation (expired December 31, 2024)
- LePage® Heavy Duty Contact Cement (various sizes)
- Lampe Berger Canada Inc.
- Bouquet and Bouquet Refill (various fragrances) (expired December 31, 2025)
- Lampe Berger Refill (various fragrances) (valid until December 31, 2027)
- Recochem Inc. (valid until December 31, 2026)
- ColRFlo Acrylic Lacquer Thinner (3.78 L)
- Solvable™ Professional Grade Lacquer Thinner (various sizes)
- Solvable™ Professional Grade Xylene (various sizes)
- Solvable™ Professional Grade Toluene (3.78 L)
- Sani Marc Inc.
- SIPHON (various sizes) (expired June 30, 2024)
- ENERGIE (various sizes) (expired June 30, 2024)
- POWERGEL (various sizes) (expired September 30, 2024)
- SANI-DRIP (various sizes) (expired December 31, 2024)
- CHILL OUT (various sizes) (expired December 31, 2024)
- PLZ Corp (expired December 31, 2024)
- No Name® fume-free oven cleaner (400 g)
- Compliments Fume-Free Oven Cleaner (400 g)
- Selection™ Oven Cleaner (400 g)
- Great Value™ Fume Free Oven Cleaner (400 g)
- Envision SQ Inc. (valid until December 31, 2026)
- GermStop 24 Hour Hospital-Grade Disinfectant (various sizes)
Permit – Product Whose Use Results in Lower VOC Emissions
A permit for Products Whose Use Results in Lower VOC Emissions (PULE) allows companies to import or manufacture a product that exceeds the VOC concentration limit if, as a result of an innovative design, formulation, delivery or other factors, the total VOC emissions are lower than those from a comparable compliant product when used according to the manufacturer’s written instructions.
To apply, a company must provide:
- the estimated quantity imported or manufactured in a year
- evidence that shows the product’s use results in lower VOC emissions than a compliant product in the same category
This permit is valid up to four years and can be renewed. The request for renewal must be submitted 90 days prior to expiry. Additional guidance and criteria for assessment of the application are provided in the application form.The PULE application form may be obtained by contacting Produits-products@ec.gc.ca.
Permits issued – Product Whose Use Results in Lower VOC Emissions
PULE permits have been granted to the following organization for the specified products.
- Newell Brands Canada (valid until December 31, 2027)
- Microburst 3000 Refill (0.057 kg) (various fragrances)
- Microburst 9000 Refill (0.150 kg) (various fragrances)
VOC Compliance Unit Trading System (CUTS)
The regulations include a VOC Compliance Unit Trading System (CUTS) that provides an alternative method for complying with VOC concentration limits. The CUTS permit allows companies to manufacture or import products that exceed VOC concentration limits by balancing emissions from products that exceed the concentration limits with either:
- compliance units earned from products that were reformulated to have a VOC; concentration lower than the regulatory limits
- compliance units transferred from other companies
Generating compliance units
Companies who wish to generate compliance units must submit a notice of intent before October 1 of the first year in which they want to earn compliance units, and must report actual quantities of products manufactured in Canada, imported into Canada and exported from Canada by March 1 of every subsequent year. Companies will receive confirmation of compliance units generated within 60 days of a complete report. Compliance units are valid for two years beginning on January 1 of the year following the calendar year in which they are generated.
- Notification forms and annual reporting forms for the generation of compliance units may be obtained by contacting: Produits-products@ec.gc.ca
Permits for products exceeding the VOC concentration limits
To apply for a CUTS permit, companies must provide:
- information on the products that exceed the limits and
- a plan to compensate for the excess quantity of VOCs
CUTS Permit holders must submit an annual report no later than March 1 of each year that includes actual quantities manufactured, imported and exported, which compliance units are being used to compensate for the excess quantity of VOCs, and a confirmation of intent to continue manufacturing or importing the product under the permit. If emissions are not balanced for the calendar year, the permit will be revoked.
- Application forms and annual reporting forms for CUTS permits may be obtained by contacting: Produits-products@ec.gc.ca
Using and transfer of compliance units
A company can use or trade unused compliance units. If companies intend to transfer compliance units, they must submit a joint application for approval of the transfer.
- The Compliance Unit transfer application form may be obtained and submitted by contacting: Produits-products@ec.gc.ca
Compliance Unit Trading System Participants
Compliance Unit Generators:
The following organizations have generated compliance units:
- S.C. Johnson and Son Limited (generated only in 2023)
- Reckitt Benckiser (Canada) Inc. (since 2023)
- Chanel Canada ULC (since 2023)
- Sani Marc Inc. (since 2023)
- Wurth Canada Limited (since 2024)
CUTS Permits Issued:
CUTS permits have been granted to the following organizations for the specified products.
- Reckitt Benckiser (Canada) Inc.
- Airwick Freshmatic Automatic Spray Refill (various fragrances and sizes) (now a product of Essential. H. Inc.)
- Silvo® Metal Polish (178 g) (now a product of Essential. H. (Canada) Inc.)
- Lysol® Simply™ All Purpose Cleaner Orange Blossom (650 g)
- Lysol® Simply™ Multi-purpose Cleaning Wipes Unscented (50 sheets)
- Lysol ADVANCED Disinfecting Wipes – Citrus (5x110 count)
- Lysol Bathroom Foam Cleaner - Summer Fresh (680 g)
- Lysol POWER Shower Foam Cleaner (538 g)
- Lysol Disinfecting Wipes (various fragrances and sizes)
- Lysol Dual Action Wipes – Citrus/Mango and Hibiscus (various sizes)
- Lysol Shower Foam Cleaner - Brand New Day Mango & Hibiscus (0.538 L)
- Chanel Canada ULC:
- Nº5 Parfum (various formats and sizes)
- Bois des Iles Parfum (15 ml)
- Allure Homme Sport Superleggera Eau de parfum Spray (various sizes)
- Essential. H. (Canada) Inc.:
- Air Wick Freshmatic Automatic Spray Refill (various fragrances and sizes)
- Silvo® Metal Polish (178 g)
Related links
Contact us
Chemical Production Division
Environment and Climate Change Canada
351 St. Joseph Blvd
Gatineau QC K1A 0H3
Email: Produits-Products@ec.gc.ca
Toll-free: 1-800-668-6767