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Guidance Document: Analytical methods for determining VOC concentrations and VOC emission potential for the Volatile Organic Compound Concentration Limits for Certain Products Regulations

(Version 2.0 – September 2026)

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1. Introduction

Purpose and scope

This Guidance Document describes the analytical methods identified for use in determining the volatile organic compound (VOC) concentrations and VOC emission potential for the purposes of the Volatile Organic Compound Concentration Limits for Certain Products RegulationsFootnote 1 (the Regulations). The Regulations apply to manufacturers and importers in Canada and establish VOC limits for the import and manufacture of products in approximately 130 product categories and sub-categories covering product types such as personal care products, automotive and household maintenance products, adhesives, adhesive removers, sealants and caulks as well as other miscellaneous products.

Under section 21 of the Regulations, any analysis performed to determine the VOC concentration or VOC emission potential of a product for the purposes of the Regulations must be performed by a laboratory that is accredited under the International Organization for Standardization standard ISO/IEC 17025 or under the Environmental Quality Act, CQLR, c. Q-2, and the scope of its accreditation includes the parameters that are analyzed or determined. If no recognized standards development organization has established a method for the analysis and the scope of the laboratory’s accreditation does not therefore include that analysis, the analysis must be performed in accordance with standards of good scientific practice that are generally accepted at the time that it is performed.

Environment and Climate Change Canada’s (ECCC) VOC in Products (VOCP) test laboratory is ISO/IEC 17025 accredited. It uses fit-for-purpose analytical methods that produce accurate, reliable, and reproducible results.  The reference methods described herein were developed, validated and/or approved by internationally recognized organizations, such as the Canadian Association for Laboratory Accreditation (CALA), the American Society for Testing and Materials (ASTM), the United States Environmental Protection Agency (US EPA) and the California Air Resources Board (CARB).

Disclaimer

Mention of trade names or commercial products in this document does not constitute endorsement or recommendation by ECCC. References to specific brand names, techniques and instrumentation are provided solely for information purposes to illustrate methods and equipment used by ECCC’s testing laboratory. Any instrumentation or methods that are functionally equivalent in performance and compliance with ISO/IEC 17025 accreditation requirements could be considered acceptable alternatives.

While every effort has been made to ensure that this document reflects the requirements of the Canadian Environmental Protection Act, 1999Footnote 2 (CEPA) and the Volatile Organic Compound Concentration Limits for Certain Products Regulations, the Act and these Regulations prevail over the text of this document in case of any discrepancies or inconsistencies. This document does not supersede or modify the Act or these Regulations. Regulatees are ultimately responsible for understanding and complying with the full text and application of the Regulations.

2. Terms and definitions

Unless otherwise indicated, all terms and definitions in this section are extracted from the Regulations.

“Volatile organic compound” (VOC) means a volatile organic compound that participates in atmospheric photochemical reactions and that is not excluded under item 60 of part 2 of Schedule 1 to the Canadian Environmental Protection Act, 1999.

“Low vapour pressure VOC” (LVOC) in respect of a product other than an antiperspirant or deodorant for the human axilla, is defined in the Regulations as a VOC that meets any of the following criteria:

“Medium vapour pressure VOC” (MVOC) in respect of an antiperspirant or deodorant for the human axilla, means a VOC that has a vapour pressure greater than 0.267 kPa but less than or equal to 10.67 kPa when measured at 20 °C.

“High vapour pressure VOC” (HVOC) in respect of an antiperspirant or deodorant for the human axilla, means a VOC that has a vapour pressure greater than 10.67 kPa when measured at 20 °C.

“Fragrance” means a substance or mixture of chemicals, natural essential oils or other components, that has a combined vapour pressure that is less than or equal to 0.267 kPa at 20 °C, the sole purpose of which is to impart a scent or to mask an unpleasant odour.

“Net weight” is not defined in the Regulations. For the purpose of this guidance, it refers to the weight of the product excluding all packaging material and delivery substrate from which it can be mechanically extracted.

“Content” is not defined in the Regulations. It is a term used by the laboratory only when dealing with a fraction of the product weight and is used in this guidance in relation to product total volatility, ammonia and water determination. It is generally dimensionless.

“VOC Concentration” for a product that belongs to a product category set out in Schedule 1 of the Regulations, is measured and expressed as a percentage of the product’s net weight in the formulation (% w/w), as determined by equation 1:

(1)  % V O C = w s - w ex w p × 100

Where:

“VOC emission potential” for a product that belongs to a product category listed in Schedule 2 of the Regulations, means the quantity of VOC that can be expected to be released during a single use of the product as determined by one of the following methods:

(2)  Emission potential = Ws- Wex Wd × Wper use

Where:

3. Testing procedures

Overview

To determine whether a product complies with the maximum VOC concentration or emission potential limits in the Regulations, several tests are required. The product testing procedure is divided into separate determinations:

  1. Determination of the net weight of a representative sample of the product (Wp)
  2. Determination of the weight of substances in the sample that volatilize (Ws)
  3. Determination of the weight of all the volatile substances in the sample to be excluded as applicable to the product category (Wex), including:
    1. water
    2. ammonia
    3. volatile inorganic substances other than water and ammonia (for example, some inorganic acids)
    4. ethanol and compounds excluded under item 60 of part 2 of Schedule 1, and
    5. low vapour pressure VOCs
  4. Determination of the Low, Medium and High vapour pressure VOC content, as applicable
  5. Determination of the propellant and non propellant fractions (aerosol products) for Ws and Wex
  6. Samples with atypical matrices (for example, product-impregnated materials)

Note for aerosol products: The propellant and non-propellant fractions are determined separately, as described in section E.

Note for antiperspirants/deodorants for the human axilla: The VOC concentrations are determined separately for MVOCs and HVOCs, as described in section D.

A. Determining the net weight of a representative sample (Wp)

The sample net weight is established using an analytical balance. Typically, a balance needs to be accurate to 0.01% of a sample net weight, for example, when dealing with sample net weight in the range of 1 to 10 grams, the determination should be accurate within 0.0001 g or 0.1 mg.

B. Determining the total volatiles weight (Ws)

“Total volatiles” refers to all components in a product sample that volatilize under the analytical method being used. It represents the combined weight of every substance that evaporates during testing, including any substance that is to be excluded when determining the VOC concentration.

The weight of total volatiles in a non-aerosol sample, as well as in the non-propellant portion of an aerosol product sample, is determined gravimetrically in accordance with ECCC VOCP Method 9.01. The analytical approach is based on US EPA Methods 24 and 24AFootnote 5 and ASTM D2369.Footnote 6 Typically, a portion of a sample (usually 0.3 to 1.0 g) is dispensed with a syringe into a preconditioned aluminum weighing dish (Al-dishes). Preconditioning is achieved by heating the Al-dishes for 30 minutes at 110 ± 5 °C, after which they are transferred and stored in a desiccator prior to use (see ASTM D2369-07, section 5.2 for details).  If the sample interacts with the aluminium dish, a Teflon dish may be used. A small volume of an appropriate solvent, typically water, toluene or methanol is used to facilitate its dispersion. The solvent evaporates fully during sample heating and does not contribute to sample non-volatile weight, which is used to determine sample total volatiles. If the sample in the dish does not disperse well it may interfere with sample volatilization.

The sample is then heated at 110 ± 5 °C for 60 minutes. The volatile content is calculated from the difference in the sample weight before and after heating. A desiccator is used for cooling samples to ambient temperature before weighing and for vial conditioning to avoid absorption of water vapour from air.

Thick oven cleaners containing sodium hydroxide and/or entrained propellant can be difficult to analyze. Even when using Teflon weighing dishes, the sample can forcibly eject residue during the oven drying process and affect sample analysis. To mitigate contamination and retain any ejected residue, the Teflon weighing dish containing the sample is placed in a larger Petri dish and covered with a Teflon bowl. This system of Teflon dishes and bowl comprises a containment unit, which needs to be used in place of the single weighing dish prescribed in methods 24 and 24A.

C. Determining the weight of all the substances to be excluded (Wex)

The total volatile analysis includes the mass of any water, ammonia, other volatile inorganic substances, excluded VOCs, fragrances, colourants and LVOCs that may be present in the sample. Depending on the product category, some of these components are to be excluded when determining the VOC concentration. Where applicable, these constituents must be measured separately and subtracted from the total volatile content before performing the VOC calculation. The weight of these excluded constituents can be determined as follows:

i) Water content, by Karl Fischer titration

This method is applicable over a wide range of water content including very low (below 1%) and very high (above 80%) concentrations and is the preferred method for analysing samples. Water content can be determined using commercially available Karl Fischer (KF) volumetric titrators integrated with automated drying oven (ECCC VOCP Method 9.02). The procedure is based on ASTM D4017Footnote 7. The use of a KF drying oven in connection with the KF titrator is necessary. In this procedure, a pre-weighed aliquot of a product sample is diluted with 1-methoxy-2-propanol (MPA) and sealed in a preparation vial. The solvent (MPA) is completely miscible with water forming an azeotrope boiling at 97.5 °C. The sample vial is then heated in the oven until all moisture is removed from the vial headspace with a stream of dry inert gas, typically nitrogen. After passing through the vial the gas is directed to the KF titrator where water vapour is retained by the KF reagent. This technique avoids the interference between the sample matrix, KF reagent and electrode, and in most cases is preferable over the direct injection of the sample to the KF titrator.

ii) Water content, by Gas Chromatography

Alternatively, the water content may be established by direct injection gas chromatography following the approach described in ASTM D3792Footnote 8. This method was originally developed for determination of water content in water-reducible paints. This gives the best results for products with water content between 15%-75%. For samples with either a very low and/or very high water concentration, the Karl Fischer (KF) method is more accurate.

ASTM D3792 is often applied with some modifications to solvent type and/or column packing material. Such modifications are acceptable, assuming that the modified method is properly validated before use. When applied to certain products, samples can be diluted in a 1:10 ratio (weight/volume) with 1-methoxy-2-propanol (MPA) or other compatible solvents. Some samples, particularly gels, may require using the homogenizer to obtain sufficient surface area for a solvent to extract the water. After thorough mixing, the solution often requires filtering to remove any remaining insoluble material. A small aliquot (1-2 µL) of the mixture is injected into a gas chromatograph equipped with a thermal conductivity detector (TCD) with a 4 to 6 ft long column, 1/8” outside diameter (O.D.) stainless steel, lined with TFE-fluorocarbon coating and packed with 60-80 mesh (180 to 250 µm) porous polymer packing material (HayeSep R, C or similar). Calibration standards are prepared by diluting a known amount of ASTM D1193Footnote 9 type I water in solvent used for sample dilution.

iii) Ammonia content

Ammonia is not classified as a VOC; however, it is volatile and therefore captured in the total volatiles measurement. For example, some glass and general-purpose cleaners contain ammonium hydroxide, which would lead to an overestimation of VOC content. Accordingly, the ammonia content of the product must be quantified separately and subtracted from the total volatiles so that the VOC concentration reflects only regulated volatile constituents.

Procedures for the measurements of ammonium ions in aqueous products are based on ASTM D1426Footnote 10 (ECCC VOCP Method 9.07). This method uses an ion selective electrode to measure the concentration of ammonia in water-based products, which is much more rapid than traditional photometric or ion chromatography techniques.

iv) Inorganic substances (other than water and ammonia)

Certain volatile inorganic acids such as hydrochloric acid should be determined and subsequently subtracted from the total volatile content. ECCC uses an in-house developed method (ECCC VOCP Method 9.10) that uses titration with sodium hydroxide to determine the %w/w of various acids.

v) Compounds excluded under item 60 of part 2 of Schedule 1 to CEPA, and, where applicable, Ethanol

Certain organic compounds are excluded from the definition of VOC in item 60 of part 2 of Schedule 1 to CEPA. When present in a product, these excluded compounds must be quantified separately and subtracted from the total volatiles so that the calculated VOC concentration reflects only substances that meet the regulatory definition.

To determine the concentration of such compounds, ECCC uses its own reference method (ECCC VOCP Method 9.03) based on ASTM D6133Footnote 11:

Product samples are prepared as weight/volume dilutions in an organic solvent, most commonly toluene or 1-methoxy-2-propanol (MPA). After the initial extraction, the sample is further diluted to a level appropriate for mass spectrometry (MS) detection and filtered through a 0.2 μm pore size filter to remove any insoluble material that would interfere with analysis before introduction to the gas chromatography-mass spectrometry (GC-MS) system. A small aliquot of filtered sample is injected onto a 60 m × 0.25 mm internal diameter (I.D.) DB-624 capillary column, which offers good retention and separation of analyzed compounds. The data are reported as the weight fraction of analyte in the product. This method can quantify relatively large suites of VOCs including ethanol, acetone, methyl acetate, dichloromethane, t-butyl acetate, parachlorobenzotrifluoride (PCBTF) and others. It is also capable of separating and quantifying common volatile methyl siloxanes (VMS) such as D4, D5, L2, L3, L4 and L5.

vi) Fragrances and colourants

Fragrances are checked by a GC-MS screening method. If the presence of fragrances is confirmed by this method, up to 2% of the product’s net weight may be excluded from the determination of VOC concentration based on the manufacturer’s claimed composition.

For products in Category 11 (Personal fragrance products) the fragrance is separated from ethanol-containing products using brine separation (ECCC VOCP Method 9.11), with the fragrance concentrations determined gravimetrically.

Colourant concentration may be determined using the FDA Laboratory Information Bulletin Colors ManualFootnote 12.

D. Determining the LVOC, MVOC and HVOC content

a) LVOC

Where applicable, LVOC are excluded from the determination of VOC concentration limits and can be analyzed by either automated distillation or simulated distillation techniques.

To determine the LVOC content by automated distillation, an aliquot of sample up to 100 mL is accurately measured. The sample is then placed into a round-bottomed flask with some anti-bumping granules and run according to the appropriate ASTM method (ASTM D86Footnote 13, ASTM D850Footnote 14, ASTM D1078Footnote 15, ASTM D2879Footnote 16 or ASTM E1719Footnote 17) with appropriate distillation cut-off temperature (ECCC VOCP Method 9.08).

b) MVOC and HVOC

For aerosol antiperspirants and deodorants (product subcategories 2(i) and 3(i)), there are different limits for MVOCs and HVOCs and therefore the concentration of MVOCs and HVOCs must each be determined separately using automated distillation and simulated distillation techniques that allow for separation and collection of fractions of a product boiling at different temperature ranges, and consequently precise determination of weight distribution of distilled fractions.

If LVOC, MVOC, or HVOC compounds cannot be positively identified and quantified, yet the product is claimed to contain them, or if there is a discrepancy between laboratory and manufacturer/importer VOC determinations, the Enforcement Officer may request and review formulation data to assess product compliance.

E. Determining the propellant and non-propellant fractions for Ws and Wex in aerosol products

For aerosol products that use a propellant to eject and/or disperse a liquid or solid portion of the product from its container, the propellant fraction is normally completely volatile, although the not all volatile propellants are VOCs. The volatility of the non-propellant fraction also needs to be established. The gaseous and non-gaseous portions need to be collected separately. ECCC uses an in-house developed method (ECCC VOCP SOP 24.08) based on the Anton Paar Aerosol Adapter for this purpose. The VOC concentration of each fraction is determined separately, and the results are combined according to the mass contribution of each fraction to the product.

Attention needs to be paid to minimizing potential air leaks and interferences before the analysis is conducted, considering the type of containers used to collect the gaseous portion. For example, if Tedlar bags are employed, it is important to remember that they are semi-permeable and the analysis should be completed within three days of collection.

For the gaseous portion, the sample collected in the container is analyzed (screened) for identification of propellant composition using GC-MS. Once all the compounds are identified, the quantification can often be carried out using a thermal conductivity detector (TCD) instead of a mass selective detector (MSD). Inorganic propellants such as air, nitrogen and CO2 could be used in aerosol products. Other compounds often found in aerosol propellants include 1,1-difluoroethane (HFC-152a), 1,1,1,2-tetrafluoroethane (HFC-134a), propane, dimethyl ether (DME), isobutane, and n-butane.  Where present, the weight of such inorganic propellants must be included in Wex when determining the VOC concentration.

For the non-gaseous portion, the VOC concentration is determined following the procedures of US EPA Methods 24 and 24A and ASTM D2369, similar to that described for non-aerosol products at the beginning of this section.

F.  Samples with atypical matrices

a) Product-impregnated materials where the separation of the sample from the delivery system is possible

The VOC limit for a product-impregnated material such as wipes for cleaning hands or car surfaces applies to its liquid phase only (the substrate, such as tissue, is considered a delivery system and, like packaging, is excluded from the net weight of the product). The liquid needs to be separated from the substrate. The determination is carried out as described in general testing procedure for non-aerosol samples.

b) Product-impregnated materials where the separation of the sample from the delivery system is not possible.

When the sample cannot be separated from the delivery system by, for example, mechanical compression, a disc-shaped subsample is cut from a fresh sheet (or equivalent delivery substrate impregnated with the product), with a diameter slightly smaller than the diameter of the weighing dish. The volatile fraction of the subsample is established following the procedure described in US EPA Method 24. A similar approach can be applied to water determination when using Karl Fischer titration with a sample drying oven. In the case of excluded VOCs, a subsample of the product needs to be extracted with solvent prior to analysis.

c) Single-use dryer products that are designed to impart softness to, or control the static cling of, fabric

The VOC emission potential shall be determined by cutting a disc-shaped subsample from a fresh sheet (or equivalent delivery substrate impregnated with the product), with a diameter slightly smaller than the diameter of the weighing dish. The values for Wd, Ws and Wex of the subsample are determined using the procedure described above for product-impregnated materials where the separation of the sample from the delivery system is not possible. The VOC emission potential is then calculated using Equation 2, based on the weight of the recommended quantity of sheets (or equivalent) for a single use. The recommended quantity shall be as specified on the product packaging or label.

4. Data sources for chemical properties

To determine certain properties of compounds (such as boiling point or vapour pressure), ECCC follows a standardized approach using two sources:

Primary Source: The Design Institute for Physical Properties’ (DIPPR’s) Project 801 DatabaseFootnote 18 (subscription required) is recognized as the world's premier source of critically evaluated thermo-physical properties. It provides recommended values and estimates of accuracy for 34 constant properties and 15 temperature-dependent properties for compounds of interest.

Complementary Source: The ECHA CHEMFootnote 19 public chemicals database (free to access) contains information from REACH registrations, the Classification and Labelling Inventory and Regulatory lists and processes under REACH, CLP, DWD and POPs regulations.

If discrepancies exist between the two databases, ECCC will select the value that results in the lower VOC concentration.

Contact details

For further information or to request a copy of the ECCC methodology please contact the VOCP lab at: labcovp-vocplab@ec.gc.ca.

References

Page details

2026-09-16