The Consumer Council (CC) is pleased to provide views on extending the control of volatile organic compound content to cleaning products proposed by the Environmental Protection Department (EPD):
- Since the outbreak of COVID-19 pandemic over the past three years, various types of disinfectants, general purpose cleaners, and sanitizing products are widely and frequently used for household, workplaces, and also in public areas. While many of these products consist of different organic compounds, in which some of the substances may be volatile under ambient conditions.
Considering that exposure to VOCs can irritate eyes and respiratory system, which may lead to headache, breathing difficulties and nausea, the potential health and environmental impacts associated with the use of various VOC-containing cleaning and disinfecting products should be evaluated so as to safeguard the health of consumers.
- CC supports the establishment of different control measures in lowering the VOC content in various types of consumer products. VOC emission is one of the major contributors to air pollution, which also triggers the formation of photochemical smog and ozone. Therefore, lowering VOC emissions at source is crucial in alleviating the persistent air pollution situation in Guangdong-Hong Kong-Macao Greater Bay Area (GBA).
VOCs in Cleaning Products
- Conventional cleaning products and disinfectants contain different types of VOC, including but not limited to:
- fragrance chemicals that intentionally added to enhance the user experience when using these products;
- chloroform and methyl chloroform can be off-gassed when in chlorine-type cleaning products are in use;
- 2-butoxyethanol, camphene, ethylbenzene, tetrachloroethylene, toluene and limonene are commonly found in ammonia-based cleaners; and
- formaldehyde, ethylbenzene, tetrachloroethylene and toluene are used in furniture and floor-cleaning sprays.
Insights from Local Emission Study
- Referring to the EPD’s 2020 Hong Kong Emission Inventory Report released in August 2022, non-combustion sources (including the use of consumer products) was among the top emission source for VOC, contributing to 54% of the total VOC emissions. The total VOC emissions from 2001 to 2020 was significantly reduced to less than 50% due to the implementation of VOC regulation since 2007. Therefore, CC believes that extending the regulation to cover more types of consumer products will help further lowering the VOC emissions from non-combustion sources, hence improving the air quality in Hong Kong.
- Meanwhile, it was found that respirable suspended particulates (可吸入懸浮粒子RSP or PM10) and fine suspended particulates (微細懸浮粒子FSP or PM2.5) were other important emission problems aroused from non-combustion sources in the past 20 years (study period from 2001 to 2020). Although the major contribution was due to paved road dust, the level of RSP and FSP emissions from other non-combustion sources remained as important air pollution problems, which may consist potential impact on indoor air quality.
Insights from Overseas Regulations
- In the US, the California Air Resource Board (CARB) has implemented California Consumer Product Regulations since 2010, and established a systematic approach to control different aspects of air quality:
- Set up total VOCs requirements for over 100 consumer products
- imit the amount of ozone emitted from indoor air cleaning devices and set up certification schemes for products complying with the regulation
- Greenhouse gas emission control programmes
- EU also has different directives and national laws on the control of hazardous chemicals and persistent organic pollutants, including but not limited to the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) Regulation and the Persistent Organic Pollutant (POP) Regulation. These legislations prohibit or restrict the use of hazardous chemicals and persistent organic pollutants in different types of consumer products.
Suggestions from the Council
- Apart from regulating VOC contents in different types of cleaning products, CC considers that imposing control over the release of individual hazardous/harmful substances, persistent chemicals, and compounds with high Global Warming Potential (GWP) values will be another possible measures to further strengthen the air pollution control in Hong Kong.
- For instance, dry cleaning detergents (e.g. dry cleaning fluid for fabrics, carpet cleaners) may have potential emission of perchloroethylene and naphthalene. While higher levels of exposure can lead to irritation of eyes, skin, nose, throat and/or respiratory system. However, neither VOC contents nor emissions of individual harmful substances were regulated or proposed to be regulated in this consultation paper.
- While some of the VOCs are not only precursors of ozone formation, they are also greenhouse gases and persistent organic pollutants. The control of these chemicals will be important in meeting the greenhouse gas emission target set in The Hong Kong’s Climate Action Plan 2050, i.e. Hong Kong will strive to achieve carbon neutrality before 2050. The elimination of high GWP chemicals in consumer products not only will help improving air quality in Hong Kong but also reduce greenhouse gas emissions in Hong Kong.
- In some of CC’s previous studies, hazardous and volatile organic solvents, such as benzene, toluene and polycyclic aromatic hydrocarbons (PAH), were found in consumer products such as nail polish and gel nail polish products. During the usage phase of these products, the levels of organic solvents accumulated in the indoor air may be increased to certain level that would lead to health problems. Furthermore, CC also noted that odor remover/eliminator sprays, fragranced candles are growing popularity among consumers, which will emit fragrance substances and organic solvents during their use phase. Therefore, restrictions to VOC and/or other important emissions (e.g. RSP and FSP) to these products are suggested. In addition, antiperspirants and deodorants are common body care products which may have high VOC emission. Therefore, the Council recommends imposing control over the above products on their VOC contents.
- Apart from extending the VOC requirements to more consumer products, CC also recommend periodic review and tightening of existing VOC requirements. With more regulations and development in VOC control worldwide, CC believes that more products without or with low-VOC content will be coming into the market.
Proper Labelling of Products
- With reference to the Council’s study on multi-purpose disinfectants, bathroom cleaners and toilet cleaners published in 2021 and 2022 respectively, it was found that a number of disinfecting and cleaning products did not provide important information such as product ingredients and/or proper user instruction on the package. Under these circumstances, it exerts difficulties to impose proper regulation on these products. Moreover, consumers cannot rely on the labelling information for choosing products with lower VOC emissions. As a result, overuse and misuse of products, it might even lead to health risk to consumers and worsen the air quality.
- Therefore, aside from lowering the VOC contents in various cleaning products, CC considers that proper labelling of detailed ingredients, user instructions, safety precautions and warning statements, as well as disposal method should be clearly displayed on the product packaging.
- On the other hand, the development of green product certification system will be another feasible way to drive the market to innovate new products with lower VOC emission and environmental friendly alternatives. Many worldwide and local green product certification schemes, such as Green Seal, Hong Kong Green Labels, have already developed guidelines and requirements on different environmental aspects for different cleaning products.
Conclusion
- Reducing the concentration of indoors and outdoors VOCs is important to safeguarding consumers’ health and the overall environmental goal of Hong Kong. As many different types of consumer products contain various amounts of VOCs, CC therefore considers that extending the current VOC regulation to include more consumer products will help to foster better air quality in Hong Kong.
- Further to the Clean Air Plan for Hong Kong 2035, CC looks forward to seeing more policies and measures to control and regulate different air pollutant emissions from various sources in Hong Kong.
February 2023
Consumer Council
