EPA's New Hair Product Exemption Process: What It Means for Cleaner Styling Formulas

The Environmental Protection Agency (EPA) has issued a notice regarding its review of applications for innovative product exemptions under its National Volatile Organic Compound Emission Standards for Consumer Products, including a submission from Henkel Corporation for a hair styling product. This regulatory development signals a potential pathway for manufacturers to develop hair care formulations that reduce actual chemical emissions, even if they contain higher VOC content by weight.

What Are VOCs and Why Do They Matter in Hair Products?

Volatile organic compounds, or VOCs, are chemicals that evaporate easily at room temperature and contribute to air pollution and indoor air quality problems. In hair styling products, VOCs typically come from propellants in aerosol cans and solvents in gels, sprays, and creams. When you spray hairspray or apply certain styling products, these chemicals are released into the air you breathe, both in your home and in salons where professionals use these products daily.

The EPA established the National Volatile Organic Compound Emission Standards for Consumer Products in 1998 under the Clean Air Act, setting strict limits on how much VOC content is allowed in consumer products, including hair styling formulas. These limits were designed to reduce ground-level ozone formation and improve air quality.

How Does the Innovative Product Exemption Process Work?

The EPA's innovative product exemption (IPE) process allows manufacturers to request permission to exceed the standard VOC content limits if they can demonstrate that their product formulation, design, delivery system, or other factors will result in equal or lower VOC emissions during actual use. In other words, a product might contain more VOC chemicals by weight, but if the way it's delivered or applied means fewer of those chemicals actually escape into the air, it qualifies for an exemption.

On April 4, 2025, Henkel Corporation, a major personal care manufacturer, submitted an application for an innovative product exemption for one of its hair styling products. The EPA has issued a notice of its decision-making process on this and other pending applications, providing notification of the agency's actions and the basis for those decisions.

What This Means for Consumers and Clean Beauty?

This regulatory process opens a potential pathway for manufacturers to develop hair styling products that use alternative delivery systems and formulations designed to minimize VOC emissions. Rather than relying solely on traditional aerosol propellants, companies pursuing exemptions could use pump sprays, roll-on applicators, or reformulated gels and creams that reduce the amount of volatile chemicals released into the air.

For consumers concerned about indoor air quality and personal care product safety, this development suggests that manufacturers now have a regulatory framework to pursue cleaner hair styling options. Products designed to meet exemption criteria would emit fewer harmful chemicals during application, which is particularly important for people who style their hair frequently or work in salons where exposure to these chemicals accumulates over time.

How to Reduce Your Exposure to VOCs in Hair Styling Products

  • Choose pump or roll-on applicators: These delivery systems typically release fewer volatile chemicals into the air compared to traditional aerosol cans with propellants.
  • Look for gel and cream formulas: Non-aerosol styling products like gels, creams, and pomades generally have lower VOC content than spray-based formulas.
  • Improve ventilation when styling: If you use aerosol hair products, apply them in well-ventilated areas or near open windows to reduce inhalation of volatile compounds.
  • Check product labels for VOC information: As manufacturers develop products under the exemption framework, look for labels indicating reduced VOC emissions or alternative delivery systems.
  • Ask about salon practices: If you frequent salons, inquire whether stylists use lower-VOC formulations or alternative delivery systems for hair styling products.

The EPA's decision to process innovative product exemption applications for hair styling products reflects growing recognition that traditional formulations may not be the only way to achieve effective styling results. By establishing a framework that allows manufacturers to pursue alternatives reducing actual VOC emissions, the agency is creating incentives for the personal care industry to innovate toward cleaner products.

This regulatory development aligns with broader consumer demand for cleaner personal care products and lower-toxicity home and beauty formulations. As companies pursue exemptions and develop products meeting these criteria, the hair care market may see an expansion of styling options designed to reduce both indoor air pollution and personal exposure to volatile chemicals.