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Ozone Transport Commission Rules

OTC requirements under the Clean Air Act

Eco-Friendly Paint Products : OTC Paint Regulations

The Ozone Transport Commision (OTC) is a multi-state organization created under the Clean Air Act to develop and implement regional solutions to the ground-level ozone problem in the Northeast and Mid-Atlantic regions.

OTC Paint Regulations

Ozone Transport Commission (OTC) Rules


Current members include: Conneticut, Delaware, the District of Columbia, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont and Virginia. The controls placed on Architectural and Industrial Maintenance (AIM) coatings have been implemented in the OTC in the form of model rules which define the VOC content of various coating categories. Currently, two model rules are available: Model Rule 2002 and Model Rule 2010. Each participating state independently elects to adopt a model rule. All states have adopted Model Rule 2002 with the exception of Vermont which still follows the EPA National Rule and Virginia for which only select areas have adopted. Since 2017, several states have adopted Model Rule 2010 including Maryland, Delaware, Connecticut and Rhode Island. And, although Utah is not part of the OTC, it also has several counties that adopted Model Rule 2010, in 2015.

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OTC Paint Regulations

OTC Model Rule Exemptions

  • Small container exemption allows the sale of coatings above maximum VOC limits if packaged in containers of one liter or less.

  • Sell-through provision allows the sale of coatings above the maximum VOC limits if manufactured prior to the individual state rule's effective date. The sell-through period may range from three years to indefinite.

For the most current information on the OTC Model rule, please visit

For the individual state rules, please visit the specific state environmental protection agency website.

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Flat 100 50
Non-Flat 150 100
Non-Flat High Gloss 250 150
Industrial Maintenance General 340 250
Industrial Maintenance High Temp 420 420
Primer 200 100
Quick Dry Primer 200 100
Specialty Primer 350 100
Quick Dry Enamel 250 150
Floor 250 100
Rust Preventative 400 250
Stains 250 250
Dry Fog 400 150
Varnish 350 275
Waterproofing Sealer - Wood 250 275
Waterproofing Sealer - Concrete 400 100