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California Carb Conversion

Dear Valued Customer:

Important Information Regarding the Sale of WD-40 Multi-Use Product in California
The California Air Resources Board (CARB) has ruled that any product classified as a multi-purpose lubricant must have a VOC (volatile organic compound) level of 25% or less effective with a manufacturing date after December 31, 2013 in order to be sold in California.* To comply with this regulation, the WD-40 Company will begin to manufacture 25% VOC compliant product for sale in California as of January 1, 2014. Since we do not foresee other states moving to this stringent legislation and to minimize any price impact on our customers and consumers, we will continue to sell our current formula in the remaining 49 states. This product will be labeled as “not for sale in California.” Product produced prior to January 1, 2014 may continue to be shipped and sold in California for a three year period ending December 31, 2016.

Products Involved
The following WD-40 Multi-Use Products will be converted to the lower VOC formula for sale in California:
- 3oz.
- 8oz. Smart Straw
- 11oz. Smart Straw
- 12oz. Smart Straw
- 16oz. Industrial
- 18oz. Big Blast
- 20oz Trigger Pro
- 1 Gallon
- 5 Gallon
- 55 gallon drum

All other WD-40 Company products including WD-40 Specialist, WD-40 No-Mess Pen and 3IO brand are either already 50 state compliant or do not fall under this regulation.

Pricing

The WD-40 Company has worked diligently to minimize the cost impact of this formulation change. While there are cost implications to the lower VOC formula, the WD-40 Company has chosen to absorb these costs. At this time there will be no price increase for the lower VOC formula and we will maintain national pricing.

Performance
The performance of the new WD-40 25% VOC formula has been shown to be equal to the current formula in both laboratory and consumer testing.
1061 Cudahy Place, San Diego, CA 92110-3929
Tel 619/275.1400 Fax 619/275.5823

Timing
The first shipment of the lower VOC formula is expected sometime after January 1, 2014. However, since there is a three year sell through period for the current higher VOC product, the WD-40 Company will continue to ship the current formulation to California during this transition. Your Sales representative will be in touch with you regarding specific timing for your account.;

Execution Details: SKU changes, case codes, can codes In order to accurately track and identify the California only product, the case and can codes will be changed.


Component
California Only
Non-California
 Can UPC Change
 Yes  No
 Case/Display sku (order #) change
 Yes  No
 Additional Can/Corrugate Artwork
 None  Labled "Not for Sale in Ca."

Please see the attached spreadsheet for the new numbers for the California only items as well as the current sku numbers that will be maintained for the non-California items. Please note that the California only items begin with an initial digit of “49.”


The importance of inventory rotation

Under California regulations there is a three year sell through period for product produced prior to January 1, 2014. Therefore there is no action required to remove or return current product. We encourage you to follow standard FIFO inventory practices to ensure current inventory will sell through by the end of the three year period.


Next Steps
Your WD-40 Company Sales and Customer Service Representatives will be in touch with you to work through the timing and logistics of your orders destined for final sale in California.
 
Regards,
Mike Freeman
Division President – The Americas

WD-40 Company

 

*California Environmental Protection Agency, Air Resource Board, Consumer Products Regulations; Final Regulation Order effective December 2011; Regulation for Reducing Emissions from Consumer Products, Article 2, Paragraph 94509 (a); Percent Volatile Organic Compound by Weight, Multi-Purpose Lubricant, 12-31-2013 25  http://www.arb.ca.gov/consprod/regs/2012/article2080913.pdf
 

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Written on Friday, January 3, 2014 by
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