In recent years, volatile organic compounds (hereafter referred to as "VOCs"), which serve as critical precursors in the formation of ozone (O₃) and fine particulate matter (PM2.5), have been recognized as an effective pathway for controlling atmospheric pollution. 2020 marked the final year of the three-year action plan to win the "Blue Sky Defense Campaign," during which China has already rolled out a series of policies and standards closely tied to VOCs management. Among these, several upcoming product quality standards—limiting VOC content in coatings, inks, adhesives, cleaning agents, and other products—are set to take effect soon, significantly impacting related industries. This article, drawing on relevant legal and policy provisions, highlights key mandatory national standards governing VOC content in restricted products, which will come into force either by the end of this year or early next year. These standards are particularly crucial for industrial enterprises and retail companies involved in commissioned processing arrangements. ### I. The Importance of VOC Product Quality Standards On June 24, 2020, the Ministry of Ecology and Environment released the "2020 Volatile Organic Compounds Control Action Plan" (hereafter referred to as the "Action Plan"), emphasizing the strict enforcement of national and local VOC content limits for specific products. The Action Plan explicitly stated that, starting from July 1, 2020, the production, sale, and use of marine coatings and floor coatings must comply with newly issued national standards for limiting harmful substances in these products. Additionally, manufacturers were urged to proactively prepare for the implementation of similar standards on inks, adhesives, cleaning agents, as well as coatings used for wood, vehicles, exterior walls in construction, and industrial protective coatings. Companies in regions with favorable environmental conditions were encouraged to adopt these standards ahead of schedule, aligning with broader goals for improving air quality. From a legal perspective, the revised "Air Pollution Prevention and Control Law" enacted in 2018 clearly stipulates that products must meet relevant VOC content quality standards. Article 44 of the law mandates that the VOC content of raw materials and products containing volatile organic compounds must comply with established quality standards or requirements during production, import, sales, and use. Regarding liability, local market supervision departments at or above the county level have the authority, under Article 103 of the Air Pollution Prevention and Control Law, to order corrective actions against producers and sellers of raw materials or products whose VOC content fails to meet prescribed standards. Such actions may include confiscation of non-compliant materials and products, along with the recovery of illegal profits, accompanied by fines ranging from one to three times the value of the goods involved. Similarly, customs authorities, pursuant to Article 104 of the same law, can impose penalties—including confiscation of non-compliant materials and products—as well as fines equivalent to one to three times the value of the goods, on imported raw materials or products failing to meet VOC content standards. While the Air Pollution Prevention and Control Law does not explicitly address the legal responsibilities of end-users, businesses using raw materials with VOC content that does not meet quality standards may still face potential legal risks. Furthermore, since many of the recently introduced product quality standards restricting VOC content in coatings, inks, adhesives, cleaning agents, and other products are now classified as mandatory national standards, they cannot be produced, sold, imported, or offered unless they comply with these stringent criteria, as mandated by Article 25 of the "Standardization Law." ### II. Which VOC Product Quality Standards Are Relevant? Based on our research and compilation, the following VOC-related product quality standards have already been officially published, with the Ministry of Industry and Information Technology serving as the primary regulatory body: Among these, four standards—specifically "Limit Values for Harmful Substances in Industrial Protective Coatings" (GB 30981-2020), "Limit Values for Volatile Organic Compounds in Adhesives" (GB 33372-2020), "Limit Values for Volatile Organic Compounds in Cleaning Agents" (GB 38508-2020), and "Limit Values for Volatile Organic Compounds (VOCs) in Inks" (GB 38507-2020)—are expected to take effect by the end of this year or early next year, making them especially significant for many industrial enterprises and retail companies engaged in commissioned processing arrangements. ### III. How to Ensure Compliance with VOC Product Quality Standards? 1. **Assess Standard Applicability and Adhere to Applicable Requirements:** First, companies should thoroughly review the relevant standards to determine whether they apply to their own products or raw materials. If compliance is confirmed and no exemptions are available, businesses should promptly explore alternative solutions tailored to their industry and operational context—such as revising product designs or switching suppliers. In practice, we’ve observed that companies often encounter uncertainties regarding the scope of application and exemption criteria outlined in these standards. Given the limited space in this article, we recommend seeking specialized advice from environmental lawyers for guidance on specific issues. 2. **Strengthen Supplier Management:**Supply chain compliance is of great significance to corporate compliance. Companies should pay close attention to conducting thorough compliance reviews, effective management, and targeted training for their suppliers, thereby avoiding potential regulatory risks arising from supplier-related issues. At the same time, businesses must also prioritize contractual safeguards to proactively manage and mitigate the risks that may result from supplier non-compliance. 3. Monitor new regulations and enforcement actions. Companies should closely track any newly issued rules and enforcement initiatives related to VOCs, as well as those introduced by departments such as the State Administration for Market Regulation, the Ministry of Industry and Information Technology, and the Ministry of Ecology and Environment. By staying informed about regulatory priorities, organizations can continuously enhance their own compliance management systems—and those of their suppliers—as well as strengthen their overall risk mitigation strategies.