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Building Code Reference

Got a CALGreen 4.504.2 correction?

Low-VOC materials

For builders in California, Greater Seattle, the Las Vegas area, the Denver area and Kansas City · CrossBeam Permits

What this code requires, how to fix it, and how cities and counties review it

What this code requires

CALGreen 4.504.2 requires that interior finish materials in new residential construction meet low-VOC (volatile organic compound) limits to protect indoor air quality. Paints and coatings must meet the limits in CALGreen Table 4.504.3 (or stricter local limits), adhesives and sealants the SCAQMD Rule 1168 limits in Tables 4.504.1 and 4.504.2, and carpet one of the programs in 4.504.3, such as the Carpet and Rug Institute's Green Label Plus. Plan checkers flag this section when the submitted drawings or specifications don't identify the VOC content of finish materials, or when spec sheets are missing entirely. It applies to new single-family homes, ADUs, and multi-unit residential projects permitted under CalGreen Part 11.

How to fix it

  1. Add a finish materials schedule to the drawings

    Create a finish schedule (or a general notes box) on the architectural plans that lists every interior finish material category: paints and coatings, adhesives and sealants, and carpet or floor coverings. For each category, state the VOC limit required by CALGreen 4.504.2 and identify the specific rule or standard it must comply with. This schedule goes on the same sheet as the interior elevations or on a dedicated notes sheet.

  2. Specify paints and coatings to CALGreen Table 4.504.3

    For every paint or coating going on interior surfaces, the spec must state the maximum VOC content in grams per liter (g/L) for that coating category. CALGreen 4.504.2.2 points to Table 4.504.3, which sets category-by-category limits: flat coatings are capped at 50 g/L, nonflat at 100 g/L, and specialty coatings vary. Where your air district's rule (such as SCAQMD Rule 1113) is more stringent, it governs. Write the note as: 'All interior paints and coatings shall comply with CALGreen Table 4.504.3 or more stringent local VOC limits for the applicable coating category.' If a product is already spec'd, pull the SDS or product data sheet and confirm the VOC content is under the limit before submitting.

  3. Spec adhesives and sealants to SCAQMD Rule 1168

    Every interior adhesive and sealant used on the project needs to comply with SCAQMD Rule 1168. This covers construction adhesives, flooring adhesives, tile-setting adhesive, caulks, and sealants. The spec note should read: 'All interior adhesives and sealants shall comply with SCAQMD Rule 1168 VOC content limits.' Rule 1168 sets limits by product subcategory (e.g., carpet/pad adhesive: 50 g/L, wood flooring adhesive: 100 g/L, architectural sealants: 250 g/L). If you're using a specific product, verify the VOC content on the product's technical data sheet before calling it out.

  4. Confirm carpet meets CRI Green Label Plus

    The spec must state that all carpet will meet CRI (Carpet and Rug Institute) Green Label Plus or another program listed in CALGreen 4.504.3, and that carpet cushion will meet the CDPH Standard Method v1.2 per 4.504.3.1. The note can be general: 'All carpet shall comply with CALGreen 4.504.3 (e.g., CRI Green Label Plus); carpet cushion per 4.504.3.1.' You don't need to name a specific product at permit submission, but the spec must commit to the standard. Green Label Plus limits total VOC, 4-PC (4-phenylcyclohexene), and styrene emissions from carpet systems.

  5. Include product data sheets for spec'd materials

    If you've already selected products, attach the relevant product data sheets or cut sheets as an exhibit to the plans. Plan checkers move faster when they can see the VOC content right next to the spec note. For paint, the data sheet label will list VOC as 'g/L' or 'lbs/gal' (convert: 1 lbs/gal = 119.8 g/L). For adhesives, look for the Rule 1168 compliance statement on the technical data sheet or SDS. For carpet, the Green Label Plus certificate number should appear on the product page.

  6. Use a standard CalGreen compliance checklist

    The California Building Standards Commission publishes a CALGreen Residential Mandatory Checklist that plan checkers often reference. Including a completed copy of this checklist with your submittal shows the plan checker that 4.504.2 has been addressed. The checklist is available through the ICC Digital Codes viewer linked from the Building Standards Commission's codes page at dgs.ca.gov/BSC/Codes. Check the boxes for Section 4.504 and provide the page reference for where each compliance note appears in the plans.

  7. Resubmit with a correction response letter

    When resubmitting after a 4.504.2 correction, include a response letter that directly addresses the flagged item. Reference the sheet and note number where each material category is now specified. For example: 'Sheet A4.1, General Notes Box, Note 12: Paints and coatings per SCAQMD Rule 1113. Sheet A4.1, Note 13: Adhesives per SCAQMD Rule 1168. Sheet A4.1, Note 14: Carpet per CRI Green Label Plus.' This makes it easy for the plan checker to verify the correction without hunting through the set.

Take the CALGreen 4.504.2 fix steps with you

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Why you got flagged

Plan checkers flag CALGreen 4.504.2 for a few consistent reasons, and most of them come down to incomplete paperwork rather than materials that actually fail.

The most common trigger is silence on the plans. A contractor submits a full set with everything the building department asked for, but nowhere on the drawings or in the specifications does it say which paints, adhesives, or carpet are going in. The plan checker can't verify compliance if the materials aren't called out, so the correction goes out. The fix is adding a finish schedule or a general note that references 4.504.2 and lists the VOC category limits each material must meet.

A second scenario involves projects that name a paint brand but skip the VOC content. Saying "paint to match" or "latex eggshell per owner selection" doesn't satisfy the requirement. The specification needs to call out the VOC limit (e.g., "flat coating, maximum 50 g/L VOC per CALGreen Table 4.504.3") and ideally name the product or product line that meets it.

Adhesives and sealants are another common miss. On remodel projects, flooring installers, tile setters, and drywall crews often select adhesives in the field. But plan checkers want to see the spec before they approve the set. If your flooring section doesn't reference Rule 1168 limits for the adhesive, expect a correction. On ADU projects, this often shows up when a contractor submits a basic plan package without a finish legend.

Carpet selection is the fourth trap. CRI Green Label Plus is the most common of the programs CALGreen 4.504.3 accepts, but "carpet TBD" doesn't pass plan check. The spec needs to confirm the carpet will meet one of those programs before the permit is issued.

The official code

California Green Building Standards Code (CALGreen) Part 11 — Section 4.504 Pollutant Control

Read the source →

Common questions

Does CALGreen 4.504.2 apply to ADU projects?
Yes. ADUs permitted as new construction are subject to CalGreen mandatory measures, including Section 4.504.2. If you're building a detached ADU or converting a garage into an ADU with a full permit, the interior finish materials need to meet the VOC limits. Attached ADU additions that are part of a larger project also trigger the requirement. The most common miss on ADU submittals is forgetting to add finish notes at all because the plans are simpler and contractors assume a small package won't need the full checklist. It does.
What's the actual VOC limit for interior paint under CalGreen 4.504.2?
CalGreen 4.504.2.2 points to Table 4.504.3 for paint and coating limits, unless stricter local limits such as SCAQMD Rule 1113 apply. The table sets limits by coating category. For flat architectural coatings (standard interior wall paint), the limit is 50 g/L VOC. For nonflat architectural coatings (semi-gloss, gloss, satin used on trim and cabinets), the limit is 100 g/L VOC. Most major paint brands now sell low-VOC or zero-VOC lines that come in well under these thresholds. Check the label for VOC content in g/L before speccing a product. If the label shows 'oz/gal' or 'lbs/gal,' multiply lbs/gal by 119.8 to convert to g/L.
Do I need to submit product data sheets with my permit application?
You don't have to submit product data sheets with the initial application, but having them ready speeds up plan check. What you do need is a spec note or finish schedule on the drawings that calls out the compliance standard for each material category. If the plan checker has questions, they may request data sheets as a supplemental document. Providing them upfront with a correction resubmittal can cut your review time down significantly. Some jurisdictions are stricter than others on this, so check your local building department's standard plan check comments for CalGreen.
What counts as an 'equivalent' to CRI Green Label Plus for carpet?
CalGreen 4.504.3 lists the programs carpet can meet: CRI Green Label Plus, CDPH Specification 01350, NSF/ANSI 140 at the Gold level, or SCS Indoor Advantage Gold. Carpet cushion is covered separately by 4.504.3.1. In practice, most contractors and designers default to Green Label Plus because it's the most recognized certification in the residential market. If you want to use a program not on that list, confirm with your plan checker before speccing it to avoid a second correction cycle.
Is SCAQMD Rule 1168 the same as the California Air Resources Board adhesive standard?
They're related but not the same. SCAQMD Rule 1168 is a South Coast Air Quality Management District rule that CalGreen 4.504.2 specifically references for adhesives and sealants. The California Air Resources Board (CARB) also has a consumer products regulation that covers some adhesive VOC limits under different thresholds. CalGreen points to Rule 1168, so that's the standard your spec note needs to cite. If a product data sheet references 'CARB Compliant' but not Rule 1168, you may still need to verify the VOC content against the Rule 1168 subcategory limits before using it on a CalGreen project.
What happens if a subcontractor uses a non-compliant adhesive in the field?
Field substitutions that don't meet 4.504.2 can create problems at final inspection, especially if the inspector asks for compliance documentation. The correction letter is issued against the permit, not just the submittal, so if a flooring sub uses a product that doesn't meet Rule 1168, it's the GC's problem during inspection. The safest approach is to include the VOC requirement in your subcontractor scope of work and require them to submit a product data sheet before installation. Some GCs keep a short approved-products list for adhesives and sealants on CalGreen jobs to avoid surprises.

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