Michigan AIM VOC Regulations

May 15, 2023

Michigan Department of Environment, Great Lakes, and Energy (EGLE) promulgated R662 Architectural and Industrial Maintenance (AIM) Rule on April 18, 2023. 

There has been some confusion with compliance and promulgation dates, and the quick implementation of the rule.  Here are some explanations of the facts to help you move through the process and stay in compliance.

  • The Rule adopts by reference the OTC Phase II Model Rule that many states around the country have implemented.
  • EGLE finalized/promulgated the Rule on April 18, 2023.
  • The listed compliance date is January 1, 2023. No enforcement action has taken place since the rule was not final until April 18, 2023. The Rule is now fully enforceable.
  • Typically, this rule would have been phased-in over a longer period, but requirements of the Clean Air Act made it necessary for EGLE to implement it before the 2023 ozone season. Also, the reason the compliance date is listed as January 1, 2023.
  • Sell-through period – The sell-through period applies to products manufactured on or before January 1, 2023. Once stocked products manufactured before January 1, 2023, are sold, products must comply with VOC limits listed in the Rule. The sell-through period is three years, beginning January 1, 2023.
    • EGLE understands that there is product on the shelf dated after January 1, 2023, since the rule was not promulgated until April 18, 2023. All new, incoming products must comply with the R662 Architectural and Industrial Maintenance (AIM) Rule.
Michigan AIM VOC Comparison Table
CategoryVOC Limits
Conjugated Oil Varnish450
Conversion varnish725
Shellacs: Clear730
Stains: Interior/Clear and semitransparent250
Wood Coatings275
Small Container (Quart) ExemptionYes
Common coatings that fall under the Wood Coatings category:
Waterborne, Oil-modified Polyurethane, and Moisture Cured Urethane finishes, and penetrating oils.