Collision repair and auto body shops typically fall under the NAICS 811121 and SIC 7532. Most of these businesses generate air emissions and hazardous waste from painting processes that are regulated by the state or EPA. This page focuses on the coating-related air quality regulations that impact the sector.  

Since 2008, collision repair and auto body shops have had to come into compliance with a National Emission Standard for Hazardous Air Pollutants known as the NESHAP HHHHHH or 6H rule. The 6H rule impacts area sources involved in one or more of the following activities:  

• Paint stripping operations using chemical strippers that contain methylene chloride 
• Autobody refinishing operations that encompass motor vehicle and mobile equipment spray-applied surface coating operations. However, a business may petition for an exemption from the rule if it can demonstrate that it doesn’t spray apply coatings with any of the five regulated metal HAPs listed under the next activity below.  
• Spray application of coatings containing compounds of chromium, lead, manganese, nickel, or cadmium, to any part or product made of metal or plastic, or combinations of metal and plastic that are not motor vehicles or mobile equipment.

In summary, shops that spray apply coatings containing “targeted HAP” emissions (hazardous air pollutant or HAPs, which include compounds of chromium, lead, manganese, nickel, or cadmium), must take steps to reduce HAP emissions. Although most auto body shops use coatings that do NOT contain these targeted HAPs, the facility is subject to the rule until they claim or petition for exemption (see sample form below). The resources below, which include a link to a new 6H regulatory navigation tool, provide more detail on this rule as it applies to the collision repair industry.  

Beginning May 9, 2023, EPA has instituted the following changes:

• Simplified alternative to the exemption process for sources that do not spray apply coatings containing “target HAP” emissions (hazardous air pollutant (HAP) compounds of chromium, lead, manganese, nickel, or cadmium).
• Acknowledged that emissions standards apply at all times, including during periods of startup, shutdown and malfunction (SSM). The NESHAP’s SSM exemption issue was previously resolved by a change to the General Provisions. Therefore, rule-specific revisions are not necessary.
• Required electronic reporting; and
• Made other minor technical updates and clarifications. See EPA Factsheet .

General resources

• EPA 6H regulatory navigation tool – your first stop as an auto body shop to determine whether the 6H regulation applies to your facility (minor tool update pending)
  • Paint vendors list which paints are 6H rule-exempt 
    • Overview article in AftermarketMatters
    • Repairer-Driven News – explanation of 6H regulatory navigation tool 
• EPA website for 6H rule – paint stripping and miscellaneous surface- coating operations at area sources with rule, and technical and implementation information 
• 6H regulations 
• EPA collision repair campaign to reduce air toxics – includes various tools developed by the EPA and other states 
• EPA collision repair outreach and training resources – includes several outreach materials in English and Spanish, featuring Jeff Gordon in a 19-minute video explaining the NESHAP 6H or "6H rule" 
• Collision repair compliance video in English 
• Foreign language resources

State-specific resources

• Massachusetts hosts MassCAR– complete auto body compliance checklist and training resource   
• Michigan - frequently asked question or FAQ provides helpful clarification 
• Minnesota
• Wisconsin 

Vendor resources  

• 6H vendor petition for exemption resources and training opportunities - paint vendors list which paints are 6H rule-exempt
• Industry trade associations