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How does the EU regulate the use of architectural paints and paint ingredients?

Published 16.02.2022


The European Union (EU) has numerous regulations for the paint products defining their sustainability criteria, evaluating the most common hazards related to the paint ingredients, setting limits for emissions and controlling amounts of the most dangerous substances in paints. The EU also has developed an environmental excellence label (EU Ecolabel) awarded to the paint products with evaluated life cycle assessment that meet both sustainability and performance criteria defined for receiving this label. The legal framework and labels both are tools for encouraging the availability of safer and well performing products on the market as well as increasing awareness about paint hazards in the general public thus resulting in innovative solutions with healthier and more sustainable paint products.

To better understand the measures being taken to protect the consumers of paints available in the EU market, this blog post will provide an insight in the legal framework for architectural paints and their ingredients in the EU.

Why is it important to regulate paint ingredients?

Paint products are among the most widely applied chemically complex products and their health and environmental impacts are often poorly communicated and thus poorly understood by the general public. Paint ingredients, like solvents, can contain dangerous levels of volatile organic compounds (VOCs), pigments can contain heavy metals and common paint additives can include biocides. Lessons learned from the poorly regulated paint market in the past include such examples as use of lead paints, which had led to serious health damage and still have some impact on the human health and wellbeing.

It is important to test and regulate paint products and their ingredients because it involves great number of possible formulations with varied properties, performance and impacts on human health and the environment.    

Unlike the market of natural paints with simplistic formulations such as for lime or chalk paints, the conventional paint market has complicated formulations, which are difficult to fully understand without thorough background in chemistry. Therefore, the general public tends to trust in governments taking care to protect their health and the environment with general legal framework, product regulations, manufacturer monitoring and product testing.

In general, the EU legislation covers the paint products that are available in the European market, limiting paints that contain high levels of heavy metals and VOCs. It must be noted that the EU member states individually also introduce measures, set limitations and launch national environmental label programmes (a).

Important terms and definitions

Life cycle assessment (LCA) - an evaluation tool developed to provide a scientific and transparent basis for the environmental criteria set by the EU Ecolabel. The main aspects covered by the LCA are the following: to compare products based on their functionality; to show a connection of the environmental impacts throughout the product life cycle - from cradle to grave, namely, from raw material sourcing to waste management; to minimise the required data for application, by identification of ecological criteria (b).

Volatile Organic Compounds (VOCs) - organic compounds having at 293,15 K a vapour pressure of 0,01 kPa or more, or having a corresponding volatility under the particular conditions of use (c).    

Biocidal products - active substances and preparations containing one or more active substances, put up in the form in which they are supplied to the user, intended to destroy, deter, render harmless, prevent the action of, or otherwise exert a controlling effect on any harmful organism by chemical or biological means (d).

Legal framework for paints and coatings in the EU

1. Paints Directive (2004/42/EC)

The main objective of the Directive 2004/42/EC, also known as the paints directive, is to limit the total content of volatile organic compounds (VOCs) in paints and varnishes and by doing so to reduce the VOC emissions therefore limiting further formation of the destructive ground level ozone.

According to the paints directive, as of year 2010 the maximum VOC values for solvent-borne and water - borne matt coatings for interior cannot exceed 30 g/l, for interior and exterior trim and cladding paints the values must not exceed 130 g/l for water-borne and 300 g/l for solvent-borne paints and for interior and exterior trim varnishes and stains the values cannot exceed 130 g/l for water-borne varnishes and stains and 400 for solvent-borne varnishes and stains (table 1) (a).

Table 1. The maximum VOC values set by the Directive (2004/42/EC) (a)

Subcategory of product Type of coating Phase I, g/l, ready to use, (01.01.2007) Phase II, g/l, ready to use,  (01.01.2010)
Matt coatings for interior walls, gloss ≤ 25@60° Water-borne Solvent-borne





Interior/exterior trim and cladding paints for wood and metal Water-borne Solvent-borne





Interior/exterior trim varnishes and wood stain, incl. opaque wood stains Water-borne Solvent-borne





The paint directive requires all paint products to carry a label showing the contents of VOC in g/l of the product in a ready-to-use state (a).

2. The EU Ecolabel Regulation (66/2010)

The EU Ecolabel is claimed to be the leading environmental excellence award scheme in Europe, setting standards and criteria paint manufacturers (among others) must comply with in order to be recognised and awarded with the EU Ecolabel. The label is voluntary and third party evaluated. The EU ecolabel takes care to evaluate the life-cycle assessment of paints, while also evaluating their performance when compared to other paints in the market. In doing so the EU Ecolabel guarantees:

  • Minimised content of hazardous substances;
  • Reduced content of volatile organic compounds (VOCs): x g/l     ;
  • Good performance for (both) indoor (and) or outdoor use.

The EU Ecolabel requires that the paints and varnishes comply with certain criteria regarding: White pigment and wet scrub resistance; Titanium dioxide; Efficiency in use; Volatile and Semi-volatile Organic Compounds (VOCs, SVOCs); Restriction of hazardous substances and mixtures; Consumer information (e).

Read more about what it takes to label a paint product with the EU Ecolabel in our blog post: link

3. The Biocidal Products Directive (98/8/EC)

In the EU products having active agents imparting biocidal properties are regulated by the Biocidal Products Directive (98/8/EC). The directive demands that the active biocidal substances are assessed at the Community level, the “Community level” describing recognition and adaptation of the EU member states. It involves mutual recognition of authorisations issued by the member states as well as a list of active substances that can be used in biocidal products. The biocidal products directive addresses primarily the early stages of biocide life-cycle assessment. Therefore, there is still a room for improvement regarding regulations for biocidal products in the EU by adding thorough assessment of the use and waste stages of biocidal products (f; g; h).


REACH is a European Union regulation aiming to protect human health and the environment from the risks associated with chemicals while an integral goal is to work towards competitive EU chemicals industry. REACH applies to all chemical substances including paints and requires paint and paint ingredient manufacturers to provide identification and management of the risks associated with the substances they manufacture and release on the market (i).

5. The Classification, Labelling and Packaging (CLP) Regulation ((EC) No 1272/2008)

The CLP Regulation is created with means to bridge the EU member states in having a united and therefore understandable and recognisable labelling and packaging requirements for the products sold in the EU. The regulation is legally binding and demands that hazards associated with chemicals and chemical products are communicated to professionals and non-professionals.

The CLP Regulation sets criteria for labelling that includes: pictograms, signal words and standard statements for hazard, prevention, response, storage and disposal, for every hazard class and category, and additionally CLP sets the standards for packaging (j).

6. The Carcinogens and Mutagens Directive (Directive 2004/37/EC)

The Carcinogens and Mutagens Directive sets requirements for protecting workers against health and safety risks regarding workplace exposure to carcinogenic and mutagenic substances. The Directive applies to a substance or mixture that meets the criteria for classification as a Category 1A or 1B carcinogen or Category 1A or 1B germ cell mutagen set out in Annex I to the CLP Regulation. In addition, it applies to carcinogenic substances, mixtures or processes referred to in Annex I to the Directive, as well as substances or mixtures released by a process in the respective annex (k).

7. The EU Solvent Directive (1999/13/EC)

The EU Solvent Directive is created with a goal of prevention and reduction of the emissions of volatile organic compounds (VOCs), since these compounds are generally emitted by paint products and have potential of harming human health and the environment. This directive aims to meet the goal by setting emission limits for VOCs as well as laying down operating conditions for installations using organic solvents.

The EU Solvents Directive demands that “solvents or mixtures likely to have a serious effect on human health because of their content of VOCs (classified as carcinogens, mutagens, or toxic to reproduction) must be replaced by less harmful substances or mixtures” (l).




Due to complexity of conventional paint profile, where volatile organic compounds, biocides and heavy metals are used to meet desired paint properties, paint ingredients need a legal framework in order to have rules and regulations for their use. Without this legal framework, such substances can potentially cause harm to human health and the environment. Numerous EU regulations and one leading environmental label scheme provide key limitations and requirements for the paint products placed in the EU market and availability of safer paint products.

Common EU regulations include:

  • The paints directive setting limitations for VOC emissions from paints;
  • The EU Ecolabel awarding environmentally excelling and well performing paints;
  • The biocidal products directive regulating the use of biocides in paints (assessing beginning stages of product life-cycle);
  • REACH requiring chemical manufacturers to manage and assess the risks associated with substance manufacture and release in the market;
  • The Classification, Labelling and Packaging (CLP) Regulation that ensures a united and recognisable packaging and labelling standards across the EU market;
  • The Carcinogens and Mutagens Directive (Directive 2004/37/EC) setting standards for protection of workers exposed to carcinogenic and mutagenic substances;
  • The EU Solvent Directive (1999/13/EC) preventing and reducing the amount of VOC emissions related to solvents.    



Author: written by Anse Romančuka, edited by Linda Kikuste



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