See Full Document Text
Official Journal EN
of the European Union L series
2025/2607 22.12.2025
COMMISSION DECISION2025/2607
of 17 December 2025
establishing the EU Ecolabel criteria for decorative paints, varnishes, and related products,
performance coatings and related products, and water-based aerosol spray paints and repealing
Decision 2014/312/EU
(notified under document C(2025) 8879)
(Text with EEA relevance)
THE EUROPEAN COMMISSION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Regulation (EC) No 66/2010 of the European Parliament and of the Council of 25 November 2009 on the
EU Ecolabel(1), and in particular Article 8(2) thereof,
After consulting the European Union Ecolabelling Board,
Whereas:
(1) Under Regulation (EC) No 66/2010, the EU Ecolabel may be awarded to those products with a reduced
environmental impact during their entire life cycle.
(2) Regulation (EC) No 66/2010 provides that specific EU Ecolabel criteria are to be established according to product
groups.
(3) Commission Decision 2014/312/EU(2) established EU Ecolabel criteria and related assessment and verification
requirements for the product group ‘indoor and outdoor paints and varnishes’. Those criteria and the related
assessment and verification requirements are valid until 31 December 2025.
(4) Two separate sets of criteria for decorative paints, varnishes, and related products, and performance coatings and
related products (previously referred to as ‘indoor and outdoor paints and varnishes’) are needed to better reflect best
practice in the market and to take account of policy developments, potential future opportunities for increased
uptake and the market’s demand for sustainable products. A third set of new criteria for water-based aerosol spray
paints, an additional product group with a potential growing market, is also needed.
(5) In line with those conclusions and after consulting the EU Ecolabelling Board, it is appropriate to split the product
group ‘indoor and outdoor paints and varnishes’ into two product groups, ‘decorative paints, varnishes, and related
products’ and ‘performance coatings and related products’. The scope of the Decision should also be expanded to
cover the new product group ‘water-based aerosol spray paints’.
(6) The EU Ecolabel fitness check report(3) of 30 June 2017, reviewing the implementation of Regulation (EC)
No 66/2010 concluded that a more strategic approach was needed for the EU Ecolabel, including bundling the
criteria of closely related product groups together where appropriate.
(1) OJ L 27, 30.1.2010, p. 1, ELI: http://data.europa.eu/eli/reg/2010/66/oj.
(2) Commission Decision 2014/312/EU of 28 May 2014 establishing the ecological criteria for the award of the EU Ecolabel for indoor
and outdoor paints and varnishes (OJ L 164, 3.6.2014, p. 45, ELI: http://data.europa.eu/eli/dec/2014/312/oj).
(3) Report from the Commission to the European Parliament and the Council on the review of implementation of Regulation (EC)
No 1221/2009 of the European Parliament and of the Council of 25 November 2009 on the voluntary participation by organisations
in a Community eco-management and audit scheme (EMAS) and the Regulation (EC) No 66/2010 of the Parliament and of the Council
of 25 November 2009 on the EU Ecolabel (COM(2017) 355 final).
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(7) The new circular economy action plan for a cleaner and more competitive Europe(4) adopted on 11 March 2020
underlines that durability, energy and resource efficiency, and carbon and environmental footprint requirements are
to be included more systematically in EU Ecolabel criteria.
(8) The revised EU Ecolabel criteria for decorative paints, varnishes, and related products, performance coatings and
related products, and water-based aerosol spray paints should aim to promote products that have limited
environmental impact throughout their life cycle, which are produced using material-efficient and energy-efficient
processes. In particular, those criteria should promote products that have limited impacts in terms of emissions to
water and air during production, emissions of volatile compounds during application, and which contain only a
limited amount of hazardous substances. The criteria should also encourage efficient use of the product and
recommend how to deal with unused product, thereby contributing to the transition to a more circular economy.
(9) The new criteria and related assessment and verification requirements should be valid until 31 December 2032,
taking into account the product groups’ innovation cycle.
(10) For reasons of legal certainty, Decision 2014/312/EU should be repealed.
(11) During a transitional period, manufacturers whose products have been awarded the EU Ecolabel for indoor and
outdoor paints and varnishes on the basis of the criteria established in Decision 2014/312/EU, have sufficient time
to adapt their products to comply with the new criteria and requirements laid down in this Decision. For a limited
period after this Decision has entered into application, manufacturers should also be allowed to submit applications
based either on the criteria established by Decision 2014/312/EU or on the new criteria established by this Decision.
EU Ecolabel licences awarded under the criteria established in Decision 2014/312/EU should remain valid for 18
months from the date this Decision is adopted.
(12) Water-based aerosol spray paints should not be considered suitable substitutes for conventional paints in large-scale
applications, for both wall and ceiling surfaces. This is because their typical coverage rate does not exceed 2,0 m2per
litre, in contrast to conventional paints, which generally achieve a coverage rate of no less than 8,0 m2per litre.
(13) The measures provided for in this Decision are in accordance with the opinion of the Committee established by
Article 16 of Regulation (EC) No 66/2010.
HAS ADOPTED THIS DECISION:
Article 1
1. The product group ‘decorative paints, varnishes, and related products’ shall comprise indoor and outdoor paints,
varnishes, woodstains and primers whose primary purpose is to impart decorative characteristics to buildings, their trim
and fittings and associated structures and that fall under the scope of subcategories 1.1(a) to (h) of Annex I to
Directive 2004/42/EC of the European Parliament and of the Council(5).
Decorative paint products shall include tinting bases and different colour shades achieved by tinting, either predefined by
the manufacturer or at the customised request of consumers (professional or non-professional) to operators of tinting
systems.
Decorative paints or varnishes not covered by Directive 2004/42/EC which are supplied in powder or granule form, and
that are to be diluted and mixed with water prior to use for decorative purposes, shall also be included in the scope of this
product group if marketed for use in line with one of subcategories 1.1(a) to (h) of Annex I to Directive 2004/42/EC.
(4) Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and
the Committee of the Regions, A new Circular Economy Action Plan for a cleaner and more competitive Europe (COM(2020) 98
final) (OJ C 364, 28.10.2020, p. 94).
(5) Directive 2004/42/CE of the European Parliament and of the Council of 21 April 2004 on the limitation of emissions of volatile
organic compounds due to the use of organic solvents in certain paints and varnishes and vehicle refinishing products and amending
Directive 1999/13/EC (OJ L 143, 30.4.2004, p. 87, ELI: http://data.europa.eu/eli/dir/2004/42/oj).
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2. The product group ‘decorative paints, varnishes, and related products’ shall not include the following:
(a) performance coatings as defined in subcategories 1.1(i) and 1.1(j) of Annex I to Directive 2004/42/EC;
(b) multicoloured coatings as defined in subcategory 1.1(k) of Annex I to Directive 2004/42/EC;
(c) decorative effect coatings as defined in subcategory 1.1(l) of Annex I to Directive 2004/42/EC;
(d) anti-fouling coatings;
(e) wood preservatives;
(f) any other coating systems marketed as having anti-microbial, anti-bacterial, anti-viral, disinfectant or other primary
biocidal effects for the benefit of human health or related to hygiene standards in the food or drink industry, health
services or any other sector, that extend beyond in-can preservation and preservation of the dry film (that is to say,
beyond biocidal product types 6 and 7 as defined in Annex V to Regulation (EU) No 528/2012 of the European
Parliament and of the Council(6));
(g) coatings and coating systems designed for use in industrial processes, such as powder coatings applied as powders to
substrates and coatings that are cured by UV radiation;
(h) coatings primarily intended for vehicles;
(i) wood oils and waxes;
(j) fillers, plasters, grouts, sealants and adhesives;
(k) cement-based paints;
(l) aerosol spray paints;
(m) road-marking paints.
Article 2
1. The product group ‘performance coatings and related products’ shall comprise certain one-pack and multi-pack
performance coating products whose primary purpose is to impart special performance characteristics to buildings, their
trim and fittings and associated structures and that fall under the scope of subcategories 1.1(i) and 1.1(j) of Annex I to
Directive 2004/42/EC.
The product group shall comprise floor coatings, anti-corrosion coatings, waterproofing coatings, radiator paints and any
associated primers intended for use by consumers and professional users in buildings, their trim, fittings or associated
structures.
2. The product group ‘performance coatings and related products’ shall not include the following:
(a) anti-fouling coatings;
(b) wood preservatives;
(c) any other coating systems marketed as having anti-microbial, anti-bacterial, anti-viral, disinfectant or other primary
biocidal effects for the benefit of human health or related to hygiene standards in the food or drink industry, health
services or any other sector, that extend beyond in-can preservation and preservation of the dry film (that is to say,
beyond biocidal product types 6 and 7 as defined in Annex V to Regulation (EU) No 528/2012);
(d) coatings and coating systems designed for use in industrial processes, such as powder coatings applied as powders to
substrates and coating systems that are cured by UV radiation;
(e) coatings primarily intended for vehicles;
(6) Regulation (EU) No 528/2012 of the European Parliament and of the Council of 22 May 2012 concerning the making available on the
market and use of biocidal products (OJ L 167, 27.6.2012, p. 1, ELI: http://data.europa.eu/eli/reg/2012/528/oj).
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(f) wood oils and waxes;
(g) fillers, plasters, grouts, sealants and adhesives;
(h) cement-based paints;
(i) coatings designed to impart flame retardancy;
(j) coatings designed to impart graffiti resistance;
(k) road-marking paints.
Article 3
1 The product group ‘water-based aerosol spray paints’ shall comprise integral ready-to-use metal packages intended to
be used by consumers and professional users to impart decorative or special performance characteristics to buildings, their
trim or fittings and associated structures.
The metal packages shall be equipped with a valve and a water-based paint formulation which is dispensed by pre-stored
pressure in a controlled manner when the valve is operated.
2. The product group ‘water-based aerosol spray paints’ shall not include the following:
(a) aerosol spray paints with an organic solvent-based paint formulation;
(b) aerosol spray paints that are classified as an extremely flammable aerosol (H222) or a flammable aerosol (H223)
under the classification rules for mixtures set out in Regulation (EC) No 1272/2008 of the European Parliament and
of the Council(7);
(c) aerosol spray paints marketed as having anti-microbial, anti-bacterial, anti-viral, disinfectant or other primary
biocidal effects for the benefit of human health or related to hygiene standards in the food or drink industry, health
services or any other sector, that extend beyond in-can preservation and preservation of the dry film (that is to say,
beyond biocidal product types 6 and 7 as defined in Annex V to Regulation (EU) No 528/2012);
(d) water-based aerosol spray paints marked as substitutes for conventional paints in large-scale applications, for both
wall and ceiling surfaces;
(e) water-based aerosol spray paints used for road-marking paints.
Article 4
For the purposes of this Decision, the following definitions shall apply:
(1) ‘aerosol spray paints’ means aerosol dispensers which are non-refillable receptacles made of metal and containing a
gas that is compressed, liquefied or dissolved under pressure, with a paint formulation, and fitted with a release
device allowing the contents to be ejected as solid or liquid particles in suspension in a gas, as a paste or in a liquid
state;
(2) ‘alkylphenols and alkylphenol ethoxylates’ means organic compounds obtained by the alkylation of phenols and the
ethoxylation of alkylphenols, including all the compounds listed in entry 43 of Annex XIV or entry 46 of
Annex XVII of Regulation (EC) No 1907/2006 of the European Parliament and of the Council(8);
(3) ‘anti-algal’ means coating products to prevent or reduce deterioration of the coating film due to algal growth;
(7) Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on classification, labelling and
packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC, and amending Regulation
(EC) No 1907/2006 (OJ L 353, 31.12.2008, p. 1, ELI: http://data.europa.eu/eli/reg/2008/1272/oj).
(8) Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration,
Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, amending
Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as
Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC (OJ L 396,
30.12.2006, p. 1, ELI: http://data.europa.eu/eli/reg/2006/1907/oj).
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(4) ‘anti-fouling coating’ means coating materials applied to the underwater sections of a ship´s hull or to other
underwater structures to discourage the growth of organisms;
(5) ‘anti-fungal’ means coating products to prevent or reduce the growth of mould or deterioration of the coating film
due to fungal growth;
(6) ‘anti-microbial’ or ‘anti-bacterial’ means the property of a coating product to inhibit or prevent the growth and
proliferation of microorganisms or bacteria on its surface under conditions conducive to microbial colonisation,
encompassing both preservative and disinfectant product types as defined in Annex V to Regulation (EU)
No 528/2012;
(7) ‘anti-corrosion coatings’ means coating products designed to prevent corrosion in metal substrates in the presence of
oxygen and moisture, through the application of a protective coating;
(8) ‘binding primers’, as defined in subcategory 1.1(h) of Annex I of Directive 2004/42/EC;
(9) ‘cement-based paints’ means powdered paints containing significant amounts of Portland cement or other cement in
the formulation and which need to be carefully mixed with water prior to application;
(10) ‘coatings for exterior walls of mineral substrate’ as defined in subcategory 1.1(c) of Annex I of Directive 2004/42/EC;
(11) ‘cross-linking agents’ means substances that facilitate the establishment of covalent or non-covalent (supramolecular)
bonds between separate polymer chains or between non-neighbour parts of the same polymer chain and thus change
the properties of the coating (for example drying, mechanical resistance, chemical resistance, adhesion);
(12) ‘dead matt paints’ are paints which, at an angle of incidence of 85°, give a reflectance of < 5;
(13) ‘decorative purpose’ means a treatment whose primary objective is to change or restore the appearance of a substrate;
(14) ‘dry-film preservatives’ means biocidal products within the meaning of Article 3(1), point (a), of Regulation (EU)
No 528/2012 for use in product type 7 as described in Annex V to that Regulation, used to preserve films or
coatings by controlling microbial deterioration or algal growth to protect the initial properties of the surface of
materials or objects;
(15) ‘elastomeric paints’ means paints designed to provide a high-quality decorative and protective finish for masonry
surfaces by bridging and sealing cracks in the substrate and which, thanks to their elastic properties and the use of
thicker applied films, can stretch and shrink with thermally driven building movement, thus improving the
durability of the underlying masonry material;
(16) ‘family of products’ means a group of coating products made by the same manufacturer with the same base
formulation and product subcategory, but which only differ in terms of the shade and/or packaging format;
(17) ‘filler’ means a coating material with a high proportion of extender, intended primarily to even out irregularities in
substrates to be painted and to improve surface appearance;
(18) ‘film-forming synthetic polymer microparticles’ means synthetic polymer microparticles that are added to the paint
or varnish formulation, or its ingredients, and the physical properties of which are permanently modified during the
application and curing of the paint or varnish formulation to form a film;
(19) ‘final products’ means decorative paints, varnishes, and related products; performance coatings and related products;
and water-based aerosol spray paints, that are awarded the EU Ecolabel, in the form in which they are sold to
customers;
(20) ‘floor coatings and floor paints’ means coatings and paints specifically formulated to be applied to flooring, for the
purpose of protecting or colouring the flooring substrate;
(21) ‘gloss paints’ means paints which, at an angle of incidence of 60°, give a reflectance of ≥ 60;
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(22) ‘impurities’ means unintended constituents (residuals, pollutants, contaminants, by-products, etc.) that remain in the
EU Ecolabel product in concentrations less than 100 ppm (0,0100 % w/w, 100 mg/kg) or that remain in the
supplied ingredient or raw material in concentrations less than 1 000 ppm (0,100 % w/w, 1 000 mg/kg). Any
unintended constituents present above these respective limits for the EU Ecolabel product or the supplied ingredient
or raw material shall instead be considered as ingoing substances;
(23) ‘in-can preservatives’ means biocidal products within the meaning of Article 3(1), point (a), of Regulation (EU)
No 528/2012 for use in product type 6 as described in Annex V to that Regulation, in particular to preserve
manufactured products during storage by controlling microbial deterioration to protect their shelf life, and used to
preserve tints that will be dispensed from machines;
(24) ‘ingoing substances’ means constituents (as pure substances or as part of a mixture, and regardless of the amount)
that are intentionally added to the final product or its ingredients to achieve or influence certain properties of the
final product or its ingredients; substances known to be released from ingoing substances after they have been added
(for example formaldehyde from preservatives and arylamine from azodyes and azopigments) shall also be regarded
as ingoing substances; unintended constituents present in the final product or its ingredients in concentrations
which exceed the permitted concentrations for impurities, shall be considered as ingoing substances;
(25) ‘interior/exterior trim and cladding paints for wood, metal or plastic’, as defined in subcategory 1.1(d) of Annex I of
Directive 2004/42/EC,
(26) ‘interior/exterior trim varnishes and woodstains’, as defined in subcategory 1.1(e) of Annex I of
Directive 2004/42/EC;
(27) ‘just add water decorative paints or varnishes’ means paints or varnishes that are supplied in powder form, which do
not use cement binders, and which simply need to be mixed with water before use as any one of the categories
defined in subcategories 1.1(a) to 1.1(h) of Annex I of Directive 2004/42/EC;
(28) ‘lasure (woodstain)’ means a coating material containing small amounts of a suitable pigment and/or extender and
used to form a transparent or semi-transparent film to decorate and/or protect the substrate;
(29) ‘light-coloured coating’ means a coating with tristimulus values Y and Y10 greater than 25, measured with a
spectrophotometer on a black and white substrate;
(30) ‘masonry coating’ means a coating that produces a decorative and protective film for use on concrete, paintable
brickwork, blockwork, rendering, calcium silicate board or fibre-reinforced cement;
(31) ‘matt or glossy coatings for interior walls and ceilings’ means coatings designed for application to indoor walls and
ceilings, which deliver a dead matt, matt, semi-matt, satin, semi-gloss or gloss finish;
(32) ‘matt paints’ means paints which, at an angle of incidence of 85°, give a reflectance of < 10 and ≥ 5;
(33) ‘mid-sheen paints’ (also referred to as semi-gloss, satin, semi-matt) are paints which, at an angle of incidence of 60° or
of 85°, give a reflectance of < 60 and ≥ 10;
(34) ‘minimal build woodstains’, as defined in subcategory 1.1(f) of Annex I of Directive 2004/42/EC;
(35) ‘mixture’, as defined in Article 3(2) of Regulation (EC) No 1907/2006;
(36) ‘multi-pack performance coatings’ means coatings with the same use as one-performance coatings, but with a second
component for example tertiary amines) added prior to application;
(37) ‘neutralising agent’ means a chemical substance or material added to coating formulations that acts as a Bronsted
base, Bronsted acid, Lewis base or Lewis acid in order to stabilise the pH of the coating formulation and prevent
unwanted reactions or degradations during production, storage and application that would adversely affect the
properties of the coating product and the resulting dry film;
(38) ‘one-pack performance coatings’, as defined in subcategory 1.1(i) of Annex I of Directive 2004/42/EC;
(39) ‘opaque’ means a film with a contrast ratio of ≥ 98 % at 120 μm wet film thickness;
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(40) ‘organotin compounds’ means any organometallic compound with at least one Sn-C covalent bond;
(41) ‘paint’ means a pigmented coating material, supplied in a liquid, paste or powder form, which, when applied to a
substrate, forms an opaque film having protective, decorative or specific technical properties, which after application
dries to a solid, adherent and protective coating;
(42) ‘PFAS’ means any substance that contains at least one fully fluorinated methyl (CF -) or methylene (-CF -) carbon
3 2
atom (without any H/Cl/Br/I attached to it), except a substance that only contains the following structural elements:
CF -X or X-CF -X’, where X = -OR or -NRR’ and X’ = methyl (-CH ), methylene (-CH -), an aromatic group, a
3 2 3 2
carbonyl group (-C(O)-), -OR", -SR" or –NR"R"’, and where R/R’/R"/R"’ is a hydrogen (-H), methyl (-CH ), methylene
3
(-CH -), an aromatic group or a carbonyl group (-C(O)-);
2
(43) ‘phthalates’ means esters of phthalic acid / orthophthalic acid / 1,2- benzene dicarboxylic acid;
(44) ‘plasters’ means premixed materials designed for plastering interior or exterior walls and ceilings, including gypsum
plasters, solvent-free pasty plasters, masonry mortars and structural wall paints designed for use indoors as internal
plaster with a thickness of > 400 μm and/or a minimum coverage of < 2 m2/l;
(45) ‘powder coating’ means protective or decorative coating formed by the application of a coating powder to a substrate
and fusion to create a continuous film;
(46) ‘primers’, as defined in subcategory 1.1(g) of Annex I of Directive 2004/42/EC;
(47) ‘road-marking paints’ means, paints that form part of the means for horizontal signage and require a functional
component to provide road safety;
(48) ‘subcategory of products’ means a defined purpose of use for which a coating product has been formulated and which
aligns with the subcategories defined in section 1.1 under the scope of Annex I to Directive 2004/42/EC. For clarity,
aerosol spray paints shall always be considered as a separate subcategory from conventional paints even if they share
the same final purpose of use;
(49) ‘substance’, as defined in Article 3(1) of Regulation (EC) No 1907/2006;
(50) ‘transparent’ and ‘semi-transparent’ means a film with a contrast ratio of < 98 % at 120 μm wet film thickness;
(51) ‘tinting system’ means a method for preparing coloured paints by mixing a ‘tinting base’ with colour tint;
(52) ‘TiO nanoform’ means a form of TiO meeting the requirements of nanoform in accordance with the Regulation
2 2
(EC) No 1907/2006, irrespective of whether it is actually required to be registered pursuant to that Regulation;
(53) ‘trim and cladding’ are building elements with functional and aesthetic roles. Trim refers to finishing materials around
edges or openings, such as doors and windows, that are used to conceal joints, protect surfaces and enhance design.
Cladding is the application of one material over another in a building in order to protect the underlying material,
improve building envelope insulation and/or contribute to visual appeal;
(54) ‘tristimulus values’ means the amount of reference colour stimuli, in a given trichromatic system, required to match
the colour of the stimulus considered. In the CIE standard colorimetric systems (for example CIE 1931 and CIE
1964) the tristimulus values are represented, for example, by the symbols R, G, B; X, Y, Z; R10, G10, B10, or X10,
Y10, Z10;
(55) ‘undercoat’ is a preparatory layer applied before the final coat of paint or varnish, designed to improve adhesion, level
the surface, seal porosities, enhance colour perception for darker shades and/or provide additional protection to the
substrate;
(56) ‘UV curable paint system’ means the hardening of coating materials by exposure to artificial ultra-violet radiation;
(57) ‘varnish’ means a clear coating material which, when applied to a substrate, forms a solid transparent film having
protective, decorative or specific technical properties, which after application dries to a solid, adherent and
protective coating;
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(58) ‘waterproofing coatings’ means coating products and systems (including any primers and undercoats) applied in
liquid form to seal roof surfaces (including green roofs), interior or exterior floor surfaces in a building and building
elements in contact with soil;
(59) ‘waxes’ means a group of organic compounds that are typically solid at room temperature and become malleable or
liquid when heated;
(60) ‘wood oils’ means oils used to care for and protect wood (for example pearling effect) without any cleaning action;
(61) ‘wood preservative’ are biocidal products within the meaning of Article 3(1)(a) of Regulation (EU) No 528/2012 for
use in product type 8 as described in Annex V to that Regulation, they are used for the preservation of wood, from
and including the saw-mill stage, or wood products by the control of wood-destroying or wood-disfiguring
organisms, including insects.
Article 5
1. In order for a product to be awarded the EU Ecolabel under Regulation (EC) No 66/2010 for the product group
‘decorative paints, varnishes, and related products’, it shall fall within the definition of that product group in Article 1 of
this Decision, and shall comply with the respective criteria and related assessment and verification requirements
established in Annex I to this Decision.
2. In order for a product to be awarded the EU Ecolabel under Regulation (EC) No 66/2010 for the product group
‘performance coatings and related products’, it shall fall within the definition of that product group in Article 2 of this
Decision and shall comply with the respective criteria and related assessment and verification requirements established in
Annex II to this Decision.
3. In order for a product to be awarded the EU Ecolabel under Regulation (EC) No 66/2010 for the product group
‘water-based aerosol spray paints’, it shall fall within the definition of that product group in Article 3 of this Decision and
shall comply with the respective criteria and related assessment and verification requirements established in Annex III to
this Decision.
Article 6
The EU Ecolabel criteria for the product groups ‘decorative paints, varnishes, and related products’, ‘performance coatings
and related products’, and ‘water-based aerosol spray paints’ and the related assessment and verification requirements shall
be valid until 31 December 2032.
Article 7
1. For administrative purposes, the code number assigned to the product group ‘decorative paints, varnishes, and related
products’ shall be ‘044’.
2. For administrative purposes, the code number assigned to the product group ‘performance coatings and related
products’ shall be ‘056’.
3. For administrative purposes, the code number assigned to the product group ‘water-based aerosol spray paints’ shall
be ‘057’.
Article 8
Decision 2014/312/EU is repealed.
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Article 9
1. Applications submitted before the date of application of this Decision for the EU Ecolabel for the product group
‘indoor and outdoor paints and varnishes’, as defined in Decision 2014/312/EU, shall be evaluated in accordance with the
conditions established in that Decision.
2. Applications for the EU Ecolabel for products falling within the product group ‘indoor and outdoor paints and
varnishes’ as defined in Decision 2014/312/EU submitted within 2 months following the date of application of this
Decision may be based either on the criteria established in this Decision, or on the criteria established in
Decision 2014/312/EU. Those applications shall be evaluated in accordance with the criteria on which they are based.
3. EU Ecolabel licences awarded on the basis of an application evaluated in accordance with the criteria established in
Decision 2014/312/EU may be used for 18 months from the date of application of this Decision.
Article 10
This Decision is addressed to the Member States.
Done at Brussels, 17 December 2025.
For the Commission
Jessika ROSWALL
Member of the Commission
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ANNEX I
EU Ecolabel criteria for awarding the EU Ecolabel to decorative paints, varnishes, and related
products
The EU Ecolabel criteria target the best paints, varnishes, and related products on the market, in terms of environmental
performance. The criteria focus on the main environmental impacts associated with the life cycle of these products and
promote circular economy aspects.
Assessment and verification requirements
For the EU Ecolabel to be awarded to a specific product, the product shall comply with each requirement. The applicant
shall provide a written confirmation stating that all the criteria are fulfilled.
Specific assessment and verification requirements are indicated within each criterion.
Where the applicant is required to provide declarations, documentation, analyses, test reports, or other evidence to show
compliance with the criteria, these may originate from the applicant and/or their supplier(s) as appropriate.
Competent bodies shall preferentially recognise attestations that are issued by bodies accredited in accordance with the
relevant harmonised standard for testing and calibration laboratories, and verifications by bodies that are accredited in
accordance with the relevant harmonised standard for bodies certifying products, processes, and services.
Where appropriate, test methods other than those indicated for each criterion may be used if the competent body assessing
the application accepts their equivalence.
Where appropriate, competent bodies may require supporting documentation and may carry out independent verifications
or site inspections to check compliance with these criteria.
Changes in suppliers and production sites pertaining to products to which the EU Ecolabel has been awarded shall be
notified to competent bodies, together with supporting information to enable verification of continued compliance with
the criteria.
As pre-requisite, the product shall meet all respective legal requirements of the country or countries in which the product is
intended to be placed on the market. The applicant shall declare the product’s compliance with this requirement.
The following information shall be provided together with the application for the EU Ecolabel:
(a) A list of all individual paint and varnish products covered by the EU Ecolabel application, grouped into product
families and indicating any relevant product characteristics that affect which specific requirements from the EU
Ecolabel criteria would apply. A family of products will all have the same base formulation and product subcategory,
but may differ in terms of shade and/or packaging format.
(b) A description of the product formulation(s), with a % composition of the ingredients used and the specific function of
each ingredient (the composition information may be subject to a non-disclosure agreement between the applicant
and the competent body or, in some cases, directly between the supplier and the competent body). Ingredient
functions shall be either: accelerator; additive; anti-blocking agent; anti-foaming agent; anti-settling agent; anti-
skinning agent; binder; coalescing agent; colourant-dyestuff; colourant-pigment; crosslinking agent; curing agent/
hardener; diluent; dispersing agent; drier; filler; dry-film preservative; in-can preservative; matting agent; neutralising
agent; optical brightener; plasticiser; polymer dispersion; preservative stabiliser; resin; retarder; rheological modifier;
silicone resin; solvent; surfactant; UV stabiliser; water; water-repelling agent or, in case none of these apply, ‘other’.
(c) Safety data sheets for the ingredients used in the paint and varnish formulations.
(d) Any other information associated with the production of ingredients and materials that is necessary for
demonstrating compliance with the EU Ecolabel criteria shall be provided by the suppliers or producers of those
ingredients and materials.
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(e) In order to help determine the number of products within any given family of products, a description of the
packaging format(s) used, the volume(s) of product held and the packaging material(s) used for each of the paint and
varnish products covered by the EU Ecolabel application.
(f) In order to reduce the quantity of testing and documentation required for assessment and verification procedures,
several criteria explicitly state that compliance of an entire family of products can be assumed if the worst-case
product can be shown to comply. Each time data for a worst-case product is submitted, it shall be accompanied by
an explanation of why this particular product represents the worst-case within its family of products for the
property being tested.
Criterion 1. Titanium dioxide production
If the final product contains more than 3,0 % w/w of titanium dioxide (TiO ) pigment, the emissions to air and water from
2
the production of any titanium dioxide pigment used shall meet the relevant requirements listed below for the respective
production processes:
Table 1
Requirements for Titanium Dioxide production
Parameter and analytical method Sulphate process Chloride process
Emissions of dust to air(1)(measured with the relevant ≤ 0,40 kg/t TiO pigment ≤ 0,66 kg/t TiO pigment
2 2
European or international standards)
Emissions of SO to air(1)(measured with the relevant ≤ 4,5 kg/t TiO pigment n/a
2 2
European or international standards)
Emissions of HCl to air(1)(measured with the relevant n/a ≤ 0,70 kg/t TiO pigment
2
European or international standards)
Emissions of SO 2-to water (measured with the relevant ≤ 300 kg SO 2-/t TiO n/a
4 4 2
European or international standards) pigment
Emissions of Cl-to water (measured using the mass n/a ≤ 103 kg Cl-/t TiO pigment(2)
2
balance method or with the relevant European or ≤ 179 kg Cl-/t TiO pigment(3)
2
international standards) ≤ 329 kg Cl-/t TiO pigment(4)
2
Low dust working environment To be demonstrated To be demonstrated
(1) Point sources for emissions of dust to air from the chloride process are considered as: milling, chlorination, oxidation and
micronisation stages. Point sources for emissions of HCl to air from the chloride process are considered as: chlorination, acid
scrubber from solid separation and metal chloride treatment processes. Point sources for emissions of dust to air from the sulphate
process are considered as: milling, digestion, calcination and micronisation stages. Point sources for emissions of SO to air from the
2
sulphate process are considered as: digestion and calcination processes.
(2) When ore used is > 95 % TiO content.
2
(3) When ore used is 90-95 % TiO content.
2
(4) When ore used is < 90 % TiO content.
2
Emissions to air shall be counted from the relevant point source(s) stated in point (1) above where emissions can be
continuously or periodically monitored from a fixed sampling point after any exhaust gas abatement system(s).
Emissions to water shall be considered as sulphate or chloride present in any treated wastewater effluent that is discharged
into any rivers, lakes, transitional waters, coastal waters or seawaters.
The relevant limit for chloride emissions to water shall be based on the weighted average % TiO content of ore(s) used
2
during the calculation period.
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A low dust working environment shall, as a minimum, include the follows aspects:
— A risk assessment for the workplace that identifies all the main areas of potential dust emission and worker exposure
to dust.
— The need to have in place an occupational hygiene workplace monitoring program.
— Provision of appropriate training to employees about good practice for dust control.
— Provision of adequate personal protective equipment to employees and visitors.
Assessment and verification
The applicant shall declare the content of TiO used in each of the product formulations subject to the EU Ecolabel license
2
application. For any products with more than 3,0 % w/w TiO pigment content, the applicant shall also declare the supplier
2
or suppliers of the TiO used in those products.
2
The applicant declaration shall be supported by declarations from their TiO supplier(s) (or TiO producer(s), if different)
2 2
stating:
— The type of TiO production process used (chloride or sulphate).
2
— The applicable TiO content range of the weighted average ore in case of the chloride process.
2
— Annual average emissions data of dust to air, SO to air, and SO 2-to water for TiO produced through the sulphate
2 4 2
process. Alternatively, average emission data of dust to air, HCl to air, and Cl- to water for TiO produced through
2
the chloride process.
— The declarations from TiO supplier(s) (or TiO producer(s), if different) should include the relevant European or
2 2
international standards used to measure the relevant parameters listed in the Table 1.
— The measures in place to ensure a low dust working environment.
The declaration from the TiO supplier(s) (or TiO producer(s), if different) shall include a basic calculation about how the
2 2
annual average emissions were obtained. If the production of the supplied TiO pigment is non-continuous, then emission
2
data calculations covering a shorter period than 12 months may be accepted. In cases of continuous monitoring, the annual
average emission concentrations shall be derived from daily average concentrations. For periodically monitored emissions,
at least 3 samples must be taken to derive the average results. Any periodic sampling must be taken during periods of stable
operation that are representative of normal plant conditions for the production of the TiO pigments used in the EU
2
Ecolabel paint products.
The emission calculations shall only be required to be submitted at the date of application for the EU Ecolabel. If the EU
Ecolabel is awarded, the applicant can simply request updated declarations each year from their TiO supplier(s) of
2
continuing compliance with the emission limits.
For emissions to air, concentrations shall be expressed in units of mg/Nm3and multiplied by a specific emission air flow
rate in units of Nm3/tonne TiO pigment production for the same time period that the data was collected. If there is more
2
than one exhaust gas abatement system for major point sources of emissions to air, emissions from the clean air from each
abatement system shall be counted and added.
For emissions to water, either a direct measurement or a mass balance approach shall be used. The mass balance approach
shall be based on the balance between inputs of raw sulphate/chloride and outputs of sulphate/chloride in by-products, in
emissions to air and in solid waste that is disposed of to landfill or incinerated. The difference in the masses of the inputs
and outputs shall be considered as the mass of sulphate/chloride that is emitted to water during the calculation period and
shall be divided by the estimated quantity of TiO pigment produced during the same period to calculate specific emissions
2
to water in units of kg sulphate or chloride/t TiO pigment.
2
With the direct measurement approach for emissions to water, measured concentrations in units of g/m3shall be multiplied
by a specific treated wastewater effluent flow rate in units of m3/tonne TiO pigment production for the same time period
2
that the sulphate/chloride data was collected.
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Criterion 2. Efficiency in use requirements
In order to demonstrate the efficiency in use of decorative paints, varnishes, and related products, the following tests per
type of product, as indicated in Table 2 and detailed in the criterion text later, shall be undertaken.
Table 2
Performance requirements for different kinds of decorative paints, varnishes, and related products
Decorative paint and varnish categories
(with their subcategories identified according to the Directive 2004/42/EC) ‘Just add water’
decorative paints or
Criteria I an nd do o cer ilw ina gll O mu it nd eo rao lr T cr laim dd a inn gd Var an nis dh es Primers Binding bv uar iln di is nh ge ss , f to hr e iu r s te r io mn ,
paint substrate paints woodstains (g) primers fittings or associated
(a, b) paint (d) (e, f) (h) structures
(c)
Opaque Opaque Paints: Yes
2(a) Spreading rate Yes Yes Yes No
only only Varnishes: No
2(b) Wet scrub Paints: WPC (and
Opaque Opaque
resistance WSR if marketed
WSR and WPC WPC only only
(WSR) and Neither as subcategory a
WPC only only (WPC (WPC
white pigment or b)
only) only)
content (WPC) Varnishes: Neither
Yes, except
Paints: No
minimal
2(c) Resistance to Varnishes: Only if
No No No build No No
water marketed as
wood
subcategory e or f
stains
Opaque Opaque Opaque
under and for and for
2(d) Adhesion No No No No
coats masonry masonry
only only only
Only if marketed
Outdoor Outdoor
2(e) Weathering No Yes No No for outdoor
only only
application
2(f) Water vapour If
No No No No No No
permeability claimed
2(g) Liquid water
No Yes No No No No No
permeability
2(h) Fungal If
If claimed If claimed No No No If claimed
resistance claimed
2(i) Algal If
No If claimed No No No If claimed
resistance claimed
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Decorative paint and varnish categories
(with their subcategories identified according to the Directive 2004/42/EC) ‘Just add water’
decorative paints or
Criteria I an nd do o cer ilw ina gll O mu it nd eo rao lr T cr laim dd a inn gd Var an nis dh es Primers Binding bv uar iln di is nh ge ss , f to hr e iu r s te r io mn ,
paint substrate paints woodstains (g) primers fittings or associated
(a, b) paint (d) (e, f) (h) structures
(c)
2(j) Crack If
No No No No No If claimed
bridging claimed
For For
2(k) Alkali outdoor outdoor Only if marketed
No Yes No No
resistance masonry masonry as subcategory c
systems systems
2(a) Spreading rate
Note 1: This requirement does not apply to varnishes, lasures, transparent adhesion primers or any other transparent or
semi-transparent coatings.
Note 2. For tinting systems, this criterion applies only to the tinting base containing the most TiO in terms of g/l of
2
tinting base. In cases where this tinting base is unable to achieve this requirement, the criterion shall be met after
tinting the base to produce the standard colour RAL 9010.
Note 3. This requirement applies to all white paints. For families of paint products available only in preset shades, the
spreading rate shall apply to the lightest colour.
Spreading rates shall be calculated while ensuring a hiding power of at least 98 % according to relevant European or
international standards or an equivalent method that can be validated against them. The following minimum spreading
rate limits apply:
— Indoor white paints and light-coloured paints, including finishing coats and intermediate coats (subcategories a and
b), shall have a spreading rate of at least 8 m2per litre of product.
— Outdoor white and light-coloured paints, including finishing coats and intermediate coats (subcategory c), shall have
a spreading rate of at least 6 m2per litre of product. Products marketed for both indoor and outdoor application shall
meet the higher spreading rate requirement of at least 8 m2per litre.
— Opaque primers and undercoats (sub-categories g and h) shall have a spreading rate of at least 8 m2 per litre of
product, or of at least 6 m2 per litre of product in the cases of opaque primers with specific blocking, sealing,
penetrating, binding or special adhesion properties.
— Opaque elastomeric paints (subcategory c, but with crack-bridging claims) shall have a spreading rate of at least 4 m2
per litre of product.
For paints that are a part of a tinting system, the applicant must advise the end-user on the product packaging and at the
point of sale (POS) which shade or primer/undercoat (if possible, bearing the EU Ecolabel) should be used as a basecoat
before applying the darker shade.
Assessment and verification:
The applicant shall provide a declaration of compliance with the relevant spreading rate limits or a justification of non-
applicability of the spreading rate requirement for each of the products covered by the EU Ecolabel application. The
declaration shall be supported by test results according to relevant European or international standards or an equivalent
method that can be validated against them. It shall be clearly indicated which spreading rate results correspond to which
families of products covered by the EU Ecolabel license application.
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The highest TiO content tinting base shall be identified by presenting safety data sheets for them or a suitable declaration
2
that covers all tinting bases within a given family of products. For bases used to produce tinted products that have not
been evaluated according to the abovementioned requirements, the applicant shall provide evidence of how the end-user
will be advised to use a relevant primer and/or grey (or other relevant shade) of undercoat before application of the product.
2(b) Wet scrub resistance and white pigment content
Note: This criterion only applies to paint products and white pigment content shall be calculated with the same products
for which spreading rate is measured as per the notes in criterion 2(a). For the purposes of this criterion, the term
‘white pigment’, shall be considered to refer only to pigments with a refractive index higher than 1,8.
Any indoor wall and ceiling paint products that claim wet scrub resistance must meet the requirements for class 1 or class 2
according to the procedure defined in relevant European or international standards and the classification systems and
comply with the respective upper limits for white pigment content defined in the table below. All other relevant products
that do not make wet scrub resistance claims must comply with the corresponding white pigment content limit defined in
the Table 3.
Table 3
Requirements for wet scrub resistance and white pigment content for paint products
Wet scrub resistance claim? (product subcategory) Wet scrub resistance White pigment content
Yes (a), b), or just add water paints marketed as a) Class 1 ≤ 40 g/m2(*)
or b))
Yes (a), b), or just add water paints marketed as a) Class 2 ≤ 36 g/m2(*)
or b))
No (a), b), or just add water paints marketed as a) n/a ≤ 25 g/m2(*)
or b))
n/a (all other relevant subcategories: c), d), g) or n/a ≤ 38 g/m2(*)
h), or just add water paints marketed as c), d), g)
or h))
n/a (varnishes and woodstains: e) or f)) n/a n/a
(*) The m2refers to 1m2of dry film with an opacity of at least 98 % according to relevant European or international standards.
Assessment and verification:
The applicant shall provide a declaration of compliance with the relevant requirement or a justification of the non-
applicability of the requirements for each of the products covered by the EU Ecolabel application. In cases of relevant
products, the applicant shall declare the total content of white pigments with a refractive index > 1,8 in the final product,
relevant tinting base or light base paint formulations that are subject to the EU Ecolabel license application. This
information shall be provided in terms of the chemical name and CAS number of the white pigment, its declared refractive
index, its concentration in g/l of paint product and the density of the paint, in g/l. The spreading rate of the paint product, in
l/m2for a dry film of at least 98 % opacity according to relevant European or international standards, shall also be stated (as
per criterion 2(a)). Multiplying the white pigment concentration (in g/l) by the spreading rate (in l/m2) will produce white
pigment levels in units of g/m2that can be compared to the limits in the table above.
Except in cases where the content of white pigments is < 25,0 g/m2and no claims of wet scrub resistance are made, the
applicant shall also provide results of wet scrub resistance testing according to the relevant European or international
standards that show that the products meet the applicable class 1 or class 2 resistance requirements defined in other
relevant European or international standards.
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2(c) Resistance to water
Note: In varnish or woodstain coating systems with a primer, either the full coating system or just the finishing layer
may be tested.
Cured coatings shall have resistance to water, as determined by relevant European or international standards, such that after
24 hours of exposure and 16 hours of recovery, no change of gloss is observed in transparent or semi-transparent coatings.
No change of gloss in exposed samples shall be considered as a visual rating of 0 when measured for quantity of defects, size
of defects and intensity of changes according to the classification system of relevant European or international standards.
Assessment and verification:
The applicant shall provide a declaration of compliance with the requirement or a justification of the non-applicability of
the requirement for each of the products covered by the EU Ecolabel application.
For any varnish or woodstain products included in their license application, the applicant declaration shall be supported by
copies of test report(s) following relevant European or international standards that cover the licensed product or family of
products, including reported results for change of gloss according to relevant European or international standards.
If the exemption for minimal build woodstains is applied, the applicant shall justify the exemption by providing test reports
according to relevant European or international standards, that show the thickness of the coating layer to be less than 5μm.
2(d) Adhesion
Note: This criterion applies to opaque primers and binding primers for masonry coatings and to undercoats for wood or
metal trim and cladding paints. The adhesion test may be conducted on any opaque primer or undercoat alone, or
on the primer/undercoat and finishing coat together, so long as the combination is opaque. In cases of different
colour shades within a family of products, only the light-coloured or white base paint or tinting base(s) need to be
tested.
Pigmented masonry primers for exterior uses shall score a pass in the pull-off test of relevant European or international
standards where the cohesive strength of the substrate is less than the adhesive strength of the primer coating, otherwise
the adhesion of the primer coating must be in excess of a pass value of 1,5 MPa.
Interior masonry primers, metal and wood undercoats shall score 2 or less in the test for adhesion of relevant European or
international standards.
Assessment and verification:
The applicant shall provide a declaration of compliance with the relevant requirement or a justification of the non-
applicability of the requirements for each of the products covered by the EU Ecolabel application. For any opaque masonry
primer, binding primer, wood undercoat or metal undercoat products included in their license application, the applicant
shall provide copies of test reports following relevant European or international standards, as applicable.
2(e) Weathering
Note: This criterion applies to outdoor paints and varnishes. In the case of different colour shades within a family of
products, only the light-coloured or white base paint or tinting base(s) need to be tested.
All outdoor paints or varnishes shall be exposed to artificial weathering in apparatus including fluorescent UV lamps and
condensation or water spray according to relevant European or international standards. They shall be exposed to test
conditions for 1 000 hours with cycling conditions of: UVA 4 h/60 °C + humidity 4 h/50 °C.
Alternatively, outdoor wood finishes and outdoor wood varnishes may be exposed to weathering for 1 000 hours in the
QUV accelerated weathering apparatus with cyclic exposure with UV(A) radiation and spraying according to relevant
European or international standards.
After weathering, the exposed films shall comply with the requirements specified in the Table 4.
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Table 4
Overview of weathering requirements for decorative paints, varnishes, and related products according to
relevant European or international standards
Property Requirement (after weathering) Scope of products covered/not covered
Not applicable to any varnishes or any
Colour change Colour change, ΔΕ ≤ 4
transparent or semi-transparent tinting bases
Not applicable to mid-sheen or matt
≤ 50 % decrease compared to initial
Decrease of gloss finishing coats with initial gloss value of
value
< 60 % at 60° angle of incidence
Chalking A score of ≤ 2
Flake density: ≤ 2
Flaking
Flake size: ≤ 2
Only applicable to finishing coats of coating
systems used on outdoor masonry, wood
Crack quantity: ≤ 2
Cracking and metal substrates
Crack size: ≤ 3
Blister density: ≤ 3
Blistering
Blister size: ≤ 3
Assessment and verification:
The applicant shall provide a declaration of compliance with the relevant requirement or a justification of the non-
applicability of the requirements for each of the products covered by the EU Ecolabel application. For any outdoor
decorative paints or varnishes included in their license application, the applicant shall provide copies of test reports that
detail the weathering test method used (being in compliance with relevant European or international standards) and
provide results of changes in properties after weathering, as applicable.
2(f) Water vapour permeability
Note: This criterion only applies to outdoor masonry paints that make ‘breathable’ or ‘water vapour permeable’ claims in
their marketing material. In cases of different colour shades within a family of products, only the light-coloured or
white base paint or tinting base(s) need to be tested.
Relevant paint product(s) shall be tested for water vapour permeability according to relevant European or international
standards and generate results that correspond to a medium (class V2) or high (class V1) water vapour permeability as
defined in relevant European or international standards.
Assessment and verification:
The applicant shall provide a declaration of compliance with the relevant requirement or a justification of the non-
applicability of the requirements for each of the products covered by the EU Ecolabel application. For any outdoor
masonry paints included in their license application that make relevant marketing claims, the applicant shall provide
copies of test reports according to relevant European or international standards, with results expressed according to the
classification system defined in relevant European or international standards.
2(g) Liquid water permeability
Note: This criterion only applies to outdoor masonry paints. In cases of different colour shades within a family of
products, only the light-coloured or white base paint or tinting base(s) need to be tested.
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The paint product(s) shall be tested for liquid water permeability according to relevant European or international standards
and meet the following requirements, as appropriate:
— For outdoor masonry paints that make claims about being water repellent or hydrophobic or similar: Low liquid
water permeability (Class W3) according to the classification system of relevant European or international standards.
— For all other outdoor masonry paints: medium liquid water permeability (Class W2) according to the classification
system of relevant European or international standards.
Assessment and verification:
The applicant shall provide a declaration of compliance with the relevant requirement or a justification of the non-
applicability of the requirements for each of the products covered by the EU Ecolabel application. For any outdoor
masonry paints, the applicant shall provide copies of test reports according to relevant European or international
standards, with results expressed according to the classification system defined in relevant European or international
standards.
2(h) Fungal resistance
Note: This criterion only applies to outdoor masonry paints or wood paints that have anti-fungal marketing claims. In
cases of different colour shades within a family of products, only the light-coloured or white base paint or tinting
base(s) need to be tested.
In accordance with Product Type 7 (PT7) efficacy requirements of Regulation (EU) No 528/2012, the following
requirements shall be met, as appropriate:
— For outdoor masonry paints: A score of class 1 or lower (class 0) for fungal resistance according to relevant European
or international standards.
— For wood paints: A score of class 0 for fungal resistance according to relevant European or international standards.
Assessment and verification:
The applicant shall provide a declaration of compliance with the relevant requirement or a justification of the non-
applicability of the requirements for each of the products covered by the EU Ecolabel application. For any outdoor
masonry paints or wood paints that have relevant marketing claims, the applicant shall provide copies of test reports
according to relevant European or international standards.
2(i) Algal resistance
Note: This criterion only applies to outdoor masonry paints or wood paints that have anti-algal marketing claims. In
cases of different colour shades within a family of products, only the light-coloured or white base paint or tinting
base(s) need to be tested.
In accordance with Product Type 7 (PT7) efficacy requirements of Regulation (EU) No 528/2012, the following
requirements shall be met, as appropriate:
— For outdoor masonry paints: A score of class 1 or lower (class 0) for algal resistance according to relevant European
or international standards.
— For wood paints: A score of class 0 for algal resistance according to relevant European or international standards.
Assessment and verification:
The applicant shall provide a declaration of compliance with the relevant requirement or a justification of the non-
applicability of the requirements for each of the products covered by the EU Ecolabel application. For any outdoor
masonry paints or wood paints that have relevant marketing claims, the applicant shall provide copies of test reports
according to relevant European or international standards.
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2(j) Crack bridging
Note: This criterion only applies to outdoor masonry paints that have elastomeric (i.e. crack-bridging) marketing claims.
In cases of different colour shades within a family of products, only the light-coloured or white base paint or
tinting base(s) need to be tested.
The coating shall meet the requirements for crack-bridging performance of class A1 or better at 23 °C (i.e. A2, A3 etc.)
according to relevant European or international standards.
Assessment and verification:
The applicant shall provide a declaration of compliance with the relevant requirement or a justification of the non-
applicability of the requirements for each of the products covered by the EU Ecolabel application. For any outdoor
masonry paints that have relevant marketing claims, the applicant shall provide copies of test reports according to relevant
European or international standards.
2(k) Alkali resistance
Note: This criterion only applies to masonry coatings, including primers. In cases of different colour shades within a
family of products, only the light-coloured or white base paint or tinting base(s) need to be tested.
The coating shall show no noticeable damage when the coating is spotted for 24 hours with 10 % NaOH solution according
to relevant European or international standards. The evaluation shall be done after 24 hours drying-recovery. No noticeable
damage shall be considered as a rating of 1 or better (i.e. 0 or 1) as defined in relevant European or international standards,
following a visual assessment for both the size and quantity of defects for blistering on the surface of the tested coating in
accordance with those same international standards.
Assessment and verification:
The applicant shall provide a declaration of compliance with the relevant requirement or a justification of the non-
applicability of the requirements for each of the products covered by the EU Ecolabel application. For any outdoor
masonry paints or primers, the applicant shall provide copies of test reports according to relevant European or
international standards with results expressed in terms of the rating system in other relevant European or international
standards.
Criterion 3. Content of Volatile and Semi-volatile Organic Compounds (VOCs, SVOCs)
The maximum content of Volatile Organic Compounds (VOCs) and Semi-Volatile Organic Compounds (SVOCs) shall not
exceed the limits given in Table 5.
The content of VOCs and SVOCs shall be determined for the ready to use product and shall include any recommended
additions prior to application such as colourants and/or thinners.
Table 5
VOC and SVOC content limit
VOC and SVOC content limits
Product description (with subcategory denotation according to VOC(3)limits (g/l of ready to SVOC(4)limits (g/l of ready
Directive 2004/42/EC) use product) to use product)
a. Interior matt walls and ceilings (Gloss < 25@60°) 10 25(1)/ 30(2)
b. Interior glossy walls and ceilings (Gloss > 25@60°) 30 25(1)/ 30(2)
c. Exterior walls of mineral substrate 20 35
d. Interior/Exterior trim and cladding paints for wood and
60 40(1)/ 50(2)
metal
e. Interior trim varnishes and woodstains, including opaque
60 30
woodstains
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VOC and SVOC content limits
Product description (with subcategory denotation according to VOC(3)limits (g/l of ready to SVOC(4)limits (g/l of ready
Directive 2004/42/EC) use product) to use product)
e. Exterior trim varnishes and woodstains, including opaque
60 50
woodstains
f. Interior and Exterior minimal build woodstains 40 30(1)/ 40(2)
g. Primers 10 25(1)/ 30(2)
h. Binding primers 10 25(1)/ 30(2)
(1) SVOC limit applies to indoor white paints and varnishes
(2) SVOC limit applies to indoor tinted paints/outdoor paints and varnishes
(3) ‘Volatile organic compounds (VOCs)’ means any organic compounds having an initial boiling point less than or equal to 250 °C
measured at a standard pressure of 101,3 kPa
(4) ‘Semi volatile organic compounds (SVOCs)’ means any organic compound having a boiling point greater than 250 °C and less than
370 °C measured at a standard pressure of 101,3 kPa
The VOC content shall be determined either by calculation based on the ingredients and raw materials or by using the
methods given in relevant European or international standard or, alternatively for products with a VOC content of less
than 1,0 g/l, the methods given in other relevant European or international standard. The SVOC content shall be
determined using the method given in relevant European or international standard. In the case of products used both
indoors and outdoors the strictest SVOC limit value for indoor paints and varnishes shall prevail.
Assessment and verification:
The applicant shall provide a declaration of compliance supported by calculations of VOC and SVOC contents based on the
ingredients and raw materials used in the ready to use product. Alternatively, the VOC and SVOC contents of the ready to
use product shall be communicated via a representative test report or reports using the methods given in the relevant
international standard, as appropriate, and results shall demonstrate compliance with the relevant limits.
Criterion 4. Restriction of hazardous substances and mixtures
Note: These sub-criteria apply to the final product formulation and any supplied ingredients therein.
4.1. Restrictions on Substances of Very High Concern (SVHCs)
The final product formulation and any supplied ingredients therein shall not contain any ingoing substances that meet the
criteria referred to in Article 57 of Regulation (EC) No 1907/2006 that have been identified according to the procedure
described in Article 59 of that Regulation and included in the candidate list for substances of very high concern for
authorisation.
Assessment and verification:
The applicant shall provide a signed declaration that the final product formulation and any supplied ingredients therein do
not contain any SVHCs as ingoing substances. The applicant declaration shall be supported by safety data sheets of all
supplied ingredients used to produce the final product and declarations from the chemical suppliers.
The list of substances identified as SVHCs and included in the candidate list in accordance with Article 59 of Regulation
(EC) No 1907/2006 can be found here:
https://www.echa.europa.eu/candidate-list-table
Reference to the list shall be made on the submission date of the EU Ecolabel application.
For any level of known impurities identified as SVHCs in ingredients, the concentration of the impurity and an assumed
retention factor of 100 % shall be used to estimate the quantity of the SVHC impurity remaining in the final product
formulation. Impurities that are SVHCs cannot be present in the paint or varnish product formulation above 0,0100 % w/
w or in any individual ingredient in concentrations exceeding 0,100 % w/w. Any deviation from a retention factor of 100 %
for an SVHC impurity (for example due to solvent evaporation) or in case of chemical modification, must be supported by
adequate justifications.
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4.2. General restrictions based on classifications according to specific hazard classifications defined in
Regulation (EC) No 1272/2008.
(a) Final product formulation
The final product formulation shall not be classified as being carcinogenic, mutagenic, toxic for reproduction, acutely toxic,
an aspiration hazard, a specific target organ toxicant, a respiratory or skin sensitiser, hazardous to the aquatic environment,
hazardous to the ozone layer, an endocrine disruptor, persistent, bioaccumulative and toxic (PBT) or persistent, mobile and
toxic (PMT) in accordance with Regulation (EC) No 1272/2008 and specifically in terms of the hazard statement codes
stated in Table 6. The only exception permitted to this rule shall be the H412 and H413 classification, and only if due to
levels of dry-film preservatives in the case of outdoor paints or varnishes.
(b) Ingoing substances
Unless derogated in Table 7, the final product formulation shall not contain any ingoing substances in concentrations at or
above 0,010 % weight by weight of the final product formulation that are classified, in accordance with Regulation (EC)
No 1272/2008, with any of the hazard classes, categories and associated hazard statement codes stated in Table 6.
Table 6
Restricted hazard classes, categories, codes and associated hazard statements
Carcinogenic, mutagenic or toxic for reproduction (CMR)
Categories 1A and 1B Category 2
H340: May cause genetic defects H341: Suspected of causing genetic defects
H350: May cause cancer H351: Suspected of causing cancer
H350i: May cause cancer by inhalation
H360: May damage fertility or the unborn child H361: Suspected of damaging fertility or the unborn child
H360F: May damage fertility H361f: Suspected of damaging fertility
H360D: May damage the unborn child H361d: Suspected of damaging the unborn child
H360FD: May damage fertility. May damage the unborn H361fd: Suspected of damaging fertility. Suspected of
child damaging the unborn child
H360Fd: May damage fertility. Suspected of damaging the H362: May cause harm to breast fed children
unborn child.
H360Df: May damage the unborn child. Suspected of
damaging fertility.
Acute toxicity
Categories 1 and 2 Category 3
H300: Fatal if swallowed H301: Toxic if swallowed
H310: Fatal in contact with skin H311: Toxic in contact with skin
H330: Fatal if inhaled H331: Toxic if inhaled
EUH070: Toxic by eye contact
Aspiration hazard
Category 1
H304: May be fatal if swallowed and enters airways
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Carcinogenic, mutagenic or toxic for reproduction (CMR)
Categories 1A and 1B Category 2
Specific target organ toxicity
Category 1 Category 2
H370: Causes damage to organs H371: May cause damage to organs
H372: Causes damage to organs through prolonged or H373: May cause damage to organs through prolonged or
repeated exposure repeated exposure
Respiratory and skin sensitization
Category 1, 1A and 1B
H317: May cause an allergic skin reaction
H334: May cause allergy or asthma symptoms or breathing
difficulties if inhaled
Hazardous to the aquatic environment
Categories 1 and 2 Categories 3 and 4
H400: Very toxic to aquatic life H412: Harmful to aquatic life with long-lasting effects
H410: Very toxic to aquatic life with long-lasting effects H413: May cause long-lasting effects to aquatic life
H411: Toxic to aquatic life with long-lasting effects
Hazardous to the ozone layer
H420: Harms public health and the environment by
destroying ozone in the upper atmosphere
Endocrine disruptors (EDs) for human health and the environment
Category 1 Category 2
EUH380: May cause endocrine disruption in humans EUH381: Suspected of causing endocrine disruption in
humans
EUH430: May cause endocrine disruption in the EUH431: Suspected of causing endocrine disruption in the
environment environment.
Persistent, Bioaccumulative and Toxic (PBT)
PBT very Persistent and very Bioaccumulative (vPvB)
EUH440: Accumulates in the environment and living EUH441: Strongly accumulates in the environment and
organisms including in humans living organisms including in humans
Persistent, Mobile and Toxic (PMT)
PMT very Persistent and very Mobile (vPvM)
EUH450: Can cause long-lasting and diffuse contamination EUH451: Can cause very long-lasting and diffuse
of water resources contamination of water resources
The use of substances that are chemically modified during the production process, so that any relevant hazard for which the
substance has been classified under Regulation (EC) No 1272/2008 no longer applies, shall be exempted from the above
requirement.
This criterion shall not apply to ingoing substances covered by points (a) and (b) of Article 2(7) of Regulation (EC)
No 1907/2006, which set out criteria for exempting substances within Annexes IV and V to that Regulation from the
registration, downstream user and evaluation requirements.
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Table 7
Derogations to restrictions on ingoing substances that are classified with one or more of the restricted hazards
listed in Table 6 and are present in concentrations at or above 0,010 % (weight by weight) of the final product
formulation.
Substance type, substance Derogated hazard
Derogation conditions
name and CAS number code(s)
Preservatives and preservative stabilisers
Note on preservatives: all preservatives added to ingredients must be declared by suppliers and all preservatives added
directly to the final product formulation must be declared by the paint or varnish producer. The only types of
preservatives permitted in ingredients and the final product shall be those that are compliant with Regulation (EU)
No 528/2012. For final products originating in the Union, it is reminded that it is not sufficient that the active substances
contained in the preservative product are approved under Regulation (EU) No 528/2012 for product type 6 (PT6) (in-can
preservative) or for product type 7 (PT7) (dry-film preservative), but the preservative product must be authorised under
Regulation (EU) No 528/2012 for PT6 or PT7 or made available on the market according to the transitional measures set
out in Article 89(2) of that Regulation. The combined total limits for PT6 and PT7 preservatives shall apply to these
following product categories:
— For indoor products: up to 0,080 % weight by weight of PT6 in the final product.
— For colour tints used in tinting systems: up to 0,20 % weight by weight of PT6 in the colour tint.
— For indoor products marketed for use in high humidity areas: up to 0,080 % weight by weight of PT6 and up to 0,10 %
weight by weight of PT7 in the final product.
— For outdoor products: up to 0,080 % weight by weight of PT6 and up to 0,50 % weight by weight of PT7 in the final
product.
Except for colour tints, all references to concentrations/limits/levels of preservatives in the section ‘Preservatives and
preservative stabilisers’, shall be understood as referring to the preservative active substances contained in the final product
formulation.
Any preservatives which cannot be present in the final product formulation at concentrations exceeding 0,010 %, due to
specific concentration limits (SCLs) lower than 0,010 % that would classify the final product with a restricted CLP hazard,
are not mentioned in the derogation table below because they cannot be used in concentrations exceeding 0,010 % in the
first place and thus do not need a derogation. This does not imply that they cannot be used as ingoing substances in EU
Ecolabel products at any level. If not explicitly excluded in sub-criterion 4.3, such preservatives may be used so long as it is
at levels below any SCLs that would trigger a restricted CLP classification of the final product formulation.
In-can preservatives (PT6) H301, H311, (*)See horizontal derogation condition at foot of table
in colour tints or final H317, H330, The sum total of all PT6 in-can preservatives (those derogated for use
product: H331, H372, above 0,010 % plus those that are non-derogated but used in levels
H373, H400, < 0,010 %) must be within the relevant limits defined in the note
H410, H411, above.
H412, H413 When preservatives that are formaldehyde donors are used, the
relevant limits for free formaldehyde in the final product formulation
set out in sub-criterion 4.3(l) must be respected.
Specific concentration limits (% weight by weight in the final product
formulation) shall apply for the derogated substances listed below:
— Bronopol(CAS No 52-51-7): up to 0,030 %.
— DBNPA(CAS No 10222-01-2): up to 0,030 %.
— Sodium pyrithione(CAS No 3811-73-2): up to 0,030 %.
— BIT(CAS No 2634-33-5): up to 0,036 %.
— Combined total isothiazolinones and isothiazolinone releasers
(those derogated for use above 0,010 % plus those that are non-
derogated but used in levels < 0,010 %): up to 0,040 % in final
product formulations
— Diamine(CAS No 2372-82-9): up to 0,050 %.
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Substance type, substance Derogated hazard
Derogation conditions
name and CAS number code(s)
Dry-film preservatives H311, H317, (*)See horizontal derogation condition at foot of table
(PT7): H330, H331, Only applies to outdoor products and indoor products for use in high
H372, H373 humidity areas.
H400, H410, The sum total of all PT7 dry-film preservatives (those derogated for
H411, H412 and use above 0,010 % plus those that are non-derogated but used in
H413 levels < 0,010 %) must be within the relevant limits defined in the
note above.
In the case of slow release, encapsulated forms of dry-film
preservatives, the specific classification of the final product, or read-
across formulations, should consider the absolute concentration of
the hazardous components (i.e. without capsules). The final product
or read-across formulation cannot be classified with any of the
hazards listed in Table 6.
Any dry-film preservatives classified as H400 or H410 must be non-
bioaccumulative, demonstrated by having an octanol-water coefficient
(Log Kow) of ≤ 3,2 or a bioconcentration factor (BCF) of ≤ 100.
Preservative stabiliser: H400, H410 (*)See horizontal derogation condition at foot of table
Zinc oxide (CAS Permitted to be used as a preservative stabiliser, up to 0,040 % weight
No 1314-13-2) by weight in the final product formulation, when used to stabilise
in-can or dry-film preservative combinations that require
1,2-Benzisothiazol-3(2H)-one (BIT).
Drying and anti-skinning agents
Anti-skinning agents H317, H412, (*)See horizontal derogation condition at foot of table
H413 The sum total anti-skinning agent content shall not exceed 0,40 %
weight by weight in the final product formulation.
Driers (siccatives) H301, H317, (*)See horizontal derogation condition at foot of table
H373, H400†, The sum total drier content shall not exceed 0,10 % weight by weight
H410†, H412, in the final product formulation.
H413 † The derogation for H400 and H410 only applies to cobalt-based
drier compounds and such compounds can only be used up to
0,050 % weight by weight in the final product formulation.
Pigments and pigments additives
Trimethylolpropane (CAS H361fd (*)See horizontal derogation condition at foot of table
No 77-99-6) Only when used as an additive in supplied pigments and only up to
0,50 % weight by weight in the supplied pigment.
Binders and polymer dispersions
Binders and crosslinking H317, H411 (*)See horizontal derogation condition at foot of table
agents: Only allowed up to 1,0 % weight by weight in the binder or polymer
Adipic acid dihydrazide dispersion ingredient and when used as an adhesion promoter or as a
(CAS No 1071-93-8) crosslinking agent.
Unreacted monomers (in H301, H304, (*)See horizontal derogation condition at foot of table
binders) H311, H317, The sum total concentration of unreacted monomers needing this
H331, H334, derogation shall not exceed 0,050 % weight by weight in the final
H372, H400, product formulation.
H410, H411,
H412
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Substance type, substance Derogated hazard
Derogation conditions
name and CAS number code(s)
Other, miscellaneous
Methanol (CAS H301, H311, (*)See horizontal derogation condition at foot of table
No 67-56-1) H331, H370 Only permitted as a residual reaction product of other substances in
the product formulation. Allowable residual concentration increases
as a function of binder content in the following manner:
— Binder content of 10-20 %: allowable residual methanol is 0,020 %
weight by weight in the final product formulation.
— Binder content of 20-40 %: allowable residual methanol is 0,030 %
weight by weight in the final product formulation.
— Binder content of > 40 %: allowable residual methanol is 0,050 %
weight by weight in the final product formulation.
Mineral raw materials, H372, H373 (*)See horizontal derogation condition at foot of table
including fillers, anti- Only applies to mineral raw materials and leucophyllite minerals that
sagging agents and matting naturally contain crystalline silica.
agents Only permitted in contents up to 1,0 % weight by weight in the final
product formulation for H372 materials or up to 10 % for H373
materials.
In cases where the material is supplied in dry powder form, the
applicant shall demonstrate that they have systems in place to
minimise worker exposure to dry powder in the workplace (for
example closed dosing systems, ventilated dosing and mixing areas
and personal protective equipment).
Neutralising agents H301, H311, (*)See horizontal derogation condition at foot of table
H331, H400, Only allowed up to 1,0 % weight by weight in varnish formulations,
H410, H411, and up to 0,50 % in all other products.
H412, H413
Optical brighteners H413 (*)See horizontal derogation condition at foot of table
Only allowed up to 0,10 % weight by weight in the final product
formulation.
Silicone resin H412, H413 (*)See horizontal derogation condition at foot of table
Only allowed up to 2,0 % weight by weight in the final product
formulation.
Solvents H304 (*)See horizontal derogation condition at foot of table
Only allowed up to 2,0 % weight by weight in the final product
formulation.
Surfactants H411, H412, (*)See horizontal derogation condition at foot of table
H413 Only allowed up to 1,0 % weight by weight in transparent, semi-
transparent, white or light-coloured product formulations or up to
3,0 % weight by weight in all other colours.
UV stabilisers H317, H411, (*)See horizontal derogation condition at foot of table
H412, H413 Only applicable to outdoor products and only up to 0,60 % weight by
weight in the final product formulation.
(*) Horizontal derogation condition: none of the derogations above, either individually or in combination, shall be permitted if they
result in the final product formulation being classified with any of the hazards defined in Table 6, with the notable exception of
H412 and H413 for outdoor products due to the presence of dry-film preservatives.
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Assessment and verification:
The applicant shall provide a signed declaration of compliance with sub-criterion 4.2, including compliance with any
relevant derogation conditions, supported by declarations from suppliers and any other relevant documentation.
A list of all ingoing substances with one or more of the restricted CLP hazards calculated to be present in the final product
formulation in concentrations greater than 0,010 % weight by weight shall be presented, together with their CAS numbers,
CLP classification status (i.e. harmonised, joint entry or self-entries only) the relevant function of the ingoing substance (for
example in-can preservative, drier, pigment, neutralising agents, surfactants, UV stabiliser etc.)., Calculations for ingoing
substance concentrations in the final product formulation shall be based on:
— a list of all ingredients, chemicals or raw materials used to make the final product formulation;
— the screening of ingredients, chemicals or raw materials for those ingoing substances and known impurities with any
of the EU Ecolabel-restricted CLP hazards;
— the concentrations of any screened ingoing substances and known impurities with EU Ecolabel-restricted CLP hazards
in the ingredients, chemicals or raw materials used in the format supplied;
— the weight of each of the ingredients, chemicals or raw materials added to make a known weight of final product
formulation.
Known impurities shall be treated as ingoing substances only if the screening exercise reveals that their content in the final
product formulation shall exceed 0,010 % weight by weight or their content in an ingredient shall exceed 0,100 % weight
by weight. Known impurities below these thresholds shall not be counted in calculations.
Any screened ingoing substances shall be assumed by default to be 100 % retained in the final product. Justifications for any
deviation from a retention factor of 100 % during processing (for example solvent evaporation) or for chemical
modification of a screened ingoing substance shall be provided. Substances known to be released or to degrade from
ingoing substances are considered ingoing substances and not impurities.
For any screened ingoing substances remaining in the final product formulation in concentrations greater than 0,010 %
weight by weight, but which are exempted from sub-criterion 4.2 (see Annexes IV and V to Regulation (EC)
No 1907/2006), a declaration to this effect by the applicant shall suffice for those substances.
Since multiple products or potential products (for example customised shades from a tinting system) using the same
ingredients, chemicals or raw materials may be covered by one EU Ecolabel license, a worst-case calculation may be
acceptable for each screened ingoing substance within a common family of products covered by the same license.
Regarding information requested from suppliers that may be commercially sensitive, evidence from suppliers can also be
provided directly to competent bodies without necessarily providing certain details to the applicant.
4.3. Specific hazardous substance restrictions for ingoing substances.
Unless derogated in sub-criterion 4.2, the substances indicated below shall not be included as ingoing substances in the final
product formulation or as ingoing substances to the ingredients used to make the final product formulation:
(a) Preservatives or driers classified as carcinogenic, mutagenic or toxic for reproduction.
(b) Substances classified as category 1 or category 2 endocrine disruption for human health or the environment in
accordance with CLP Regulation (EC) 1272/2008, substances included in the candidate list referred to in
Article 59(1) of REACH Regulation (EC) 1907/2006 as having endocrine-disrupting properties for human health or
the environment, substances identified as having endocrine-disrupting properties in accordance with Regulation
(EU) No 528/2012 or Regulation (EC) No 1107/2009, except for DBNPA (CAS No 10222-01-2) when used as an
in-can preservative.
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(c) Substances classified as Persistent, Bioaccumulative and Toxic (PBT) or very Persistent and very Bioaccumulative
(vPvB) for the environment and living organisms including in humans in accordance with CLP Regulation
(EC) 1272/2008, substances included in the candidate list referred to in Article 59(1) of REACH Regulation
(EC) 1907/2006 as having PBT or vPvB properties for the environment and living organisms including in humans,
substances identified as having PBT or vPvB properties for the environment and living organisms including in
humans in accordance with Regulation (EU) No 528/2012 or Regulation (EC) No 1107/2009.
(d) Substances classified as Persistent, Mobile and Toxic (PMT) or very Persistent and very Mobile (vPvM) in accordance
with CLP Regulation (EC) 1272/2008, substances included in the candidate list referred to in Article 59(1) of REACH
Regulation (EC) 1907/2006 as having PMT or vPvM properties.
(e) Alkylphenols, alkylphenol ethoxylates (APEOs) and their derivatives, as referred to in entry 43 to Annex XIV or entry
46 to Annex XVII of the Regulation (EC) 1907/2006.
(f) Perfluorinated and polyfluorinated compounds (PFAS), as defined in Article 4(42).
(g) Phthalates.
(h) Organotin compounds.
(i) Fragrance substances which are prohibited or restricted in cosmetic products and listed in Annexes II or III to
Regulation (EC) No 1223/2009.
(j) Bisphenols that have been identified by ECHA in their 2021 ‘Assessment of Regulatory Needs report on Bisphenols’
for further EU regulatory risk management that are known or potential endocrine disruptors for the environment or
for human health, or that can be identified as toxic for reproduction.
(k) Pigments used shall not be based on Cadmium, Lead, Chromium (VI), Mercury, Arsenic, Selenium, Antimony or
Cobalt. The following impurities from any pigments used shall not be present in the final product formulation in
quantities exceeding 0,010 % weight by weight (per metal): Cadmium, Lead, Chromium (VI), Mercury, Arsenic,
Selenium, Antimony and Cobalt. The only exceptions to pigment use and to the 0,010 % limit for impurities shall be:
— Cobalt: due to the use of Cobalt aluminate blue spinel (CAS No 1345-16-0) and Cobalt chromite blue-green
spinel pigments (CAS No 68187-11-1).
— Antimony: due to the use of pigments based on Antimony Nickel within an insoluble TiO lattice.
2
(l) Free formaldehyde shall not be intentionally added to the final product formulation. The final product shall be tested
in order to determine its free formaldehyde content. Worst-case samples for testing shall be selected for each family of
products based on which product is predicted to have the highest theoretical amount of formaldehyde content. Under
the conditions defined below, the following sum total limits of free formaldehyde shall be permitted:
— Up to 0,0010 % weight by weight permitted when bronopol or preservatives that are formaldehyde donors are
required as an in-can preservative to protect a specific type of paint or varnish
— Up to 0,010 % weight by weight permitted when polymer dispersions (binders) provide, through residual levels
of formaldehyde, the function of formaldehyde donors instead of in-can preservatives.
— Up to 0,010 % when both conditions listed above apply in the same product.
(m) Synthetic polymer microparticles (SPMs, commonly known as microplastics) as defined in entry 78 of Annex XVII to
Regulation (EC) No 1907/2006 (REACH), shall not be used for non-film forming purposes in any product
formulation unless their use and purpose is explicitly declared, together with a justification of why their use
improves the overall environmental performance of the paint or varnish product.
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Assessment and verification:
(a to j) The applicant shall declare the non-use of the relevant substances indicated in this sub-criterion, namely CMR
preservatives, CMR driers, endocrine disruptors (except DBNPA), PBT and vPVB substances, PMT and vPvM
substances, alkylphenols and APEOs, PFAS, phthalates, organotin compounds, fragrances and bisphenols as
ingoing substances in their formulation, supported by declarations from their suppliers about the non-use of
the same hazardous substance groups as ingoing substances in the ingredients supplied and that are used in
formulations covered by the EU Ecolabel license application procedure.
(k) In the case of the heavy metal restrictions from pigments, the applicant or pigment supplier shall provide a
declaration stating that neither the pigment itself nor any ingoing substances that may be incorporated into
the pigment product are based on the listed heavy metals. The applicant or pigment supplier shall also provide
a test report with the heavy metal impurity levels of representative samples of the pigment supplied. The
applicant shall then use these results, together with the % of pigment(s) used in the final product, to calculate
the concentration of heavy metals from pigments remaining in the final product. In the case of exempted
pigments, the pigment supplier shall declare which pigment(s) have the exemption (i.e. cobalt aluminate blue
spinel, cobalt chromite blue-green spinel or antimony nickel in an insoluble TiO lattice).
2
(l) The applicant shall declare which of their products should have the highest theoretical free formaldehyde
content within each family of products’ formulation. This declaration shall be based on the choice of the paint
formulator to use formaldehyde donors as in-can preservatives and declarations from suppliers regarding the
amounts of formaldehyde donors used to preserve supplied ingredients (especially binders). The addition of
these substances (and any other ingredients that release formaldehyde) to the worst-case formulations shall not
result in the content of free formaldehyde in the final product exceeding the relevant concentration limit, as
measured with relevant European or international standards.
(m) The applicant shall provide either a declaration of the non-use of SPMs for non-film forming purposes or a
declaration of their use in the product formulation. In cases where the use of SPMs for non-film forming
purposes is declared, the type, quantity (% weight by weight) and purpose shall be stated in the declaration,
together with a justification of how the use of SPMs for non-film forming purposes improves the overall
environmental performance of the product. Such justifications should normally compare the environmental
performance of the same product with and without the SPMs for non-film forming purposes.
Criterion 5. Volatile Organic Compounds (VOCs) emissions
Note: Only applicable to indoor decorative paints, varnishes, and related products
Emissions of VOCs shall not exceed the limits defined in the Table 8 below.
Table 8
VOC emission limits
Parameter 3-day test results 28-day test results
TVOC(*) ≤ 3 000 μg/m3 ≤ 300 μg/m3
R value(**) n/a ≤ 1,0
Formaldehyde n/a ≤ 10 μg/m3
Any other category 1A or 1B carcinogenic VOCs not covered by EU LCI ≤ 10 μg/m3per ≤ 1 μg/m3per
values(***) substance substance
(*) TVOC shall be measured as defined in relevant European or international standards and including quantification of any non-target
compounds
(**) R value, as defined in relevant European or international standards. Results for the cumulative R value shall be rounded to one
decimal place before determining compliance or non-compliance with the limit of 1,0.
(***)Does not apply to formaldehyde, which is a VVOC and is covered by a specific individual limit. Does not apply to any other
carcinogenic VVOCs or VOCs that have an EU-LCI value, since these are already covered by the R-value limit.
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Assessment and verification:
The applicant shall submit a copy of test report according to relevant European or international standards for the worst-
case product formulation within each of the relevant families of products being covered by the EU Ecolabel license
application. Any changes to the formulations that would create a higher worst-case VOC content shall trigger the
requirement to submit an updated VOC emission test report. When relevant, a clear explanation of the distinctions made
between families of products (for example binder chemistry, product category etc.) shall be provided, together with a
justification of the worst-case product within each family of products.
In cases where a coating system has multiple layers, the full system should be applied to the test substrate according to
manufacturer instructions prior to emission testing.
For the calculation of the R value, reference should be made to the latest set of agreed EU LCI (Lowest Concentration of
Interest) values available at the time of testing. These values can be consulted on the European Commission website (1).
If chamber air concentrations can be shown to comply with the 28-day limits before the 28-day period has been completed
but after a period of at least 3 days, then those results can be accepted as proof of compliance and the test can be halted at
that point.
(1) See: https://single-market-economy.ec.europa.eu/sectors/construction/eu-lci-subgroup/eu-lci-values_en
Criterion 6. Consumer information
6(a) The following information shall appear on or be attached to the packaging:
— Recommendation to minimise paint or varnish wastage by estimating how much paint or varnish is needed
before purchase,
— How to recover unused paint or varnish for reuse,
— How reuse of paint or varnish can effectively minimise the products’ life cycle environmental impact,
— Information requested in sub-criterion 6(b) or explanation of how to access such information.
6(b) The following information shall appear on or be attached to the packaging or be available via a web-link or QR
code:
— How to estimate the amount of paint or varnish needed prior to purchase in order to minimise paint or
varnish wastage and a recommended amount as a guideline (for example for 1 m2of wall, X litres of paint or
varnish is needed),
— Appropriate storage conditions of the product (before and after opening), including, where appropriate, safety
advice,
— Safety measures for the user including basic recommendation on personal protective equipment that should
be worn and additional measures that should be taken when using the product and if applicable when using
spray equipment,
— The use of cleaning equipment and appropriate waste management of the ‘leftover paint or varnish’ and
packaging (in order to limit water and soil pollution). For example, text advising that the unused product
requires specialist handling for safe environmental disposal and therefore it should not be thrown away with
household or commercial waste.
Assessment and verification:
The applicant shall declare that the product complies with the requirement and provide the competent body with
the artwork or samples of the user information and/or a link or QR code to a manufacturer’s website containing
this information as part of the application. The recommended amount of paint given as a guideline shall be
provided.
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Criterion 7. Information appearing on the EU Ecolabel
The optional label with text box shall contain three of the following statements, according to their relevance:
— Minimised content of hazardous substances,
— Reduced content of volatile organic compounds (VOCs): x g/l,
— Reduced emissions of volatile organic compounds to indoor air (for indoor products),
— Good performance for indoor use (for indoor products), or
— Good performance for outdoor use, (for outdoor products) or
— Good performance for both indoor and outdoor use (for products suitable for indoor and outdoor use).
The guidelines for the use of the optional label with text box can be found in the ‘Guidelines for use of the Ecolabel logo’ on
the website:
http://ec.europa.eu/environment/ecolabel/documents/logo_guidelines.pdf
Assessment and verification:
The applicant shall provide a sample of the product label or an artwork of the packaging where the EU Ecolabel is placed,
together with a declaration of compliance with this criterion.
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ANNEX II
EU Ecolabel criteria for awarding the EU Ecolabel to performance coatings and related products
The EU Ecolabel criteria target the best performance coatings and related products on the market, in terms of
environmental performance. The criteria focus on the main environmental impacts associated with the life cycle of these
products and promote circular economy aspects.
Assessment and verification requirements
For the EU Ecolabel to be awarded to a specific product, the product shall comply with each requirement. The applicant
shall provide a written confirmation stating that all the criteria are fulfilled.
Specific assessment and verification requirements are indicated within each criterion.
Where the applicant is required to provide declarations, documentation, analyses, test reports, or other evidence to show
compliance with the criteria, these may originate from the applicant and/or their supplier(s) as appropriate.
Competent bodies shall preferentially recognise attestations that are issued by bodies accredited in accordance with the
relevant harmonised standard for testing and calibration laboratories, and verifications by bodies that are accredited in
accordance with the relevant harmonised standard for bodies certifying products, processes, and services.
Where appropriate, test methods other than those indicated for each criterion may be used if the competent body assessing
the application accepts their equivalence.
Where appropriate, competent bodies may require supporting documentation and may carry out independent verifications
or site inspections to check compliance with these criteria.
Changes in suppliers and production sites pertaining to products to which the EU Ecolabel has been awarded shall be
notified to competent bodies, together with supporting information to enable verification of continued compliance with
the criteria.
As pre-requisite, the product shall meet all respective legal requirements of the country or countries in which the product is
intended to be placed on the market. The applicant shall declare the product’s compliance with this requirement.
The following information shall be provided together with the application for the EU Ecolabel:
(a) A list of all individual paint and varnish products covered by the EU Ecolabel application, grouped into product
families and indicating any relevant product characteristics that affect which specific requirements from the EU
Ecolabel criteria would apply. A family of products will all have the same base formulation and product subcategory,
but may differ in terms of shade and/or packaging format.
(b) A description of the product formulation(s), with a % composition of the ingredients used and the specific function of
each ingredient (the composition information may be subject to a non-disclosure agreement between the applicant
and the competent body or, in some cases, directly between the supplier and the competent body). Ingredient
functions shall be either: accelerator; additive; anti-blocking agent; anti-foaming agent; anti-settling agent; anti-
skinning agent; binder; coalescing agent; colourant-dyestuff; colourant-pigment; crosslinking agent; curing agent/
hardener; diluent; dispersing agent; drier; filler; dry-film preservative; in-can preservative; matting agent; neutralising
agent; optical brightener; plasticiser; polymer dispersion; preservative stabiliser; resin; retarder; rheological modifier;
silicone resin; solvent; surfactant; UV stabiliser; water; water-repelling agent or, in case none of these apply, ‘other’.
(c) Safety data sheets for the ingredients used in the paint and varnish formulations.
(d) Any other information associated with the production of ingredients and materials that is necessary for
demonstrating compliance with the EU Ecolabel criteria shall be provided by the suppliers or producers of those
ingredients and materials.
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(e) In order to help determine the number of products within any given family of products, a description of the
packaging format(s) used, the volume(s) of product held and the packaging material(s) used for each of the paint and
varnish products covered by the EU Ecolabel application.
(f) In order to reduce the quantity of testing and documentation required for assessment and verification procedures,
several criteria explicitly state that compliance of an entire family of products can be assumed if the worst-case
product can be shown to comply. Each time data for a worst-case product is submitted, it shall be accompanied by
an explanation of why this particular product represents the worst-case within its family of products for the
property being tested.
Criterion 1. Titanium dioxide production
If the final product contains more than 3,0 % w/w of titanium dioxide (TiO ) pigment, the emissions to air and water from
2
the production of any titanium dioxide pigment used shall meet the relevant requirements listed below for the respective
production processes:
Table 1
Requirements for Titanium Dioxide production
Parameter and analytical method Sulphate process Chloride process
Emissions of dust to air(1)(measured with the relevant ≤ 0,40 kg/t TiO pigment ≤ 0,66 kg/t TiO pigment
2 2
European or international standards)
Emissions of SO to air(1)(measured with the relevant ≤ 4,5 kg/t TiO pigment n/a
2 2
European or international standards)
Emissions of HCl to air(1)(measured with the relevant n/a ≤ 0,70 kg/t TiO pigment
2
European or international standards)
Emissions of SO 2-to water (measured with the relevant ≤ 300 kg SO 2-/t TiO n/a
4 4 2
European or international standards) pigment
Emissions of Cl-to water (measured using the mass n/a ≤ 103 kg Cl-/t TiO pigment(2)
2
balance method or with the relevant European or ≤ 179 kg Cl-/t TiO pigment(3)
2
international standards) ≤ 329 kg Cl-/t TiO pigment(4)
2
Low dust working environment To be demonstrated To be demonstrated
(1) Point sources for emissions of dust to air from the chloride process are considered as: milling, chlorination, oxidation and
micronisation stages. Point sources for emissions of HCl to air from the chloride process are considered as: chlorination, acid
scrubber from solid separation and metal chloride treatment processes. Point sources for emissions of dust to air from the sulphate
process are considered as: milling, digestion, calcination and micronisation stages. Point sources for emissions of SO to air from the
2
sulphate process are considered as: digestion and calcination processes.
(2) When ore used is > 95 % TiO content.
2
(3) When ore used is 90-95 % TiO content.
2
(4) When ore used is < 90 % TiO content.
2
Emissions to air shall be counted from the relevant point source(s) stated in point (1) above where emissions can be
continuously or periodically monitored from a fixed sampling point after any exhaust gas abatement system(s).
Emissions to water shall be considered as sulphate or chloride present in any treated wastewater effluent that is discharged
into any rivers, lakes, transitional waters, coastal waters or seawaters.
The relevant limit for chloride emissions to water shall be based on the weighted average % TiO content of ore(s) used
2
during the calculation period.
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A low dust working environment shall, as a minimum, include the follows aspects:
— A risk assessment for the workplace that identifies all the main areas of potential dust emission and worker exposure
to dust.
— The need to have in place an occupational hygiene workplace monitoring program.
— Provision of appropriate training to employees about good practice for dust control.
— Provision of adequate personal protective equipment to employees and visitors.
Assessment and verification
The applicant shall declare the content of TiO used in each of the product formulations subject to the EU Ecolabel license
2
application. For any products with more than 3,0 % w/w TiO pigment content, the applicant shall also declare the supplier
2
or suppliers of the TiO used in those products.
2
The applicant declaration shall be supported by declarations from their TiO supplier(s) (or TiO producer(s), if different)
2 2
stating:
— The type of TiO production process used (chloride or sulphate).
2
— The applicable TiO content range of the weighted average ore in case of the chloride process.
2
— Annual average emissions data of dust to air, SO to air, and SO 2-to water for TiO produced through the sulphate
2 4 2
process. Alternatively, average emission data of dust to air, HCl to air, and Cl- to water for TiO produced through
2
the chloride process.
— The declarations from TiO supplier(s) (or TiO producer(s), if different) should include the relevant European or
2 2
international standards used to measure the relevant parameters listed in the Table 1.
— The measures in place to ensure a low dust working environment.
The declaration from the TiO supplier(s) (or TiO producer(s), if different) shall include a basic calculation about how the
2 2
annual average emissions were obtained. If the production of the supplied TiO pigment is non-continuous, then emission
2
data calculations covering a shorter period than 12 months may be accepted. In cases of continuous monitoring, the annual
average emission concentrations shall be derived from daily average concentrations. For periodically monitored emissions,
at least 3 samples must be taken to derive the average results. Any periodic sampling must be taken during periods of stable
operation that are representative of normal plant conditions for the production of the TiO pigments used in the EU
2
Ecolabel paint products.
The emission calculations shall only be required to be submitted at the date of application for the EU Ecolabel. If the EU
Ecolabel is awarded, the applicant can simply request updated declarations each year from their TiO supplier(s) of
2
continuing compliance with the emission limits.
For emissions to air, concentrations shall be expressed in units of mg/Nm3and multiplied by a specific emission air flow
rate in units of Nm3/tonne TiO pigment production for the same time period that the data was collected. If there is more
2
than one exhaust gas abatement system for major point sources of emissions to air, emissions from the clean air from each
abatement system shall be counted and added.
For emissions to water, either a direct measurement or a mass balance approach shall be used. The mass balance approach
shall be based on the balance between inputs of raw sulphate/chloride and outputs of sulphate/chloride in by-products, in
emissions to air and in solid waste that is disposed of to landfill or incinerated. The difference in the masses of the inputs
and outputs shall be considered as the mass of sulphate/chloride that is emitted to water during the calculation period and
shall be divided by the estimated quantity of TiO pigment produced during the same period to calculate specific emissions
2
to water in units of kg sulphate or chloride/t TiO pigment.
2
With the direct measurement approach for emissions to water, measured concentrations in units of g/m3shall be multiplied
by a specific treated wastewater effluent flow rate in units of m3/tonne TiO pigment production for the same time period
2
that the sulphate/chloride data was collected.
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Criterion 2. Efficiency in use requirements
In order to demonstrate the efficiency in use of performance coatings and related products, the following tests per type of
product, as indicated in Table 2 and detailed in the criterion text later, shall be undertaken.
Table 2
Performance requirements for different kinds of performance coatings and related products
Performance coating categories
(with their subcategories identified according to the Directive 2004/42/EC)
Criteria Binding
Primers
Floor covering Floor covering Anti-corrosion primers Waterproofing
(within i) and
paints (i, j) varnishes (i, j) products (i, j) (within i) and coatings (i, j)
j) systems)
j) systems)
If opaque,
2(a) Spreading rate Yes No If opaque If opaque If opaque
report only
2(b) White pigment If opaque,
Yes No If opaque No No
content report only
2(c) Resistance to
Yes Yes Yes No No Yes + ETA
water
If opaque If opaque If opaque If opaque If opaque If opaque and
and no and no and no no undercoat
2(d) Adhesion
undercoat or undercoat or undercoat or or primer
primer primer primer
If for metal If for trafficked
2(e) Abrasion Yes Yes No No
flooring floors
2(f) Weathering If outdoors If outdoors If outdoors No No If outdoors
2(g) Corrosion
If claimed No Yes If claimed If claimed If claimed
resistance
2(h) Ecotoxicity No No Yes No No If outdoors
2(a) Spreading rate
Note 1: This requirement does not apply to transparent or semi-transparent coatings.
Note 2. For tinting systems, this criterion applies only to the tinting base containing the most TiO . In cases where this
2
tinting base is unable to achieve this requirement, the criterion shall be met after tinting the base to produce the
standard colour RAL 9010.
Note 3. This requirement applies to all white paints. For families of paint products available only in preset shades, the
spreading rate shall apply to the lightest colour.
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Spreading rates shall be calculated while ensuring a hiding power of at least 98 % according to relevant European or
international standards or an equivalent method that can be validated against them. The following minimum spreading
rate limits apply:
— Indoor performance coatings shall have a spreading rate of at least 8 m2per litre of product.
— Outdoor performance coatings shall have a spreading rate of at least 6 m2per litre of product.
— Performance coatings marketed for both indoor and outdoor application shall meet the higher spreading rate
requirement of at least 8 m2per litre.
— Any opaque primers used in performance coating systems shall have a spreading rate of at least 8 m2 per litre of
product. A lower spreading rate of 6 m2 per litre of product applies to opaque primers with specific blocking,
sealing, penetrating, binding or special adhesion properties.
Assessment and verification:
The applicant shall provide a declaration of compliance with the relevant spreading rate limits or a justification of non-
applicability of the spreading rate requirement for each of the products covered by the EU Ecolabel application. The
declaration shall be supported by test results according to relevant European or international standards or an equivalent
method that can be validated against them. It shall be clearly indicated which spreading rate results correspond to which
families of products covered by the EU Ecolabel license application.
2(b) White pigment content
Note: This criterion only applies to paint products and white pigment content shall be calculated with the same products
for which spreading rate is measured as per the notes in criterion 2(a). For the purposes of this criterion, the term
‘white pigment’, shall be considered to refer only to pigments with a refractive index higher than 1,8.
The white pigment content shall not exceed:
— 36 g/m2for performance coatings marketed for indoor use only.
— 38 g/m2for performance coatings marketed for outdoor use only.
— 36 g/m2for performance coatings marketed for both indoor and outdoor use. Any EU Ecolabel paint products that
claim wet scrub resistance must meet the requirements for class 1 or class 2 according to the procedure defined in
relevant European or international standards and classification systems and comply with the respective upper limits
for white pigment content.
Assessment and verification:
The applicant shall provide a declaration of compliance with the relevant requirement or a justification of the non-
applicability of the requirements for each of the products covered by the EU Ecolabel application. In cases of relevant
products, the applicant shall declare the total content of white pigments with a refractive index > 1,8 in the final product,
relevant tinting base or white base paint formulations that are subject to the EU Ecolabel license application. This
information shall be provided in terms of the chemical name and CAS number of the white pigment, its declared refractive
index, its concentration in g/l of paint product and the density of the paint, in g/l
2(c) Resistance to water
Note: This requirement applies to all performance coatings. In coating systems with a primer or undercoat(s), either the
full coating system or just the finishing layer may be tested.
All performance coatings shall have resistance to water, as determined by relevant European or international standards,
such that after 24 hours of exposure and 16 hours of recovery, no change of gloss is observed in transparent or semi-
transparent coatings and no change of colour occurs in any opaque coatings.
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No change of gloss or colour in exposed samples shall be considered as a visual rating of 0 when measured for quantity of
defects, size of defects and intensity of changes according to the classification system of relevant European or international
standards.
Additionally for waterproofing coatings, compliance with any relevant European Assessment Document (EAD) stipulations
shall also be demonstrated.
Assessment and verification:
The applicant shall provide a declaration of compliance with the requirement or a justification of the non-applicability of
the requirement for each of the products covered by the EU Ecolabel license application.
For any applicable products included in their license application, the applicant declaration shall be supported by copies of
test report(s) following relevant European or international standards that cover the licensed product or family of products,
including reported results for change of gloss according to relevant European or international standards.
For waterproofing coatings, the applicant shall additionally provide a European Technical Approval (ETA) certificate that
has been issued by an approved Technical Assessment Body (for example a certificate according to EAD when the product
is a liquid applied roof waterproofing kit). In cases where there is no relevant EAD to follow, the applicant shall declare this
and provide a technical description of the product, including compliance with any relevant European or international
standards and a description of the intended uses of the product and how it should be used correctly.
2(d) Adhesion
Note: This criterion applies to opaque primers or undercoats for performance coatings. The adhesion test may be
conducted on any opaque primer or undercoat alone, or on the primer/undercoat and finishing coat together, so
long as the combination is opaque. In cases of different colour shades within a family of products, only the light-
coloured or white base paint or tinting base(s), need to be tested.
Primers for exterior masonry uses shall score a pass in the pull-off test of relevant European or international standards
where the cohesive strength of the substrate is less than the adhesive strength of the primer coating, otherwise the
adhesion of the primer coating must be in excess of a pass value of 1,5 MPa.
Floor primers or floor undercoats shall score 2 or less in the test for adhesion of relevant European or international
standards.
Assessment and verification:
The applicant shall provide a declaration of compliance with the relevant requirement or a justification of the non-
applicability of the requirements for each of the products covered by the EU Ecolabel application. For any opaque masonry
primer, binding primer or undercoat products included in their license application, the applicant shall provide copies of test
reports following relevant European or international standards, as applicable.
2(e) Abrasion
Note: This criterion applies to floor coatings. In cases of different colour shades within a family of products, only the
light-coloured or white base paint or tinting base(s),need to be tested.
A weight loss of ≤ 70 mg shall be observed when floor coatings are exposed to 1 000 test cycles with a 1 000 g load and a
CS10 wheel according to relevant European or international standards.
Assessment and verification:
The applicant shall provide a declaration of compliance with the requirement for floor coating products included in their
license application. The declaration shall be supported by copies of test reports following relevant European or
international standards.
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2(f) Weathering
Note: This criterion applies to outdoor performance coatings. In the case of different colour shades within a family of
products, only the light-coloured or white base paint or tinting base(s)need to be tested.
All outdoor performance coatings shall be exposed to artificial weathering in apparatus including fluorescent UV lamps
and condensation or water spray according to relevant European or international standards. They shall be exposed to test
conditions for 1 000 hours with cycling conditions of: UVA 4 h/60 °C + humidity 4 h/50 °C.
Alternatively, outdoor performance coatings for wooden substrates may be exposed to weathering for 1 000 hours in the
QUV accelerated weathering apparatus with cyclic exposure with UV(A) radiation and spraying according to relevant
European or international standards.
After weathering, the exposed films shall comply with the requirements specified in Table 3 below.
Table 3
Overview of weathering requirements for performance coatings and related products according to relevant
European or international standards
Property Requirement (after weathering) Scope of products covered/not covered
Not applicable to primers or intermediate
coats in performance coating systems nor to
Colour change Colour change, ΔΕ ≤ 4
transparent or semi-transparent
performance coating systems
Not applicable to performance coatings with
≤ 30 % decrease compared to initial
Decrease of gloss initial gloss value of < 60 % at 60° angle of
value
incidence
Chalking A score of ≤ 2
Flake density: ≤ 2
Flaking
Flake size: ≤ 2 Only applicable to finishing coats or the full
performance coating system used on
Crack quantity: ≤ 2 outdoor masonry, wood and metal
Cracking
Crack size: ≤ 3 substrates.
Blister density: ≤ 3
Blistering
Blister size: ≤ 3
Assessment and verification:
The applicant shall provide a declaration of compliance with the relevant requirement or a justification of the non-
applicability of the requirements for each of the products covered by the EU Ecolabel application. For any outdoor
performance coatings included in their license application, the applicant shall provide copies of test reports that detail the
weathering test method used (being in compliance with relevant European or international standards) and provide results
of changes in properties after weathering, as applicable.
2(g) Corrosion resistance
Note: This criterion only applies to anti-corrosion performance coatings and related products.
Anti-corrosion primers or coating systems shall be exposed to simulated corrosion stresses on the metallic substrates and
use environments (for example C2, C3, C4 or C5 as per relevant European or international standards) for which their use
is recommended. Corrosion stresses applied in testing shall correspond to the ‘high’ level for each category, which is as
follows:
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Table 4
Requirements for corrosion resistance testing for anti-corrosion primers and performance coating systems
according to relevant European or international standards
Test regime 1 Test regime 2
Corrosivity
category
Water condensation, hours Neutral salt spray, hours Annex B (cyclic ageing test, hours)
C2 (high) 120 - -
C3 (high) 240 480 -
C4 (high) 480 720 -
C5 (high) 720 1 440 1 680
After exposure, the coated surfaces shall be examined and be found to comply with the following requirements:
— A rating of 3 or better (i.e. 0, 1 or 2) for size of blisters according to relevant European or international standards.
— A rating of 3 or better (i.e. 0, 1 or 2) for quantity of blisters according to relevant European or international standards.
— A rating of Ri2 or better (i.e. Ri0 or Ri1) for degree of rusting according to relevant European or international
standards.
Assessment and verification:
The applicant shall provide a declaration of compliance with the relevant requirement or a justification of the non-
applicability of the requirements for each of the products covered by the EU Ecolabel application. Any declaration of
compliance shall be supported by copies of test reports according to relevant European or international standards.
2(h) Ecotoxicity
Note, this criterion only applies to anti-corrosion or waterproofing performance coating systems that are marketed for use
in outdoor environments. In the case of a family of products, only the worst-case product needs to be tested. The worst-case
product should be chosen based on the total estimated quantity of H400 and H410/H411/H412 classified ingredients
present.
Ecotoxicity shall be measured by testing the ecotoxicity of the eluate obtained from the contact with water of the two glass
plates that have been coated with the complete coating system, including any primer coats, undercoats, intermediate coats
and finishing coat. The test procedure is:
— Prepare two glass plates with roughened surfaces and apply the coating to the plates in accordance with manufacturer
instructions. Each plate shall present a coated surface area of between 250 and 500 cm2. Make sure that the primer
layer does not protrude from beyond the finishing layer.
— In parallel, prepare a blind test where the roughened glass plates are not coated at all but are treated and then tested in
an identical way exact for the coating procedure.
— Allow the coating to cure and be pre-conditioned for a period of 72 hours at a temperature of 19 to 25 °C and a
relative humidity of 40 to 60 %.
— Elute the coating on the glass plates (and blind control samples) in accordance with relevant European or
international standards for 24 hours (if the primer does not stick to the surface or the coating becomes detached
from the surface during the leaching test, the manufacturer and the testing institution should agree on another
environmentally safe surface instead of glass plates with a roughened surface).
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— The ratio of water volume to coated surface area of the test specimen shall be between 25 and 30 l/m2. A suitable
vessel shall be used that the water level can always remain at least 20 mm above the upper surface of the test
specimen.
— Measure the pH, conductivity and, optionally, dissolved organic carbon prior to starting the ecotoxicity tests, which
are defined in the Table 5 below together with their pass requirements.
Table 5
Ecotoxicity testing and requirements
Test species Endpoint Requirement
Luminescent bacteria (Vibrio fischeri) Light G ≤ 8
L
Algae (Raphidocelis subcapitata /Desmodesmus Growth G ≤ 4
A
subspicatus)
umu test Genotoxicity G ≤ 1,5
EU
Assessment and verification:
The applicant shall provide a declaration of compliance with the relevant requirement or a justification of the non-
applicability of the requirements for each of the products covered by the EU Ecolabel application. Any declaration of
compliance shall be supported by copies of test reports according to relevant European or international standards.
Criterion 3. Content of Volatile and Semi-volatile Organic Compounds (VOCs, SVOCs)
The maximum content of Volatile Organic Compounds (VOCs) and Semi-Volatile Organic Compounds (SVOCs) shall not
exceed the limits given in Table 6.
The content of VOCs and SVOCs shall be determined for the ready to use product and shall include any recommended
additions prior to application such as colourants and/or thinners.
Table 6
VOC and SVOC content limit
VOC and SVOC content limits
Product description (with subcategory denotation according to VOC limits (g/l of ready to use SVOC limits (g/l of ready to
Directive 2004/42/EC) product) use product)
i. One-pack performance coating products mentioned in
Article 2(1), including waterproofing coatings but excluding 65 45(1)/ 55(2)
anti-corrosion coatings
j. Multi-pack reactive performance coating products
mentioned in Article 2(1), including waterproofing coatings 65 45
but excluding anti-corrosion coatings
(part of i or j) Anti-corrosion coating products and primers 65 50
(1) SVOC limit applies to indoor white paints and varnishes
(2) SVOC limit applies to indoor tinted paints/outdoor paints and varnishes
(3) ‘Volatile organic compounds’ (VOC) means any organic compounds having an initial boiling point less than or equal to 250 °C
measured at a standard pressure of 101,3 kPa
(4) ‘Semi volatile organic compounds’ (SVOCs) means any organic compound having a boiling point greater than 250 °C and less than
370 °C measured at a standard pressure of 101,3 kPa
The VOC content shall be determined either by calculation based on the ingredients and raw materials or by using the
methods given in relevant European or international standards. The SVOC content shall be determined using the method
given in relevant European or international standards. In the case of products used both indoors and outdoors the strictest
SVOC limit value for indoor paints and varnishes shall prevail.
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Assessment and verification:
The applicant shall provide a declaration of compliance supported by calculations of VOC and SVOC contents based on the
ingredients and raw materials used in the ready to use product. Alternatively, the VOC and SVOC contents of the ready to
use product shall be communicated via a representative test report or reports using the methods given in relevant
European or international standards and results shall demonstrate compliance with the relevant limits.
Criterion 4. Restriction of hazardous substances and mixtures
Note: These sub-criteria apply to the final product formulation and any supplied ingredients therein.
4.1. Restrictions on Substances of Very High Concern (SVHCs)
The final product formulation and any supplied ingredients therein shall not contain any ingoing substances that meet the
criteria referred to in Article 57 of Regulation (EC) No 1907/2006 that have been identified according to the procedure
described in Article 59 of that Regulation and included in the candidate list for substances of very high concern for
authorisation.
Assessment and verification:
The applicant shall provide a signed declaration that the final product formulation and any supplied ingredients therein do
not contain any SVHCs as ingoing substances. The applicant declaration shall be supported by safety data sheets of all
supplied ingredients used to produce the final product and declarations from the chemical suppliers.
The list of substances identified as SVHCs and included in the candidate list in accordance with Article 59 of Regulation
(EC) No 1907/2006 can be found here:
https://www.echa.europa.eu/candidate-list-table
Reference to the list shall be made on the submission date of the EU Ecolabel application.
For any level of known impurities identified as SVHCs in ingredients, the concentration of the impurity and an assumed
retention factor of 100 % shall be used to estimate the quantity of the SVHC impurity remaining in the final product
formulation. Impurities that are SVHCs cannot be present in the paint or varnish product formulation above 0,0100 % w/
w or in any individual ingredient in concentrations exceeding 0,100 % w/w. Any deviation from a retention factor of 100 %
for an SVHC impurity (for example due to solvent evaporation) or in case of chemical modification, must be supported by
adequate justifications.
4.2. General restrictions based on classifications according to specific hazard classifications defined in
Regulation (EC) No 1272/2008.
(a) Final product formulation
The final product formulation shall not be classified as being carcinogenic, mutagenic, toxic for reproduction, acutely toxic,
an aspiration hazard, a specific target organ toxicant, a respiratory or skin sensitiser, hazardous to the aquatic environment,
hazardous to the ozone layer, an endocrine disruptor, persistent, bioaccumulative and toxic (PBT) or persistent, mobile and
toxic (PMT) in accordance with Regulation (EC) No 1272/2008 and specifically in terms of the hazard statement codes
stated in Table 7. The only exception permitted to this rule shall be the H412 and H413 classification, and only if due to
levels of dry-film preservatives in the case of outdoor paints or varnishes.
(b) Ingoing substances
Unless derogated in Table 8, the final product formulation shall not contain any ingoing substances in concentrations at or
above 0,010 % weight by weight of the final product formulation that are classified, in accordance with Regulation (EC)
No 1272/2008, with any of the hazard classes, categories and associated hazard statement codes stated in Table 7.
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Table 7
Restricted hazard classes, categories, codes and associated hazard statements
Carcinogenic, mutagenic or toxic for reproduction (CMR)
Categories 1A and 1B Category 2
H340: May cause genetic defects H341: Suspected of causing genetic defects
H350: May cause cancer H351: Suspected of causing cancer
H350i: May cause cancer by inhalation
H360: May damage fertility or the unborn child H361: Suspected of damaging fertility or the unborn child
H360F: May damage fertility H361f: Suspected of damaging fertility
H360D: May damage the unborn child H361d: Suspected of damaging the unborn child
H360FD: May damage fertility. May damage the unborn H361fd: Suspected of damaging fertility. Suspected of
child damaging the unborn child
H360Fd: May damage fertility. Suspected of damaging the H362: May cause harm to breast fed children
unborn child.
H360Df: May damage the unborn child. Suspected of
damaging fertility.
Acute toxicity
Categories 1 and 2 Category 3
H300: Fatal if swallowed H301: Toxic if swallowed
H310: Fatal in contact with skin H311: Toxic in contact with skin
H330: Fatal if inhaled H331: Toxic if inhaled
EUH070: Toxic by eye contact
Aspiration hazard
Category 1
H304: May be fatal if swallowed and enters airways
Specific target organ toxicity
Category 1 Category 2
H370: Causes damage to organs H371: May cause damage to organs
H372: Causes damage to organs through prolonged or H373: May cause damage to organs through prolonged or
repeated exposure repeated exposure
Respiratory and skin sensitization
Category 1, 1A and 1B
H317: May cause an allergic skin reaction
H334: May cause allergy or asthma symptoms or breathing
difficulties if inhaled
Hazardous to the aquatic environment
Categories 1 and 2 Categories 3 and 4
H400: Very toxic to aquatic life H412: Harmful to aquatic life with long-lasting effects
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Carcinogenic, mutagenic or toxic for reproduction (CMR)
Categories 1A and 1B Category 2
H410: Very toxic to aquatic life with long-lasting effects H413: May cause long-lasting effects to aquatic life
H411: Toxic to aquatic life with long-lasting effects
Hazardous to the ozone layer
H420: Harms public health and the environment by
destroying ozone in the upper atmosphere
Endocrine disruptors (EDs) for human health and the environment
Category 1 Category 2
EUH380: May cause endocrine disruption in humans EUH381: Suspected of causing endocrine disruption in
humans
EUH430: May cause endocrine disruption in the EUH431: Suspected of causing endocrine disruption in the
environment environment.
Persistent, Bioaccumulative and Toxic (PBT)
PBT very Persistent and very Bioaccumulative (vPvB)
EUH440: Accumulates in the environment and living EUH441: Strongly accumulates in the environment and
organisms including in humans living organisms including in humans
Persistent, Mobile and Toxic (PMT)
PMT very Persistent and very Mobile (vPvM)
EUH450: Can cause long-lasting and diffuse contamination EUH451: Can cause very long-lasting and diffuse
of water resources contamination of water resources
The use of substances that are chemically modified during the production process, so that any relevant hazard for which the
substance has been classified under Regulation (EC) No 1272/2008 no longer applies, shall be exempted from the above
requirement.
This criterion shall not apply to ingoing substances covered by points (a) and (b) of Article 2(7) of Regulation (EC)
No 1907/2006, which set out criteria for exempting substances within Annexes IV and V to that Regulation from the
registration, downstream user and evaluation requirements.
Table 8
Derogations to restrictions on ingoing substances that are classified with one or more of the restricted hazards
listed in Table 7 and are present in concentrations at or above 0,010 % (weight by weight) of the final product
formulation.
Substance type, substance Derogated hazard
Derogation conditions
name and CAS number code(s)
Preservatives and preservative stabilisers
Note on preservatives: all preservatives added to ingredients must be declared by suppliers and all preservatives added
directly to the final product formulation must be declared by the paint or varnish producer. The only types of
preservatives permitted in ingredients and the final product shall be those that are compliant with Regulation (EU)
No 528/2012. For final products originating in the Union, it is reminded that it is not sufficient that the active substances
contained in the preservative product are approved under Regulation (EU) No 528/2012 for product type 6 (PT6) (in-can
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Substance type, substance Derogated hazard
Derogation conditions
name and CAS number code(s)
preservative) or for product type 7 (PT7) (dry-film preservative), but the preservative product must be authorised under
Regulation (EU) No 528/2012 for PT6 or PT7 or made available on the market according to the transitional measures set
out in Article 89(2) of that Regulation. The combined total limits for PT6 and PT7 preservatives shall apply to these
following product categories:
— For indoor products: up to 0,080 % weight by weight of PT6 in the final product.
— For colour tints used in tinting systems: up to 0,20 % weight by weight of PT6 in the colour tint.
— For indoor products marketed for use in high humidity areas: up to 0,080 % weight by weight of PT6 and up to
0,10 % weight by weight of PT7 in the final product.
— For outdoor products: up to 0,080 % weight by weight of PT6 and up to 0,50 % weight by weight of PT7 in the
final product.
Except for colour tints, all references to concentrations/limits/levels of preservatives in the section ‘Preservatives and
preservative stabilisers’, shall be understood as referring to the preservative active substances contained in the final
product formulation.
Any preservatives which cannot be present in the final product formulation at concentrations exceeding 0,010 %, due
to specific concentration limits (SCLs) lower than 0,010 % that would classify the final product with a restricted CLP
hazard, are not mentioned in the derogation table below because they cannot be used in concentrations exceeding
0,010 % in the first place and thus do not need a derogation. This does not imply that they cannot be used as ingoing
substances in EU Ecolabel products at any level. If not explicitly excluded in sub-criterion 4.3, such preservatives may
be used so long as it is at levels below any SCLs that would trigger a restricted CLP classification of the final product
formulation.
In-can preservatives (PT6) H301, H311, (*)See horizontal derogation condition at foot of table
in colour tints or final H317, H330, The sum total of all PT6 in-can preservatives (those derogated for
product: H331, H372, use above 0,010 % plus those that are non-derogated but used in
H373, H400, levels < 0,010 %) must be within the relevant limits defined in the
H410, H411, note above.
H412, H413 When preservatives that are formaldehyde donors are used, the
relevant limits for free formaldehyde in the final product
formulation set out in sub-criterion 4.3(l) must be respected.
Specific concentration limits (% weight by weight in the final
product formulation) shall apply for the derogated substances
listed below:
— Bronopol(CAS No 52-51-7): up to 0,030 %.
— DBNPA(CAS No 10222-01-2): up to 0,030 %.
— Sodium pyrithione(CAS No 3811-73-2): up to 0,030 %.
— BIT(CAS No 2634-33-5): up to 0,036 %.
— Combined total isothiazolinones and isothiazolinone releasers
(those derogated for use above 0,010 % plus those that are non-
derogated but used in levels < 0,010 %): up to 0,040 % in final
product formulations.
— Diamine(CAS No 2372-82-9): up to 0,050 %.
Dry-film preservatives H311, H317, (*)See horizontal derogation condition at foot of table
(PT7): H330, H331, Only applies to outdoor products and indoor products for use in
H372, H373 high humidity areas.
H400, H410, The sum total of all PT7 dry-film preservatives (those derogated for
H411, H412 and use above 0,010 % plus those that are non-derogated but used in
H413 levels < 0,010 %) must be within the relevant limits defined in the
note above.
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Substance type, substance Derogated hazard
Derogation conditions
name and CAS number code(s)
In the case of slow release, encapsulated forms of dry-film
preservatives, the specific classification of the final product, or
read-across formulations, should consider the absolute
concentration of the hazardous components (i.e. without capsules).
The final product or read-across formulation cannot be classified
with any of the hazards listed in Table 7.
Any dry-film preservatives classified as H400 or H410 must be
non-bioaccumulative, demonstrated by having an octanol-water
coefficient (Log Kow) of ≤ 3,2 or a bioconcentration factor (BCF) of
≤ 100.
Preservative stabiliser: H400, H410 (*)See horizontal derogation condition at foot of table
Zinc oxide (CAS Permitted to be used as a preservative stabiliser, up to 0,040 %
No 1314-13-2) weight by weight in the final product formulation, when used to
stabilise in-can or dry-film preservative combinations that require
1,2-Benzisothiazol-3(2H)-one (BIT).
Drying and anti-skinning agents
Anti-skinning agents H317, H412, (*)See horizontal derogation condition at foot of table
H413 The sum total anti-skinning agent content shall not exceed 0,40 %
weight by weight in the final product formulation.
Driers (siccatives) H301, H317, (*)See horizontal derogation condition at foot of table
H373, H400†, The sum total drier content shall not exceed 0,10 % weight by
H410†, H412, weight in the final product formulation.
H413 † The derogation for H400 and H410 only applies to cobalt-based
drier compounds and such compounds can only be used up to
0,050 % weight by weight in the final product formulation.
Pigments and pigments additives
Trimethylolpropane (CAS H361fd (*)See horizontal derogation condition at foot of table
No 77-99-6) Only when used as an additive in supplied pigments and only up to
0,50 % weight by weight in the supplied pigment.
Binders and polymer dispersions
Binders and crosslinking H317, H411 (*)See horizontal derogation condition at foot of table
agents: Only allowed up to 1,0 % weight by weight in the binder or
Adipic acid dihydrazide polymer dispersion ingredient and when used as an adhesion
(CAS No 1071-93-8) promoter or as a crosslinking agent.
Unreacted monomers (in H301, H304, (*)See horizontal derogation condition at foot of table
binders) H311, H317, The sum total concentration of unreacted monomers needing this
H331, H334, derogation shall not exceed 0,050 % weight by weight in the final
H372, H400, product formulation.
H410, H411,
H412
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Substance type, substance Derogated hazard
Derogation conditions
name and CAS number code(s)
Other, miscellaneous
Methanol (CAS H301, H311, (*)See horizontal derogation condition at foot of table
No 67-56-1) H331, H370 Only permitted as a residual reaction product of other substances
in the product formulation. Allowable residual concentration
increases as a function of binder content in the following manner:
— Binder content of 10-20 %: allowable residual methanol is
0,020 % weight by weight in the final product formulation.
— Binder content of 20-40 %: allowable residual methanol is
0,030 % weight by weight in the final product formulation.
— Binder content of > 40 %: allowable residual methanol is
0,050 % weight by weight in the final product formulation.
Mineral raw materials, H372, H373 (*)See horizontal derogation condition at foot of table
including fillers, anti- Only applies to mineral raw materials and leucophyllite minerals
sagging agents and that naturally contain crystalline silica.
matting agents Only permitted in contents up to 1,0 % weight by weight in the
final product formulation for H372 materials or up to 10 % for
H373 materials.
In cases where the material is supplied in dry powder form, the
applicant shall demonstrate that they have systems in place to
minimise worker exposure to dry powder in the workplace (for
example closed dosing systems, ventilated dosing and mixing areas
and personal protective equipment).
Neutralising agents H301, H311, (*)See horizontal derogation condition at foot of table
H331, H400, Only allowed up to 1,0 % weight by weight in varnish
H410, H411, formulations, and up to 0,50 % in all other products.
H412, H413
Optical brighteners H413 (*)See horizontal derogation condition at foot of table
Only allowed up to 0,10 % weight by weight in the final product
formulation.
Silicone resin H412, H413 (*)See horizontal derogation condition at foot of table
Only allowed up to 2,0 % weight by weight in the final product
formulation.
Solvents H304 (*)See horizontal derogation condition at foot of table
Only allowed up to 2,0 % weight by weight in the final product
formulation.
Surfactants H411, H412, (*)See horizontal derogation condition at foot of table
H413 Only allowed up to 1,0 % weight by weight in transparent, semi-
transparent, white or light-coloured product formulations or up to
3,0 % weight by weight in all other colours.
UV stabilisers H317, H411, (*)See horizontal derogation condition at foot of table
H412, H413 Only applicable to outdoor products and only up to 0,60 % weight
by weight in the final product formulation.
(*) Horizontal derogation condition: none of the derogations above, either individually or in combination, shall be permitted if they
result in the final product formulation being classified with any of the hazards defined in Table 7, with the notable exception of
H412 and H413 for outdoor products due to the presence of dry-film preservatives.
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Assessment and verification:
The applicant shall provide a signed declaration of compliance with sub-criterion 4.2, including compliance with any
relevant derogation conditions, supported by declarations from suppliers and any other relevant documentation.
A list of all ingoing substances with one or more of the restricted CLP hazards calculated to be present in the final product
formulation in concentrations greater than 0,010 % weight by weight shall be presented, together with their CAS numbers,
CLP classification status (i.e. harmonised, joint entry or self-entries only) the relevant function of the ingoing substance (for
example in-can preservative, drier, pigment, neutralising agents, surfactants, UV stabiliser etc.)., Calculations for ingoing
substance concentrations in the final product formulation shall be based on:
— a list of all ingredients, chemicals or raw materials used to make the final product formulation;
— the screening of ingredients, chemicals or raw materials for those ingoing substances and known impurities with any
of the EU Ecolabel-restricted CLP hazards;
— the concentrations of any screened ingoing substances and known impurities with EU Ecolabel-restricted CLP hazards
in the ingredients, chemicals or raw materials used in the format supplied;
— the weight of each of the ingredients, chemicals or raw materials added to make a known weight of final product
formulation.
Known impurities shall be treated as ingoing substances only if the screening exercise reveals that their content in the final
product formulation shall exceed 0,010 % weight by weight or their content in an ingredient shall exceed 0,100 % weight
by weight. Known impurities below these thresholds shall not be counted in calculations.
Any screened ingoing substances shall be assumed by default to be 100 % retained in the final product. Justifications for any
deviation from a retention factor of 100 % during processing (for example solvent evaporation) or for chemical
modification of a screened ingoing substance shall be provided. Substances known to be released or to degrade from
ingoing substances are considered ingoing substances and not impurities.
For any screened ingoing substances remaining in the final product formulation in concentrations greater than 0,010 %
weight by weight, but which are exempted from sub-criterion 4.2 (see Annexes IV and V to Regulation (EC)
No 1907/2006), a declaration to this effect by the applicant shall suffice for those substances.
Since multiple products or potential products (for example customised shades from a tinting system) using the same
ingredients, chemicals or raw materials may be covered by one EU Ecolabel license, a worst-case calculation may be
acceptable for each screened ingoing substance within a common family of products covered by the same license.
Regarding information requested from suppliers that may be commercially sensitive, evidence from suppliers can also be
provided directly to competent bodies without necessarily providing certain details to the applicant.
4.3. Specific hazardous substance restrictions for ingoing substances.
Unless derogated in sub-criterion 4.2, the substances indicated below shall not be included as ingoing substances in the final
product formulation or as ingoing substances to the ingredients used to make the final product formulation:
(a) Preservatives or driers classified as carcinogenic, mutagenic or toxic for reproduction.
(b) Substances classified as category 1 or category 2 endocrine disruption for human health or the environment in
accordance with CLP Regulation (EC) 1272/2008, substances included in the candidate list referred to in
Article 59(1) of REACH Regulation (EC) 1907/2006 as having endocrine-disrupting properties for human health or
the environment, substances identified as having endocrine-disrupting properties in accordance with Regulation
(EU) No 528/2012 or Regulation (EC) No 1107/2009, except for DBNPA (CAS No 10222-01-2) when used as an
in-can preservative.
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(c) Substances classified as Persistent, Bioaccumulative and Toxic (PBT) or very Persistent and very Bioaccumulative
(vPvB) for the environment and living organisms including in humans in accordance with CLP Regulation
(EC) 1272/2008, substances included in the candidate list referred to in Article 59(1) of REACH Regulation
(EC) 1907/2006 as having PBT or vPvB properties for the environment and living organisms including in humans,
substances identified as having PBT or vPvB properties for the environment and living organisms including in
humans in accordance with Regulation (EU) No 528/2012 or Regulation (EC) No 1107/2009.
(d) Substances classified as Persistent, Mobile and Toxic (PMT) or very Persistent and very Mobile (vPvM) in accordance
with CLP Regulation (EC) 1272/2008, substances included in the candidate list referred to in Article 59(1) of REACH
Regulation (EC) 1907/2006 as having PMT or vPvM properties.
(e) Alkylphenols, alkylphenol ethoxylates (APEOs) and their derivatives, as referred to in entry 43 to Annex XIV or entry
46 to Annex XVII of the Regulation (EC) 1907/2006.
(f) Perfluorinated and polyfluorinated compounds (PFAS), as defined in Article 4(42).
(g) Phthalates.
(h) Organotin compounds.
(i) Fragrance substances which are prohibited or restricted in cosmetic products and listed in Annexes II or III to
Regulation (EC) No 1223/2009.
(j) Bisphenols that have been identified by ECHA in their 2021 ‘Assessment of Regulatory Needs report on Bisphenols’
for further EU regulatory risk management that are known or potential endocrine disruptors for the environment or
for human health, or that can be identified as toxic for reproduction.
(k) Pigments used shall not be based on Cadmium, Lead, Chromium (VI), Mercury, Arsenic, Selenium, Antimony or
Cobalt. The following impurities from any pigments used shall not be present in the final product formulation in
quantities exceeding 0,010 % weight by weight (per metal): Cadmium, Lead, Chromium (VI), Mercury, Arsenic,
Selenium, Antimony and Cobalt. The only exceptions to pigment use and to the 0,010 % limit for impurities shall be:
— Cobalt: due to the use of Cobalt aluminate blue spinel (CAS No 1345-16-0) and Cobalt chromite blue-green
spinel pigments (CAS No 68187-11-1).
— Antimony: due to the use of pigments based on Antimony Nickel within an insoluble TiO lattice.
2
(l) Free formaldehyde shall not be intentionally added to the final product formulation. The final product shall be tested
in order to determine its free formaldehyde content. Worst-case samples for testing shall be selected for each family of
products based on which product is predicted to have the highest theoretical amount of formaldehyde content. Under
the conditions defined below, the following sum total limits of free formaldehyde shall be permitted:
— Up to 0,0010 % weight by weight permitted when bronopol or preservatives that are formaldehyde donors are
required as an in-can preservative to protect a specific type of paint or varnish
— Up to 0,010 % weight by weight permitted when polymer dispersions (binders) provide, through residual levels
of formaldehyde, the function of formaldehyde donors instead of in-can preservatives.
— Up to 0,010 % when both conditions listed above apply in the same product.
(m) Synthetic polymer microparticles (SPMs, commonly known as microplastics) as defined in entry 78 of Annex XVII to
Regulation (EC) No 1907/2006 (REACH), shall not be used for non-film forming purposes in any product
formulation unless their use and purpose is explicitly declared, together with a justification of why their use
improves the overall environmental performance of the paint or varnish product.
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Assessment and verification:
(a to j) The applicant shall declare the non-use of the relevant substances indicated in this sub-criterion, namely CMR
preservatives, CMR driers, endocrine disruptors (except DBNPA), PBT and vPVB substances, PMT and vPvM
substances, alkylphenols and APEOs, PFAS, phthalates, organotin compounds, fragrances and bisphenols as
ingoing substances in their formulation, supported by declarations from their suppliers about the non-use of
the same hazardous substance groups as ingoing substances in the ingredients supplied and that are used in
formulations covered by the EU Ecolabel license application procedure.
(k) In the case of the heavy metal restrictions from pigments, the applicant or pigment supplier shall provide a
declaration stating that neither the pigment itself nor any ingoing substances that may be incorporated into
the pigment product are based on the listed heavy metals. The applicant or pigment supplier shall also provide
a test report with the heavy metal impurity levels of representative samples of the pigment supplied. The
applicant shall then use these results, together with the % of pigment(s) used in the final product, to calculate
the concentration of heavy metals from pigments remaining in the final product. In the case of exempted
pigments, the pigment supplier shall declare which pigment(s) have the exemption (i.e. cobalt aluminate blue
spinel, cobalt chromite blue-green spinel or antimony nickel in an insoluble TiO lattice).
2
(l) The applicant shall declare which of their products should have the highest theoretical free formaldehyde
content within each family of products’ formulation. This declaration shall be based on the choice of the paint
formulator to use formaldehyde donors as in-can preservatives and declarations from suppliers regarding the
amounts of formaldehyde donors used to preserve supplied ingredients (especially binders). The addition of
these substances (and any other ingredients that release formaldehyde) to the worst-case formulations shall not
result in the content of free formaldehyde in the final product exceeding the relevant concentration limit, as
measured with relevant European or international standards.
(m) The applicant shall provide either a declaration of the non-use of SPMs for non-film forming purposes or a
declaration of their use in their product formulation. In cases where the use of SPMs for non-film forming
purposes is declared, the type, quantity (% weight by weight) and purpose shall be stated in the declaration,
together with a justification of how the use of SPMs for non-film forming purposes improves the overall
environmental performance of the product. Such justifications should normally compare the environmental
performance of the same product with and without the SPMs for non-film forming purposes.
Criterion 5. Volatile Organic Compounds (VOCs) emissions
Note: Only applicable to indoor performance coatings and related products.
Emissions of VOCs shall not exceed the limits defined in the table below.
Table 9
VOC emission limits
Parameter 3-day test results 28-day test results
TVOC(*) ≤ 3 000 μg/m3 ≤ 300 μg/m3
R value(**) n/a ≤ 1,0
Formaldehyde n/a ≤ 10 μg/m3
Any other category 1A or 1B carcinogenic VOCs not covered by EU LCI ≤ 10 μg/m3per ≤ 1 μg/m3per
values(***) substance substance
(*) TVOC shall be measured as defined in relevant European or international standards and including quantification of any non-target
compounds
(**) R value, as defined in relevant European or international standards. Results for the cumulative R value shall be rounded to one
decimal place before determining compliance or non-compliance with the limit of 1,0.
(***)Does not apply to formaldehyde, which is a VVOC and is covered by a specific individual limit. Does not apply to any other
carcinogenic VVOCs or VOCs that have an EU-LCI value, since these are already covered by the R-value limit.
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Assessment and verification:
The applicant shall submit a copy of test report according to relevant European or international standards for the worst-
case product formulation within each of the relevant families of products being covered by the EU Ecolabel license
application. Any changes to the formulations that would create a higher worst-case VOC content shall trigger the
requirement to submit an updated VOC emission test report. When relevant, a clear explanation of the distinctions made
between families of products (for example binder chemistry, product category etc.) shall be provided, together with a
justification of the worst-case product within each family of products.
In cases where a coating system has multiple layers, the full system should be applied to the test substrate according to
manufacturer instructions prior to emission testing.
For the calculation of the R value, reference should be made to the latest set of agreed EU LCI (Lowest Concentration of
Interest) values available at the time of testing. These values can be consulted on the European Commission website (1).
If chamber air concentrations can be shown to comply with the 28-day limits before the 28-day period has been completed
but after a period of at least 3 days, then those results can be accepted as proof of compliance and the test can be halted at
that point.
(1) See https://single-market-economy.ec.europa.eu/sectors/construction/eu-lci-subgroup/eu-lci-values_en
Criterion 6. Consumer information
6(a) The following information shall appear on or be attached to the packaging:
— Recommendation to minimise coating product wastage by estimating how much coating product is
needed before purchase,
— How to recover unused coating product for reuse,
— How reuse of coating product can effectively minimise the products’ life cycle environmental impact,
— Information requested in sub-criterion 6(b) or explanation of how to access such information.
6(b) The following information shall appear on or be attached to the packaging or be available via a web-link or
QR code:
— How to estimate the amount of coating product needed prior to purchase in order to minimise coating
product wastage and a recommended amount as a guideline (for example for 1 m2of wall, X litres of
coating product is needed),
— Appropriate storage conditions of the product (before and after opening), including, where appropriate,
safety advice,
— Safety measures for the user including basic recommendation on personal protective equipment that
should be worn and additional measures that should be taken when using the product and if applicable
when using spray equipment,
— The use of cleaning equipment and appropriate waste management of the ‘leftover coating product’ and
packaging (in order to limit water and soil pollution). For example, text advising that the unused
product requires specialist handling for safe environmental disposal and therefore it should not be
thrown away with household or commercial waste.
Assessment and verification:
The applicant shall declare that the product complies with the requirement and provide the competent body with the
artwork or samples of the user information and/or a link or QR code to a manufacturer’s website containing this
information as part of the application. The recommended amount of paint given as a guideline shall be provided.
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Criterion 7. Information appearing on the EU Ecolabel
The optional label with text box shall contain three of the following statements, according to their relevance:
— Minimised content of hazardous substances,
— Reduced content of volatile organic compounds (VOCs): x g/l,
— Reduced emissions of volatile organic compounds to indoor air (for indoor products),
— Good performance for indoor use (for indoor products), or
— Good performance for outdoor use (for outdoor products), or
— Good performance for both indoor and outdoor use (for products suitable for indoor and outdoor use).
The guidelines for the use of the optional label with text box can be found in the ‘Guidelines for use of the Ecolabel logo’ on
the website:
http://ec.europa.eu/environment/ecolabel/documents/logo_guidelines.pdf
Assessment and verification:
The applicant shall provide a sample of the product label or an artwork of the packaging where the EU Ecolabel is placed,
together with a declaration of compliance with this criterion.
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ANNEX III
EU Ecolabel criteria for awarding the EU Ecolabel to water-based aerosol spray paints
The EU Ecolabel criteria target the best water-based aerosol spray paints on the market, in terms of environmental
performance. The criteria focus on the main environmental impacts associated with the life cycle of these products and
promote circular economy aspects.
Assessment and verification requirements
For the EU Ecolabel to be awarded to a specific product, the product shall comply with each requirement. The applicant
shall provide a written confirmation stating that all the criteria are fulfilled.
Specific assessment and verification requirements are indicated within each criterion.
Where the applicant is required to provide declarations, documentation, analyses, test reports, or other evidence to show
compliance with the criteria, these may originate from the applicant and/or their supplier(s) as appropriate.
Competent bodies shall preferentially recognise attestations that are issued by bodies accredited in accordance with the
relevant harmonised standard for testing and calibration laboratories, and verifications by bodies that are accredited in
accordance with the relevant harmonised standard for bodies certifying products, processes, and services.
Where appropriate, test methods other than those indicated for each criterion may be used if the competent body assessing
the application accepts their equivalence.
Where appropriate, competent bodies may require supporting documentation and may carry out independent verifications
or site inspections to check compliance with these criteria.
Changes in suppliers and production sites pertaining to products to which the EU Ecolabel has been awarded shall be
notified to competent bodies, together with supporting information to enable verification of continued compliance with
the criteria.
As pre-requisite, the product shall meet all respective legal requirements of the country or countries in which the product is
intended to be placed on the market. The applicant shall declare the product’s compliance with this requirement.
The following information shall be provided together with the application for the EU Ecolabel:
(a) A list of all individual paint and varnish products covered by the EU Ecolabel application, grouped into product
families and indicating any relevant product characteristics that affect which specific requirements from the EU
Ecolabel criteria would apply. A family of products will all have the same base formulation and product subcategory,
but may differ in terms of shade and/or packaging format.
(b) A description of the product formulation(s), with a % composition of the ingredients used and the specific function of
each ingredient (the composition information may be subject to a non-disclosure agreement between the applicant
and the competent body or, in some cases, directly between the supplier and the competent body). Ingredient
functions shall be either: accelerator; additive; anti-blocking agent; anti-foaming agent; anti-settling agent; anti-
skinning agent; binder; coalescing agent; colourant-dyestuff; colourant-pigment; crosslinking agent; curing agent/
hardener; diluent; dispersing agent; drier; filler; dry-film preservative; in-can preservative; matting agent; neutralising
agent; optical brightener; plasticiser; polymer dispersion; preservative stabiliser; resin; retarder; rheological modifier;
silicone resin; solvent; surfactant; UV stabiliser; water; water-repelling agent or, in case none of these apply, ‘other’.
(c) Safety data sheets for the ingredients used in the paint and varnish formulations.
(d) Any other information associated with the production of ingredients and materials that is necessary for
demonstrating compliance with the EU Ecolabel criteria shall be provided by the suppliers or producers of those
ingredients and materials.
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(e) In order to help determine the number of products within any given family of products, a description of the
packaging format(s) used, the volume(s) of product held and the packaging material(s) used for each of the paint and
varnish products covered by the EU Ecolabel application.
(f) In order to reduce the quantity of testing and documentation required for assessment and verification procedures,
several criteria explicitly state that compliance of an entire family of products can be assumed if the worst-case
product can be shown to comply. Each time data for a worst-case product is submitted, it shall be accompanied by
an explanation of why this particular product represents the worst-case within its family of products for the
property being tested.
Criterion 1. Titanium dioxide production
If the final product contains more than 3,0 % w/w of titanium dioxide (TiO ) pigment, the emissions to air and water from
2
the production of any titanium dioxide pigment used shall meet the relevant requirements listed below for the respective
production processes:
Table 1
Requirements for Titanium Dioxide production
Parameter and analytical method Sulphate process Chloride process
Emissions of dust to air(1)(measured with the relevant ≤ 0,40 kg/t TiO pigment ≤ 0,66 kg/t TiO pigment
2 2
European or international standards)
Emissions of SO to air(1)(measured with the relevant ≤ 4,5 kg/t TiO pigment n/a
2 2
European or international standards)
Emissions of HCl to air(1)(measured with the relevant n/a ≤ 0,70 kg/t TiO pigment
2
European or international standards)
Emissions of SO 2-to water (measured with the relevant ≤ 300 kg SO 2-/t TiO n/a
4 4 2
European or international standards) pigment
Emissions of Cl-to water (measured using the mass n/a ≤ 103 kg Cl-/t TiO pigment(2)
2
balance method or with the relevant European or ≤ 179 kg Cl-/t TiO pigment(3)
2
international standards) ≤ 329 kg Cl-/t TiO pigment(4)
2
Low dust working environment To be demonstrated To be demonstrated
(1) Point sources for emissions of dust to air from the chloride process are considered as: milling, chlorination, oxidation and
micronisation stages. Point sources for emissions of HCl to air from the chloride process are considered as: chlorination, acid
scrubber from solid separation and metal chloride treatment processes. Point sources for emissions of dust to air from the sulphate
process are considered as: milling, digestion, calcination and micronisation stages. Point sources for emissions of SO to air from the
2
sulphate process are considered as: digestion and calcination processes.
(2) When ore used is > 95 % TiO content.
2
(3) When ore used is 90-95 % TiO content.
2
(4) When ore used is < 90 % TiO content.
2
Emissions to air shall be counted from the relevant point source(s) stated in point (1) above where emissions can be
continuously or periodically monitored from a fixed sampling point after any exhaust gas abatement system(s).
Emissions to water shall be considered as sulphate or chloride present in any treated wastewater effluent that is discharged
into any rivers, lakes, transitional waters, coastal waters or seawaters.
The relevant limit for chloride emissions to water shall be based on the weighted average % TiO content of ore(s) used
2
during the calculation period.
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A low dust working environment shall, as a minimum, include the follows aspects:
— A risk assessment for the workplace that identifies all the main areas of potential dust emission and worker exposure
to dust.
— The need to have in place an occupational hygiene workplace monitoring program.
— Provision of appropriate training to employees about good practice for dust control.
— Provision of adequate personal protective equipment to employees and visitors.
Assessment and verification
The applicant shall declare the content of TiO used in each of the product formulations subject to the EU Ecolabel license
2
application. For any products with more than 3,0 % w/w TiO pigment content, the applicant shall also declare the supplier
2
or suppliers of the TiO used in those products.
2
The applicant declaration shall be supported by declarations from their TiO supplier(s) (or TiO producer(s), if different)
2 2
stating:
— The type of TiO production process used (chloride or sulphate).
2
— The applicable TiO content range of the weighted average ore in case of the chloride process.
2
— Annual average emissions data of dust to air, SO to air, and SO 2-to water for TiO produced through the sulphate
2 4 2
process. Alternatively, average emission data of dust to air, HCl to air, and Cl- to water for TiO produced through
2
the chloride process.
— The declarations from TiO supplier(s) (or TiO producer(s), if different) should include the relevant European or
2 2
international standards used to measure the relevant parameters listed in the Table 1.
— The measures in place to ensure a low dust working environment.
The declaration from the TiO supplier(s) (or TiO producer(s), if different) shall include a basic calculation about how the
2 2
annual average emissions were obtained. If the production of the supplied TiO pigment is non-continuous, then emission
2
data calculations covering a shorter period than 12 months may be accepted. In cases of continuous monitoring, the annual
average emission concentrations shall be derived from daily average concentrations. For periodically monitored emissions,
at least 3 samples must be taken to derive the average results. Any periodic sampling must be taken during periods of stable
operation that are representative of normal plant conditions for the production of the TiO pigments used in the EU
2
Ecolabel paint products.
The emission calculations shall only be required to be submitted at the date of application for the EU Ecolabel. If the EU
Ecolabel is awarded, the applicant can simply request updated declarations each year from their TiO supplier(s) of
2
continuing compliance with the emission limits.
For emissions to air, concentrations shall be expressed in units of mg/Nm3and multiplied by a specific emission air flow
rate in units of Nm3/tonne TiO pigment production for the same time period that the data was collected. If there is more
2
than one exhaust gas abatement system for major point sources of emissions to air, emissions from the clean air from each
abatement system shall be counted and added.
For emissions to water, either a direct measurement or a mass balance approach shall be used. The mass balance approach
shall be based on the balance between inputs of raw sulphate/chloride and outputs of sulphate/chloride in by-products, in
emissions to air and in solid waste that is disposed of to landfill or incinerated. The difference in the masses of the inputs
and outputs shall be considered as the mass of sulphate/chloride that is emitted to water during the calculation period and
shall be divided by the estimated quantity of TiO pigment produced during the same period to calculate specific emissions
2
to water in units of kg sulphate or chloride/t TiO pigment.
2
With the direct measurement approach for emissions to water, measured concentrations in units of g/m3shall be multiplied
by a specific treated wastewater effluent flow rate in units of m3/tonne TiO pigment production for the same time period
2
that the sulphate/chloride data was collected.
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Criterion 2. Efficiency in use requirements
In order to demonstrate the efficiency in use of aerosol spray paints the following tests and requirements shall be
undertaken:
2(a) Spreading rate
Note 1: This requirement does not apply to any aerosol products that are designed to apply transparent or semi-
transparent coatings.
Note 2: If tinting systems are used to make different aerosol paint shades, only to the tinting base containing the most
TiO needs to be tested. In cases where this tinting base is unable to achieve this requirement, the criterion shall
2
be met after tinting the base to produce the standard colour RAL 9010.
Note 3: This requirement applies to white aerosol spray paints. For families of aerosol spray paints available only in preset
shades, the spreading rate shall apply to the lightest colour.
Aerosol spray paints shall have a spreading rate of at least 2,0 m2per litre while ensuring a hiding power of at least 98 %
according to relevant European or international standards. The volume unit in the spreading rate calculation shall refer to
the declared volume of the ready to use spray can.
Assessment and verification:
The applicant shall provide a declaration of compliance with the spreading rate limits or a justification of non-applicability
of the spreading rate requirement for each of the products covered by the EU Ecolabel application. The declaration shall be
supported by test results according to the method in relevant European or international standards. In cases where a result
covers multiple products, it shall be clearly indicated which results correspond to which products covered by the EU
Ecolabel license application.
2(b) Efficiency in spraying
Aerosol spray paints shall have an efficiency in spraying of at least 97 %, considered as the fraction of product in the ready
to use spray can that is discharged from the can.
The test method shall consist of a calculation of the total content of product contained in the ready to use spray can that has
not yet been operated. Prior to the test, the ready to use spray can shall be weighed. During the test, the contents of the can
shall be continuously discharged onto a weighed surface at a steady rate in order to monitor the discharge rate. After the
test, the spray can shall be weighed again to determine the total content of product discharged. The efficiency in spraying
rate shall be calculated as
total weight of product discharged during testðgÞ
Efficiency in spraying ð%Þ¼ x100%
total weight of product in can at beginning of test ðgÞ
Assessment and verification:
The applicant shall provide a test report demonstrating the calculation of the efficiency in spraying rate. The report shall
include the initial aerosol spray can weight, a plot of discharge rate versus time and the weight of the spray can at the end
of the test. The total weight of product discharged shall be considered as the difference between the initial weight and the
final weight of the can.
2(c) Adhesion
Note 1: This requirement does not apply to any aerosol products that are designed to apply transparent or semi-
transparent coatings.
Aerosol spray paint shall achieve an adhesion score of 2 or less in the test for adhesion in relevant European or international
standards.
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Assessment and verification:
The applicant shall provide a declaration of compliance with the relevant requirement or a justification of the non-
applicability of the requirements for each of the products covered by the EU Ecolabel application. The declaration shall be
supported by test results according to the method in relevant European or international standards, as applicable.
2(d) Corrosion resistance
Aerosol spray paint, when applied to blasted steel panels with a dry film thickness of at least 60μm, shall ensure adequate
corrosion resistance after being subjected to a salt spray test of 240 hours duration according to relevant European or
international standards.
After exposure, the coating shall meet the following criteria:
— A rating of 3 or better (i.e. 0, 1 or 2) for size of blisters according to relevant European or international standards.
— A rating of 3 or better (i.e. 0, 1 or 2) for quantity of blisters according to relevant European or international standards.
— A rating of Ri2 or better (i.e. Ri0 or Ri1) for degree of rusting according to relevant European or international
standards.
— A delamination result of 4mm or less according to relevant European or international standards.
— An adhesion score of 2 or less according to relevant European or international standards.
Assessment and verification:
The applicant shall provide a declaration of compliance supported by test results according to relevant European or
international standards for salt spray test, for rust, for blistering, for delamination and adhesion
2(e) Weathering
Aerosol spray paint, when applied to blasted steel panels with a dry film thickness of at least 60μm, shall ensure adequate
weathering resistance after being subjected to 500 hours of weathering cycles according to relevant European or
international standards.
After exposure, the coating shall meet the following criteria according to relevant European or international standards:
— Colour change of ΔΕ ≤ 4.
— Decrease of gloss of ≤ 30 %.
— Degree of flaking of ≤ 2 in terms of flake density and ≤ 2 in terms of flake size.
— Degree of blistering of ≤ 3 in terms of blister density and ≤ 3 in terms of blister size.
— Degree of cracking of ≤ 2 in terms of crack size.
Assessment and verification:
The applicant shall provide a declaration of compliance supported by test results of coated substrates before and after the
weathering exposure according to relevant European or international standards: for colour deviation; for gloss level
deviation; for degree of flaking; for degree of cracking, and for degree of blistering.
Criterion 3. Content of Volatile and Semi-volatile Organic Compounds (VOCs, SVOCs)
The maximum VOC content permitted in aerosol spray paints shall not exceed the limits defined in Table 2. The VOC
content shall be determined separately for each component and then added together.
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The VOC content for the liquid paint component shall first be determined either by calculation based on the ingredients and
raw materials or by using the methods given in relevant European or international standards. Then the VOC content for the
paint component (in g/l liquid paint) shall be converted to units of g/l of ready to use product by multiplying by the aerosol
spray paint volume ratio, defined as:
X Litres of liquid paint
Aerosol spray paint volume ratio¼
Y Litres of declared aerosol spray can volume
Unless otherwise demonstrated, the propellant, whether it is an individual substance or mixture, shall be assumed to be
100 % VOC. The amount of propellant VOC in the ready to use product shall be calculated based on a declared propellant
content (in units of g propellant/l volume of the aerosol can). The mass of propellant added per litre of aerosol shall be
calculated by the manufacturer.
Table 2
VOC content limit
VOC content limits(1)
Liquid paint component Propellant Final product
VOC limits (expressed in terms of g/l of aerosol)
60 g/l 290 g/l 350 g/l
(1) ‘Volatile organic compounds (VOCs)’ means any organic compounds having an initial boiling point less than or equal to 250 °C
measured at a standard pressure of 101,3 kPa
Assessment and verification:
The applicant shall provide a declaration of compliance supported by calculations of VOC content.
For the liquid paint component, the declaration of compliance shall be supported by calculations of VOC content based on
the ingredients and raw materials used in the liquid paint component. Alternatively, the VOC content of the liquid paint
component shall be communicated via a representative test report or reports using the methods given in relevant
European or international standards and results, when corrected for the water-based aerosol spray paint volume ratio, shall
demonstrate compliance with the limit.
For the propellant component, the applicant shall declare the propellant(s) used and provide details of the calculation.
Criterion 4. Restriction of hazardous substances and mixtures
Note: These sub-criteria apply to the final product formulation and any supplied ingredients therein.
4.1. Restrictions on Substances of Very High Concern (SVHCs)
The final product formulation and any supplied ingredients therein shall not contain any ingoing substances that meet the
criteria referred to in Article 57 of Regulation (EC) No 1907/2006 that have been identified according to the procedure
described in Article 59 of that Regulation and included in the candidate list for substances of very high concern for
authorisation.
Assessment and verification:
The applicant shall provide a signed declaration that the final product formulation and any supplied ingredients therein do
not contain any SVHCs as ingoing substances. The applicant declaration shall be supported by safety data sheets of all
supplied ingredients used to produce the final product and declarations from the chemical suppliers.
The list of substances identified as SVHCs and included in the candidate list in accordance with Article 59 of Regulation
(EC) No 1907/2006 can be found here:
https://www.echa.europa.eu/candidate-list-table
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Reference to the list shall be made on the submission date of the EU Ecolabel application.
For any level of known impurities identified as SVHCs in ingredients, the concentration of the impurity and an assumed
retention factor of 100 % shall be used to estimate the quantity of the SVHC impurity remaining in the final product
formulation. Impurities that are SVHCs cannot be present in the paint or varnish product formulation above 0,0100 % w/
w or in any individual ingredient in concentrations exceeding 0,100 % w/w. Any deviation from a retention factor of 100 %
for an SVHC impurity (for example due to solvent evaporation) or in case of chemical modification, must be supported by
adequate justifications.
4.2. General restrictions based on classifications according to specific hazard classifications defined in
Regulation (EC) No 1272/2008.
(a) Final product formulation
The final product formulation shall not be classified as being carcinogenic, mutagenic, toxic for reproduction, acutely toxic,
an aspiration hazard, a specific target organ toxicant, a respiratory or skin sensitiser, hazardous to the aquatic environment,
hazardous to the ozone layer, an endocrine disruptor, persistent, bioaccumulative and toxic (PBT) or persistent, mobile and
toxic (PMT) in accordance with Regulation (EC) No 1272/2008 and specifically in terms of the hazard statement codes
stated in Table 3. The only exception permitted to this rule shall be the H412 and H413 classification, and only if due to
levels of dry-film preservatives in the case of outdoor paints or varnishes.
(b) Ingoing substances
Unless derogated in Table 4, the final product formulation shall not contain any ingoing substances in concentrations at or
above 0,010 % weight by weight of the final product formulation that are classified, in accordance with Regulation (EC)
No 1272/2008, with any of the hazard classes, categories and associated hazard statement codes stated in Table 3.
Table 3
Restricted hazard classes, categories and associated hazard statement codes
Carcinogenic, mutagenic or toxic for reproduction (CMR)
Categories 1A and 1B Category 2
H340: May cause genetic defects H341: Suspected of causing genetic defects
H350: May cause cancer H351: Suspected of causing cancer
H350i: May cause cancer by inhalation
H360: May damage fertility or the unborn child H361: Suspected of damaging fertility or the unborn child
H360F: May damage fertility H361f: Suspected of damaging fertility
H360D: May damage the unborn child H361d: Suspected of damaging the unborn child
H360FD: May damage fertility. May damage the unborn H361fd: Suspected of damaging fertility. Suspected of
child damaging the unborn child
H360Fd: May damage fertility. Suspected of damaging the H362: May cause harm to breast fed children
unborn child.
H360Df: May damage the unborn child. Suspected of
damaging fertility.
Acute toxicity
Categories 1 and 2 Category 3
H300: Fatal if swallowed H301: Toxic if swallowed
H310: Fatal in contact with skin H311: Toxic in contact with skin
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Carcinogenic, mutagenic or toxic for reproduction (CMR)
Categories 1A and 1B Category 2
H330: Fatal if inhaled H331: Toxic if inhaled
EUH070: Toxic by eye contact
Aspiration hazard
Category 1
H304: May be fatal if swallowed and enters airways
Specific target organ toxicity
Category 1 Category 2
H370: Causes damage to organs H371: May cause damage to organs
H372: Causes damage to organs through prolonged or H373: May cause damage to organs through prolonged or
repeated exposure repeated exposure
Respiratory and skin sensitization
Category 1, 1A and 1B
H317: May cause an allergic skin reaction
H334: May cause allergy or asthma symptoms or breathing
difficulties if inhaled
Hazardous to the aquatic environment
Categories 1 and 2 Categories 3 and 4
H400: Very toxic to aquatic life H412: Harmful to aquatic life with long-lasting effects
H410: Very toxic to aquatic life with long-lasting effects H413: May cause long-lasting effects to aquatic life
H411: Toxic to aquatic life with long-lasting effects
Hazardous to the ozone layer
H420: Harms public health and the environment by
destroying ozone in the upper atmosphere
Endocrine disruptors (EDs) for human health and the environment
Category 1 Category 2
EUH380: May cause endocrine disruption in humans EUH381: Suspected of causing endocrine disruption in
humans
EUH430: May cause endocrine disruption in the EUH431: Suspected of causing endocrine disruption in the
environment environment.
Persistent, Bioaccumulative and Toxic (PBT)
PBT very Persistent and very Bioaccumulative (vPvB)
EUH440: Accumulates in the environment and living EUH441: Strongly accumulates in the environment and
organisms including in humans living organisms including in humans
Persistent, Mobile and Toxic (PMT)
PMT very Persistent and very Mobile (vPvM)
EUH450: Can cause long-lasting and diffuse contamination EUH451: Can cause very long-lasting and diffuse
of water resources contamination of water resources
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The use of substances that are chemically modified during the production process, so that any relevant hazard for which the
substance has been classified under Regulation (EC) No 1272/2008 no longer applies, shall be exempted from the above
requirement.
This criterion shall not apply to ingoing substances covered by points (a) and (b) of Article 2(7) of Regulation (EC)
No 1907/2006, which set out criteria for exempting substances within Annexes IV and V to that Regulation from the
registration, downstream user and evaluation requirements.
Table 4
Derogations to restrictions on ingoing substances that are classified with one or more of the restricted hazards
listed in Table 3 and are present in concentrations at or above 0,010 % (weight by weight) of the final product
formulation
Substance type, substance Derogated hazard
Derogation conditions
name and CAS number code(s)
Preservatives and preservative stabilisers
Note on preservatives: all preservatives: added to ingredients must be declared by suppliers and all preservatives added
directly to the final product formulation must be declared by the paint or varnish producer. The only types of
preservatives permitted in ingredients and the final product shall be those that are compliant with Regulation (EU)
No 528/2012. For final products originating in the Union, it is reminded that it is not sufficient that the active substances
contained in the preservative product are approved under Regulation (EU) No 528/2012 for product type 6 (PT6) (in-can
preservative) or for product type 7 (PT7) (dry-film preservative), but the preservative product must be authorised under
Regulation (EU) No 528/2012 for PT6 or PT7 or made available on the market according to the transitional measures set
out in Article 89(2) of that Regulation. The combined total limits for PT6 and PT7 preservatives shall apply to these
following product categories:
— For indoor products: up to 0,080 % weight by weight of PT6 in the final product.
— For colour tints used in tinting systems: up to 0,20 % weight by weight of PT6 in the colour tint.
— For indoor products marketed for use in high humidity areas: up to 0,080 % weight by weight of PT6 and up to 0,10 %
weight by weight of PT7 in the final product.
— For outdoor products: up to 0,080 % weight by weight of PT6 and up to 0,50 % weight by weight of PT7 in the final
product.
Except for colour tints, all references to concentrations/limits/levels of preservatives in the section ‘Preservatives and
preservative stabilisers’, shall be understood as referring to the preservative active substances contained in the final product
formulation.
Any preservatives which cannot be present in the final product formulation at concentrations exceeding 0,010 %, due to
specific concentration limits (SCLs) lower than 0,010 % that would classify the final product with a restricted CLP hazard,
are not mentioned in the derogation table below because they cannot be used in concentrations exceeding 0,010 % in the
first place and thus do not need a derogation. This does not imply that they cannot be used as ingoing substances in EU
Ecolabel products at any level. If not explicitly excluded in sub-criterion 4.3, such preservatives may be used so long as it is
at levels below any SCLs that would trigger a restricted CLP classification of the final product formulation.
In-can preservatives (PT6) in H301, H311, (*)See horizontal derogation condition at foot of table
colour tints or final H317, H330, The sum total of all PT6 in-can preservatives (those derogated for use
product: H331, H372, above 0,010 % and those that are non-derogated but allowed in levels
H373, H400, < 0,010 %) must be within the relevant limits defined in the note
H410, H411, above.
H412, H413 When preservatives that are formaldehyde donors are used, the
relevant limits for free formaldehyde in the final product set out in
sub-criterion 4.3(l) must be respected.
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Substance type, substance Derogated hazard
Derogation conditions
name and CAS number code(s)
Specific concentration limits (% weight by weight in the final product)
shall apply for the derogated substances listed below:
— Bronopol(CAS No 52-51-7): up to 0,030 %.
— DBNPA(CAS No 10222-01-2): up to 0,030 %
— Sodium pyrithione(CAS No 3811-73-2): up to 0,030 %.
— BIT(CAS No 2634-33-5): up to 0,036 %.
— Combined total isothiazolinones and isothiazolinone releasers
(those derogated for use above 0,010 % and those that are non-
derogated but allowed in levels < 0,010 %): up to 0,040 % in final
product formulations.
— Diamine(CAS No 2372-82-9): up to 0,050 %.
Dry-film preservatives H311, H317, (*)See horizontal derogation condition at foot of table
(PT7): H330, H331, Only applies to outdoor products and indoor products for use in high
H372, H373 humidity areas.
H400, H410, The sum total of all PT7 dry-film preservatives (those derogated for
H411, H412 and use above 0,010 % and those that are non-derogated but allowed in
H413 levels < 0,010 %) must be within the relevant limits defined in the
note above.
In the case of slow release, encapsulated forms of dry-film
preservatives, the specific classification of the final product, or read-
across formulations, should consider the absolute concentration of
the hazardous components (i.e. without capsules). The final product
or read-across formulation cannot be classified with any of the
hazards listed in Table 3.
Any dry-film preservatives classified as H400 or H410 must be non-
bioaccumulative, demonstrated by having an octanol-water
coefficient (Log Kow) of ≤ 3,2 or a bioconcentration factor (BCF) of
≤ 100.
Preservative stabiliser: H400, H410 (*)See horizontal derogation condition at foot of table
Zinc oxide (CAS Permitted to be used as a preservative stabiliser, up to 0,040 % weight
No 1314-13-2) by weight of the final product, when used to stabilise in-can or dry-
film preservative combinations that require 1,2-Benzisothiazol-
3(2H)-one (BIT).
Drying and anti-skinning agents
Anti-skinning agents H317, H411, (*)See horizontal derogation condition at foot of table
H412, H413 The sum total anti-skinning agent content shall not exceed 0,40 %
weight by weight in the final product.
Driers (siccatives) H301, H317, (*)See horizontal derogation condition at foot of table
H373, H400†, The sum total drier content shall not exceed 0,10 % weight by weight
H410†, H411, in the final product.
H412, H413 † The derogation for H400, H410 and H411 only applies to cobalt-
based drier compounds or neodecanoic acids and such compounds
can only be used up to 0,050 % weight by weight in the final product.
Pigments and anti-corrosion additives
Anti-corrosion pigments/ H400, H410 (*)See horizontal derogation condition at foot of table
additives Only permitted up to 0,050 % weight by weight in the final product
and only for tri-zinc bis(orthophosphate (CAS No 7779-90-0).
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Substance type, substance Derogated hazard
Derogation conditions
name and CAS number code(s)
Trimethylolpropane H361fd (*)See horizontal derogation condition at foot of table
Only when used as an additive in supplied pigments and only up to
0,50 % weight by weight in the supplied pigment.
Binders and polymer dispersions
Binders and crosslinking H317, H411 (*)See horizontal derogation condition at foot of table
agents: Only allowed up to 1,0 % weight by weight in the binder or polymer
Adipic acid dihydrazide dispersion ingredient and when used as an adhesion promoter or as a
(CAS No 1071-93-8) crosslinking agent.
Unreacted monomers (in H301, H304, (*)See horizontal derogation condition at foot of table
binders) H311, H317, The sum total concentration of unreacted monomers needing this
H331, H334, derogation shall not exceed 0,050 % weight by weight in the final
H372, H400, product.
H410, H411,
H412
Other, miscellaneous
Methanol (CAS H301, H311, (*)See horizontal derogation condition at foot of table
No 67-56-1) H331, H370 Only permitted as a residual reaction product of other substances in
the product formulation. Allowable residual concentration increases
as a function of binder content in the following manner:
— Binder content of 10-20 %: allowable residual methanol is 0,020 %
weight by weight in the final product.
— Binder content of 20-40 %: allowable residual methanol is 0,030 %
weight by weight in the final product.
— Binder content of > 40 %: allowable residual methanol is 0,050 %
weight by weight in the final product.
Mineral raw materials, H372, H373 (*)See horizontal derogation condition at foot of table
including fillers, anti- Only applies to mineral raw materials and leucophyllite minerals that
sagging agents and matting naturally contain crystalline silica.
agents Only permitted in contents up to 1,0 % weight by weight in the final
product formulation for H372 materials or up to 10 % for H373
materials.
In cases where the material is supplied in dry powder form, the
applicant shall demonstrate that they have systems in place to
minimise worker exposure to dry powder in the workplace (for
example closed dosing systems, ventilated dosing and mixing areas
and personal protective equipment).
Neutralising agents H301, H311, (*)See horizontal derogation condition at foot of table
H331, H400, Only allowed up to 1,0 % weight by weight in varnish formulations,
H410, H411, and up to 0,50 % in all other products.
H412, H413
Optical brighteners H413 (*)See horizontal derogation condition at foot of table
Only allowed up to 0,10 % weight by weight in the final product
formulation.
Silicon resin H412, H413 (*)See horizontal derogation condition at foot of table
Only allowed up to 2,0 % weight by weight in the final product
formulation.
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Substance type, substance Derogated hazard
Derogation conditions
name and CAS number code(s)
Solvents H304 (*)See horizontal derogation condition at foot of table
Only allowed up to 2,0 % weight by weight in the final product
formulation.
Surfactants H304, H400, (*)See horizontal derogation condition at foot of table
H411, H412, Only allowed up to 1,0 % weight by weight in transparent, semi-
H413 transparent, white or light-coloured product formulations or up to
3,0 % weight by weight in all other colours
UV stabilisers H317, H411, (*)See horizontal derogation condition at foot of table
H412, H413 Only applicable to outdoor products and only up to 0,60 % weight
by weight in the final product formulation.
(*) Horizontal derogation condition: none of the derogations above, either individually or in combination, shall be permitted if they
result in the final product being classified with any of the hazards defined in Table 3, with the notable exception of H412 and H413
for outdoor products due to the presence of dry-film preservatives.
Assessment and verification:
The applicant shall provide a signed declaration of compliance with sub-criterion 4.2, including compliance with any
relevant derogation conditions, supported by declarations from suppliers and any other relevant documentation.
A list of all ingoing substances with one or more of the restricted CLP hazards calculated to be present in the final product
formulation in concentrations greater than 0,010 % weight by weight shall be presented, together with their CAS numbers,
CLP classification status (i.e. harmonised, joint entry or self-entries only) the relevant function of the ingoing substance (for
example in-can preservative, drier, pigment, neutralising agents, surfactants, UV stabiliser etc.)., Calculations for ingoing
substance concentrations in the final product formulation shall be based on:
— a list of all ingredients, chemicals or raw materials used to make the final product formulation,
— the screening of ingredients, chemicals or raw materials for those ingoing substances and known impurities with any
of the EU Ecolabel-restricted CLP hazards,
— the concentrations of any screened ingoing substances and known impurities with EU Ecolabel-restricted CLP hazards
in the ingredients, chemicals or raw materials used, in the format supplied.
— the weight of each of the ingredients, chemicals or raw materials added to make a known weight of final product
formulation.
Known impurities shall be treated as ingoing substances only if the screening exercise reveals that their content in the final
product formulation shall exceed 0,010 % weight by weight or their content in an ingredient shall exceed 0,100 % weight
by weight. Known impurities below these thresholds shall not be counted in calculations.
Any screened ingoing substances shall be assumed by default to be 100 % retained in the final product. Justifications for any
deviation from a retention factor of 100 % during processing (for example solvent evaporation) or for chemical
modification of a screened ingoing substance shall be provided. Substances known to be released or to degrade from
ingoing substances are considered ingoing substances and not impurities.
For any screened ingoing substances remaining in the final product formulation in concentrations greater than 0,010 %
weight by weight, but which are exempted from sub-criterion 4.2 (see Annexes IV and V to Regulation (EC)
No 1907/2006), a declaration to this effect by the applicant shall suffice for those substances.
Since multiple products or potential products (for example customised shades from a tinting system) using the same
ingredients, chemicals or raw materials may be covered by one EU Ecolabel license, a worst-case calculation may be
acceptable for each screened ingoing substance within a common family of products covered by the same license.
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Regarding information requested from suppliers that may be commercially sensitive, evidence from suppliers can also be
provided directly to competent bodies without necessarily providing certain details to the applicant.
4.3. Specific hazardous substance restrictions for ingoing substances.
Unless derogated in sub-criterion 4.2, the substances indicated below shall not be included as ingoing substances in the final
product formulation or as ingoing substances to the ingredients used to make the final product formulation:
(a) Preservatives or driers classified as carcinogenic, mutagenic or toxic for reproduction.
(b) Substances classified as category 1 or category 2 endocrine disruption for human health or the environment in
accordance with CLP Regulation (EC) 1272/2008, substances included in the candidate list referred to in
Article 59(1) of REACH Regulation (EC) 1907/2006 as having endocrine-disrupting properties for human health or
the environment, substances identified as having endocrine-disrupting properties in accordance with Regulation
(EU) No 528/2012 or Regulation (EC) No 1107/2009, except for DBNPA (CAS No 10222-01-2) when used as an
in-can preservative.
(c) Substances classified as Persistent, Bioaccumulative and Toxic (PBT) or very Persistent and very Bioaccumulative
(vPvB) for the environment and living organisms including in humans in accordance with CLP Regulation
(EC) 1272/2008, substances included in the candidate list referred to in Article 59(1) of REACH Regulation
(EC) 1907/2006 as having PBT or vPvB properties for the environment and living organisms including in humans,
substances identified as having PBT or vPvB properties for the environment and living organisms including in
humans in accordance with Regulation (EU) No 528/2012 or Regulation (EC) No 1107/2009.
(d) Substances classified as Persistent, Mobile and Toxic (PMT) or very Persistent and very Mobile (vPvM) in accordance
with CLP Regulation (EC) 1272/2008, substances included in the candidate list referred to in Article 59(1) of REACH
Regulation (EC) 1907/2006 as having PMT or vPvM properties.
(e) Alkylphenols, alkylphenol ethoxylates (APEOs) and their derivatives, as referred to in entry 43 to Annex XIV or entry
46 to Annex XVII of the Regulation (EC) 1907/2006.
(f) Perfluorinated and polyfluorinated compounds (PFAS), as defined in Article 4(42).
(g) Phthalates.
(h) Organotin compounds.
(i) Fragrance substances which are prohibited or restricted in cosmetic products and listed in Annexes II or III to
Regulation (EC) No 1223/2009.
(j) Bisphenols that have been identified by ECHA in their 2021 ‘Assessment of Regulatory Needs report on Bisphenols’
for further EU regulatory risk management that are known or potential endocrine disruptors for the environment or
for human health, or that can be identified as toxic for reproduction.
(k) Pigments used shall not be based on Cadmium, Lead, Chromium (VI), Mercury, Arsenic, Selenium, Antimony or
Cobalt. The following impurities from any pigments used shall not be present in the final product formulation in
quantities exceeding 0,010 % weight by weight (per metal): Cadmium, Lead, Chromium (VI), Mercury, Arsenic,
Selenium, Antimony and Cobalt. The only exceptions to pigment use and to the 0,010 % limit for impurities shall be:
— Cobalt: due to the use of Cobalt aluminate blue spinel (CAS No 1345-16-0) and Cobalt chromite blue-green
spinel (CAS No 68187-11-1) pigments.
— Antimony: due to the use of pigments based on Antimony Nickel within an insoluble TiO lattice.
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(l) Free formaldehyde shall not be intentionally added to the final product formulation. The final product shall be tested
in order to determine its free formaldehyde content. Worst-case samples for testing shall be selected for each family of
products based on which product is predicted to have the highest theoretical amount of formaldehyde content. Under
the conditions defined below, the following sum total limits of free formaldehyde shall be permitted:
— Up to 0,0010 % weight by weight permitted when bronopol or preservatives that are formaldehyde donors are
required as an in-can preservative to protect a specific type of paint or varnish
— Up to 0,010 % weight by weight permitted when polymer dispersions (binders) provide, through residual levels
of formaldehyde, the function of formaldehyde donors instead of in-can preservatives.
— Up to 0,010 % when both conditions listed above apply in the same product.
(m) Synthetic polymer microparticles (SPMs, commonly known as microplastics) as defined in entry 78 of Annex XVII to
Regulation (EC) No 1907/2006 (REACH), shall not be used for non-film forming purposes in any product
formulation unless their use and purpose is explicitly declared, together with a justification of why their use
improves the overall environmental performance of the paint or varnish product.
(n) TiO nanoform, as defined in Article 4(52), shall not be used as an ingredient for any purpose in aerosol products.
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Assessment and verification:
(a to j) The applicant shall declare the non-use of the relevant substances indicated in this sub-criterion, namely CMR
preservatives, CMR driers, endocrine disruptors (except DBNPA), PBT and vPVB substances, PMT and vPvM
substances, alkylphenols and APEOs, PFAS, phthalates, organotin compounds, fragrances and bisphenols as
ingoing substances in their formulation, supported by declarations from their suppliers about the non-use of
the same hazardous substance groups as ingoing substances in the ingredients supplied and that are used in
formulations covered by the EU Ecolabel license application procedure.
(k) In the case of the heavy metal restrictions from pigments, the applicant or pigment supplier shall provide a
declaration stating that neither the pigment itself nor any ingoing substances that may be incorporated into
the pigment product are based on the listed heavy metals. The applicant or pigment supplier shall also provide
a test report with the heavy metal impurity levels of representative samples of the pigment supplied. The
applicant shall then use these results, together with the % of pigment(s) used in the final product, to calculate
the concentration of heavy metals from pigments remaining in the final product. In the case of exempted
pigments, the pigment supplier shall declare which pigment(s) have the exemption (i.e. cobalt aluminate blue
spinel, cobalt chromite blue-green spinel or antimony nickel in an insoluble TiO lattice).
2
(l) The applicant shall declare which of their products should have the highest theoretical free formaldehyde
content within each family of products’ formulation. This declaration shall be based on the choice of the paint
formulator to use formaldehyde donors as in-can preservatives and declarations from suppliers regarding the
amounts of formaldehyde donors used to preserve supplied ingredients (especially binders). The addition of
these substances (and any other ingredients that release formaldehyde) to the worst-case formulations shall not
result in the content of free formaldehyde in the final product exceeding the relevant concentration limit, as
measured with relevant European or international standards.
(m) The applicant shall provide either a declaration of the non-use of SPMs for non-film forming purposes or a
declaration of their use in the product formulation. In cases where the use of SPMs for non-film forming
purposes is declared, the type, quantity (% weight by weight) and purpose shall be stated in the declaration,
together with a justification of how the use of SPMs for non-film forming purposes improves the overall
environmental performance of the product. Such justifications should normally compare the environmental
performance of the same product with and without the SPMs for non-film forming purposes.
(n) The applicant shall provide a declaration of the non-use of TiO nanoform pigments, supported by declarations
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from their pigment supplier(s).
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Criterion 5. Consumer information
5(a) The following information shall appear on or be attached to the packaging:
— Recommendation to minimise paint wastage by estimating how much paint is needed before purchase,
— How to estimate the amount of paint needed prior to purchase in order to minimise paint wastage and a
recommended amount as a guideline (for example for 1 m2of wall, X litres of paint is needed),
— Safety measures for the user including basic recommendation on personal protective equipment that should
be worn and additional measures that should be taken when using the product,
— Recommendation to use the product outdoors or in a ventilated environment,
— Information requested in sub-criterion 5(b) or explanation of how to access such information.
5(b) The following information shall appear on or be attached to the packaging or be available via a web-link or QR code:
— Appropriate storage conditions of the product (before and after opening), including, where appropriate, safety
advice,
— Appropriate waste management of the ‘leftover paint’ and packaging (in order to limit water and soil
pollution). For example, text advising that unused paint requires specialist handling for safe environmental
disposal and therefore it should not be thrown away with household or commercial waste.
Assessment and verification:
The applicant shall declare that the product complies with the requirement and provide the competent body with the
artwork or samples of the user information and/or a link or QR code to a manufacturer’s website containing this
information as part of the application. The recommended amount of paint given as a guideline shall be provided.
Criterion 6. Information appearing on the EU Ecolabel
The optional label with text box shall contain three of the following statements, according to their relevance:
— Minimised content of hazardous substances,
— Reduced content of volatile organic compounds (VOCs): x g/l,
— Good performance for indoor use (for indoor products), or
— Good performance for outdoor use (for outdoor products), or
— Good performance for both indoor and outdoor use (for products suitable for indoor and outdoor use).
The guidelines for the use of the optional label with text box can be found in the ‘Guidelines for use of the Ecolabel logo’ on
the website:
http://ec.europa.eu/environment/ecolabel/documents/logo_guidelines.pdf
Assessment and verification:
The applicant shall provide a sample of the product label or an artwork of the packaging where the EU Ecolabel is placed,
together with a declaration of compliance with this criterion.
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