Environmental Project, 1109 – The EU Eco-label and Health – Annex 6 Theoretical proposal for amendments to criteria for paints and varnishes to improve health coverage

The EU Eco-label and Health

Annex 6 Theoretical proposal for amendments to criteria for paints and varnishes to improve health coverage

This annex contain a theoretical exercise with the aim to illustrate how the criteria for paints and varnishes may be supplemented to cover health aspects.

The existing criteria regarding chemicals in indoor paints and varnishes are supplemented with requirements regarding health aspects as outlined below..

Ingredients/ classification	Criteria Requirements
Ingredients/ classification	Existing criteria	Supplementary Health aspects
Toxicity class. R23 – R28	Ban or ≤ 0.1% for preservatives	Ban or ≤ 0.1% for preservatives
Health hazard R20 – R22	-	≤ 25%
CMR	Ban for categories 1 and 2 (minus R49)	Ban for categories 1 and 2, ≤ 0.1% for category 3
Prolonged exposure R39, R48	Ban or ≤ 0.1% for preservatives	Ban or ≤ 0.1% for preservatives
Heavy metals	Traces from raw materials for Cd, Pb, Hg, Cr(VI) and As are allowed	≤ 50 ppm for Cd, Pb, Cr(VI), Hg and As, ≤ 100 ppm for Zn, Cr(III), Ni, Co, Mn, V, Mb, Cu
Allergens R42, R43	-	≤ 0.01% corresponding to the classification limit
VOC’s	Limit values for VOC’s w. bp ≤ 250^oC	Limit value for VOC’s w. bp ≤ 280^oC
Corrosive and irritating subst. R34 – R38, R41	-	Possible declaration demand

Very toxic and toxic substances:

Toxic and very toxic substances are completely banned in the present set of criteria unless they are preservatives for which there is an allowed content of up to 0.1 %. This demand is more stringent than the limit for classification in the hazard class ”Harmful”, which is 3 % for substances classified in hazard class ”Toxic” and 1 % for substances classified in hazard class ”Very toxic”, respectively. Formaldehyde classified as T;R23/24/25 C;R34 Carc3;R40 R43 has a limit of 0.001 % for free formaldehyde. The requirements of the existing criteria thus cover health in an appropriate way.

Health hazardous substances:

There are no demands for the content of health hazardous substances in the existing criteria. A limit of max 25 % is suggested which is the limit for a classification of the product as health hazardous. The consequence of this will be that products classified as health hazardous to health cannot obtain the Eco-label.

CMR-substances:

Except for substances classified with R49 (”May cause cancer by inhalation”), the present criteria contain bans on content of CMR substances in categories 1 and 2. It is suggested that the ban is supplemented by a ban on substances classified with R49 and a limit of 0.1% for substances in category 3. The demand for formaldehyde, which is Carc3, is already lower than this limit and will therefore not be in conflict with this new demand.

Effects from prolonged use (R39, R48):

The same demands are made for content of toxic and very toxic substances. The requirements of the existing criteria thus cover health in an appropriate way.

Heavy metals:

Cadmium (Cd), lead (Pb), chromium IV (Cr(VI)), mercury (Hg) and arsenic (As) may not be used as ingredients in the product – neither as substances nor as part of a preparation according to the present criteria. However, there is no ban on trace amounts of the metals in the raw materials. It is suggested that this is specified through a ban on occurrence of Hg and Cd above the detection limit as well as a maximum limit value of 50 ppm for Pb, As and Cr(VI) for the content in the raw materials in the same way as is demanded for the Dutch eco-label.

It is suggested that the demand be extended to cover zinc (Zn), chromium III (Cr(III)), nickel (Ni), cobalt (Co), manganese (Mn), vanadium (V), molybdenum (Mb) and copper (Cu) and a limit of maximum 100 ppm is suggested. The heavy metals mentioned are used in pigments and siccatives. The suggestion may be problematic with regard to siccatives as they often contain Co.

Allergenic effects (R42 and R43):

The present criteria do not include requirements regarding the content of allergenic substances except for regulations on content of isothazolinons, which are known allergens, and used as preservatives. For the combined content of isotiazolinons, a limit of 500 ppm (0.05 %) has been established as the content of kathon (a mixture of 5-chlor-2-methyl-2H-isothiazol-3-on and 2-methyl-2H-isothiazol-3-on in the ration 3:1) may not at the same time exceed 15 ppm. Instead of isothiazolinons it is possible to use sodium benzoate or parabens as preservative. As an example, methylparaben – E218 – is used in natural paint.

It is suggested that the criteria be supplemented by a general demand that the product may not contain more than 1 % of substances classified with R43.

Volatile substances (VOC’s):

In the present criteria, VOC’s are defined as all organic compounds with a boiling point of < 250^oC. It is suggested that this limit be raised to 280^oC in order to include the glycol ether Texanol in the criteria. Natural paint contains no VOC’s as linseed oil has a boiling point above 316^oC.

A number of fragrances will be included in this criteria, as they are volatile but they are probably not added in the same amounts.

Corrosive and irritating substances (R35, R34; R38, R41):

The content of corrosive and irritating substances are not regulated in the existing criteria. Some preservatives such as aldehydes, nonylphenoles and a number of solvents such as toluene, xylene and some glycol ethers are irritating. It is difficult to evaluate whether it is possible to manufacture a paint with these requirements unless most is replaced by linseed oil as in natural paint.