The latest trends in tightening regulations on VOC content in products such as paints and inks in China.
1. Recently promulgated 7 new VOC national standards and their background
In China, in order to promote the implementation of the “Three-Year Action Plan to Win the Blue Sky Defense Battle”, in 2019, “Technical Requirements for Low VOC Content Paint Products” (draft), “Emission Standards for Air Pollutants in the Pharmaceutical Industry” , “Emission standards for Air Pollutants in the Paint, Ink, and Adhesive Industries” have been promulgated.
In addition, the following nine (9) national standards have been established for each industry to regulate the VOC content of various products, the upper limit of special volatile hazardous substances, test methods, calculation methods, and exempted substances and prohibited substances. Then, on October 16, 2019, China notified them to WTO.
- Restricted amount of harmful substances in vehicle paint
- Restricted amount of harmful substances in wood product paint
- Restricted amount of harmful substances in building wall paint
- Restricted amount of harmful substances in industrial protective paints
- -Limited amount of volatile organic compounds (VOC) in adhesives
- -Limited value of volatile organic compound (VOC) content in ink
- -Limited value of volatile organic compound (VOC) content in cleaning agent
- Limited amount of harmful substances in marine paint
- Limit amount of harmful substances in paint for interior floors
Among them, “Restricted amount of harmful substances in paints for ships” and “Restricted amount of harmful substances in paints for interior floors” were finally promulgated on December 31, 2019 and came into effect on July 1, 2020.
2. Basic information
The remaining seven national standards for limiting the amount of harmful substances such as VOCs contained in these products were promulgated by the China National Standards Committee on March 4, 2020. This means that all of the above-mentioned nine VOC standards notified to WTO in 2019 have been promulgated.
All seven GBs promulgated this time (in 2020) are mandatory national standards, so companies must take measures.
The contents and limits to be regulated are different depending on the usage of individual products, but the target of these regulations is not limited to production companies in China; however, all companies related to these VOC substances will be covered, and also it is considered that the control of the VOC substances will be stricter in the future.
The individual names and enforcement dates of the seven standard are as follows.
| Standard code | Standard name (English) | Enforcement date |
|---|---|---|
| GB 24409-2020 | Limits on Hazardous Substances Content in Vehicle Paints | December 1, 2020 |
| GB 18581-2020 | Limits on Hazardous Substances Content in Wood Paints | December 1, 2020 |
| GB 18582-2020 | Limits on Hazardous Substances Content in Architectural Wall Paint | December 1, 2020 |
| GB 30981-2020 | Limits on Hazardous Substances Content in Industrial Protective Paints | December 1, 2020 |
| GB 33372-2020 | Limits on Volatile Organic Compound (VOC) Content for Adhesive | December 1, 2020 |
| GB 38507-2020 | Limits on Volatile Organic Compound (VOC) Content in Ink | April 1, 2021 |
| GB 38508-2020 | Limits on Volatile Organic Compound (VOC) Content in Cleaning Agents | December 1, 2020 |
3. What companies should do
After the promulgation of the seven GBs this time, much more attention has been paid to VOC measures. In particular, the newly promulgated “limit value of volatile organic compound (VOC) content in ink” and “limit value of volatile organic compound (VOC) content in cleaning agent”.
The Chinese authorities have not yet published a clear commentary on what companies must prepare for the enforcement of the standards, but official documents concerned indicate definitely that the regulatory agents regard seriously these VOC standards as key regulations for the producers to comply with.
Indeed, the Chinese government has suggested a policy of strictly limiting the VOC content of products further in the future and encouraging the use of raw materials and auxiliary materials with low VOC content.
On June 25, 2020, the Ministry of Ecology and Environment promulgated a notice on the Ministry’s website regarding the “2020 Volatile Organic Compounds (VOC Substances) Management and Control Plan”. The notice is placing focus primarily on VOC emissions, but also referring to the content of hazardous substances.
Among them, the key points for companies to pay attention are as follows;
(1) Things to prepare for the enforcement of the new standards
- All of these seven standards are enforced national standards, so companies must comply with them. They must develop in advance the products that meet the limits of hazardous substances content contained therein for such products as printing inks, adhesives, cleaning agents, wood, vehicles, building exterior walls, and industrial protective paints, and complete switching to compliant products in order before the standards officially come into force.
- Companies should prepare the ledger for raw materials and auxiliary materials, record information such as names of VOC raw material/auxiliary material, ingredients, VOC content, purchase amount, usage amount, inventory amount, collection method, collection amount, and keep certification materials concerned.
(2) When the standard values of national standard GB and local standard are different
In China, regarding the content of VOC toxic substances, in addition to the national standard GB, local governments have also formulated local standards that might be stricter than the national standards according to the local situation. For example, the limits for VOC content of hazardous substances contained in building wall paints is said to be very wide; for instance, Beijing City’s “Regulations on Safety, Health and Quality Evaluation of Interior Decoration Coatings” states ” The upper limit of VOC is to be less than 125 grams per liter which is more stringent than a national level . Therefore, it is possible that the local limits happen to be stricter than the levels of national standards. Therefore, when a company confirms GB compliance, it should also confirm whether or not there are any other relevant laws and regulations in the local governments, and if so, it should further confirm their details.
(3) Enjoy the additional benefits triggered by the enforcement of the new standards
Currently, in China, the use of raw materials and auxiliary materials with low VOC content is not compulsory, but the Chinese government places the companies that fully use low VOC content raw materials and auxiliary materials on the “positive list” and “Government Green Procurement List.” Thus, it can be said that the use of low VOC content materials is highly encouraged so that the government is likely to prioritize the low VOC content materials for their investment projects. In other words, if a company doesn’t use it, it might not be eligible for the government green procurement list and the “positive list” and, as a result, it would lose various business opportunities.
In practice, companies participating to government-designated bid-purchasing opportunities such as furniture and printing producers are required to preferentially use low-volatile raw and companies participating to the government-solicited bids such as automobile repair industries are also encouraged to use low-volatile raw and auxiliary materials.
