Ireland Paint and Varnishes Regulation Amended

By Susana Planas MunGavin BSc., MSc, Senior Regulatory Specialist, Supply Chain team, UL Solutions

The Minister for the Environment, Climate and Communications adopted the European Union (Paints, Varnishes, Vehicle Refinishing Products and Activities) (Amendment) Regulations 2024, SI No. 356 to amend the European Union (Paints, Varnishes, Vehicle Refinishing Products and Activities) Regulations 2012, SI No. 564. They give effect to Commission Directive 2010/79/EU on the adaptation to technical progress of Annex III to Directive 2004/42/EC of the European Parliament and of the Council on the limitation of emissions of volatile organic compounds.

The Irish Regulations implement marketing and volatile organic compound (VOC) emission controls to products listed under Schedule 1, including paints, varnishes and vehicle refinishing products that are being sold or placed on the market, excluding aerosols specifically. Typically, paints, also include coatings listed under the sub-categories under Schedule 1, which are mainly applied to buildings, their trim and fittings, and associated structures for decorative, functional and protective purposes.

It is prohibited to sell or place on the market any of the regulated product category containing volatile organic compound (VOC) above the relevant limit value specified in Schedule 2, expressed in grams per litre, which apply to both indoor and exterior paints and varnishes, as well as vehicle refinishing products.

Regulated products must comply with the product labelling requirements.  Each product label must include the following information, as specified under Regulation 11:

“-(a) the relevant sub-category of Schedule 1,

-(b) the relevant volatile organic compound limit value for the product, expressed in grams per litre (g/l), prescribed in Schedule 2, and

-(c) the maximum volatile organic compound content, expressed in grams per litre (g/l), of the product in a ready to use condition”.

Non-compliance to labeling requirements may include the imposition of a fixed fine, ranging from EUR 1,000 to EUR 500 depending on the regulatory contravention.  If a fine notice is issued, the offender has up to 21 days to make the payment to the local authority before any further prosecution is initiated.

Recommended Action Items

• Review labels of paints and varnishes or vehicle refinishing products listed under any of the sub-categories of Schedule 1 to the Regulations being placed on the market from August 2, 2024.
• Review the need to update labels with the indication of the prescribes VOC limit values specified in Schedule 2 to the Regulations.

References

• The European Union (Paints, Varnishes, Vehicle Refinishing Products and Activities) (Amendment) Regulations 2024 (S.I. No. 356 of 2024)
• The European Union (Paints, Varnishes, Vehicle Refinishing Products and Activities) Regulations 2012 (S.I. No. 564 of 2012)
• The Air Pollution Act (Fixed Payment Notice) (Paints) Regulations 2016 (S. I. No. 348 of 2016)