Paints are liquid or semi-liquid substances used to coat surfaces for protection, decoration, or functional purposes. Composed of pigments for colour, binders to hold the pigment together, and solvents to adjust the paint’s consistency, paints can be water-based or solvent-based.
Common types include synthetic polymer-based paints like acrylic and polyurethane, which offer durability and versatility; water-based paints, which are eco-friendly and easy to clean; oil-based paints, known for their rich finish and long-lasting durability; as well as specialty coatings like enamels, lacquers, and varnishes that provide high-gloss finishes and protection for surfaces like wood, metal, and furniture.
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HS Classification / Description of Product
Paints
Paints might be subject to specific regulations due to their chemical composition and potential environmental and health impacts
HS classification
Chapter 32 of the Harmonized System (HS) code, which covers “Tanning or dyeing extracts; tannins and their derivatives; dyes, pigments and other coloring matter; paints and varnishes; putty and other mastics; inks.”
The most common subheadings for paints are:
- HS Code 3208: Paints and varnishes based on synthetic polymers or chemically modified natural polymers, dispersed or dissolved in a non-aqueous medium.
- HS Code 3209: Paints and varnishes based on synthetic polymers or chemically modified natural polymers, dispersed or dissolved in an aqueous medium.
HS Code 3210: Other paints and varnishes (including enamels, lacquers, and distempers).
General Requirements
REACH
EU legislation
Chemical substances under REACH and Classification and Labelling Regulations
Short summary
Registration of chemical substances with ECHA if imported >1 tonne/year
Domestic legislation
Main law:
The Chemical Substances Law of 2020 (L. 119(I)/2020)
Additionally, secondary legislation / regulation:
Regulatory Administrative Acts 380/2020, 381/2020, 382/2020, 383/2020, 384/2020
Domestic Competent authorities
Ministry of Labour, Welfare and Social Insurance, Department of Labour Inspection
Classification, Labelling and Packaging (CLP)
EU legislation
Short summary
Proper labelling with hazard pictograms, signal words, hazard and precautionary statements
Child-resistant fastenings and tactile warnings may be required
Domestic legislation
Main law:
The Chemical Substances Law of 2020 (L. 119(I)/2020)
Regulatory Administrative Act 381/2020
The Regulatory Administrative Act lays down fines that may be imposed.
Domestic Competent authorities
Ministry of Labour, Welfare and Social Insurance, Department of Labour Inspection
Important information
For products distributed in the areas under the control of the Republic of Cyprus, labels must be in the Greek language.
Volatile Organic Compounds (VOCs)
EU legislation
Short summary
Limitation of emissions of Volatile Organic Compounds due to the use of organic solvents in decorative paints and varnishes and vehicle refinishing products.
VOC content limits vary by paint type
Domestic Competent authorities
Ministry of Labour, Welfare and Social Insurance, Department of Labour Inspection
Important information
Annex I A of Law 35(I)/2006 sets out specific limit values for the maximum VOCs contents of decorative paints and varnishes.
Annex I B sets outs limit values for vehicle refinishing products.
Other useful material
Persistent Organic Pollutants (POPs)
EU legislation
Short summary
Protect human health and the environment from persistent organic pollutants
Domestic legislation
Domestic Competent authorities
Ministry of Labour, Welfare and Social Insurance / Ministry of Agriculture, Rural Development and Environment, Department of Environment
Important information
The Cyprus Government ratified the POPs Convention on Persistent Organic Pollutants through the “Stockholm Convention on Persistent Organic Pollutants Ratifying Law of 2004” (Law 42 (III)2004)
Other useful material
Biocidal Products
EU legislation
Short summary
Biocidal products are necessary for the control of organisms that are harmful to human or animal health and for the control of organisms that cause damage to natural or manufactured materials.
Required for paints containing biocidal substances.
Domestic legislation
Domestic Competent authorities
Ministry of Agriculture, Rural Development and Environment, Department of Agriculture
Important information
For a biocidal product to be approved in Cyprus, the corresponding application must be submitted (available in Greek only).
Certificate in all cases is valid for 5 years.
Other useful material
Safety Data Sheets (SDS)
EU legislation
Short summary
Safety Data Sheets (SDS) are the main tool for ensuring that suppliers communicate enough information along the supply chain to allow safe use of their chemical substances and mixtures
SDS required for each paint product as per REAC, Article 31 and Annex II
Domestic legislation
Domestic Competent authorities
Ministry of Labour, Welfare and Social Insurance
Important information
Chemicals placed on the Cyprus market must be accompanied by a SDS in Greek language and English language (As per art.11 of Law 119(I)/2020.
Other useful material
Packaging
EU legislation
Short summary
This Directive covers all packaging placed on the market in the Community and all packaging waste, whether it is used or released at industrial, commercial, office, shop, service, household or any other level, regardless of the material used
Domestic legislation
Domestic Competent authorities
Ministry of Agriculture, Rural Development and Environment, Department of Environment
Important information
The Packaging and Packaging Waste Law of 2002 (Law 32 (I) / 2002) with all its amendments defines the obligations of the various economic actors regarding the management of packaging and packaging waste
Other useful material
More information on Extended producer responsibility
Restricted Substances
EU legislation
Short summary
Restrictions on lead carbonates, lead sulphates, mercury compounds, cadmium and its compounds
Domestic legislation
Domestic Competent authorities
Ministry of Labour, Welfare and Social Insurance,
Department of Labour Inspection
CE Marking
EU legislation
Short summary
Required for paints considered construction products, such as fire-retardant paints.
Domestic legislation
Domestic Competent authorities
Ministry of Interior, Construction Products Sector, Technical Services
Important information
The Law is considered the «Framework Law» and contains the fundamental principles of the CE marking and market surveillance, the procedure for the approval of Notified Bodies, the powers of the competent authorities, the penalties imposed on the violations of the legislation, etc.
Other useful material
More information about the CE. The marking is affixed to those construction products for which the manufacturer has drawn up a declaration of performance.
Declaration of Performance (DoP)
EU legislation
Construction Products Regulation (EU) No 305/2011
Short summary
Required for paints under the Construction Products Regulation.
Article 15 of L.30(I)/2002 – See more on EC Declaration of Conformity
The specific harmonized standards (such as EN 1504-2, EN 13300, EN ISO 12944) are referenced in the Declaration of Performance. These standards outline the specific performance and test methods for paints used in construction and other sectors.
Domestic legislation
See “CE Marking”
Domestic Competent authorities
Ministry of Interior, Construction Products Sector, Technical Services
Environmental Considerations
EU legislation
Short summary
Eco-labels like EU Ecolabel may be advantageous.
The European Eco-label is a voluntary tool that identifies products and services that are environmentally friendly.
Domestic legislation
Domestic Competent authorities
Ministry of Agriculture, Rural Development and Environment, Department of Environment
Transport and Storage
EU legislation
Directive 2008/68/EC on the inland transport of dangerous goods
Short summary
Product may require compliance with ADR regulations
Domestic legislation
Domestic Competent authorities
Ministry of Communications and Works, Road Transport Department
Technical Documentation
EU legislation
Short summary
Detailed technical data sheets required
Domestic Competent authorities
Ministry of Labour, Welfare and Social Insurance
Proof of origin
Short summary
Provide proof of origin
Domestic Competent authorities
Ministry of Finance – Customs & Excise Department
Other useful material
The accompanying document shall be made out on forms corresponding to the specimen given in Annex I.
Restriction of Hazardous Substances (RoHS)
EU legislation
Short summary
This directive limits the use of hazardous substances in the manufacture of electrical and electronic products, including coatings and paints. These substances include heavy metals like lead, cadmium, and mercury, which can have harmful environmental and health effects.
Waste and Recycling Considerations
EU legislation
Short summary
Under Directive 94/62/EC, paints and coatings are considered part of the packaging waste. Therefore, manufacturers are responsible for ensuring the proper recycling or disposal of paint containers to minimize environmental impact.
- Recycling: Paint containers and packaging must be designed to allow recycling or reuse.
Disposal: The proper disposal of hazardous paints, especially those containing VOCs or toxic metals, is required to minimize environmental contamination.
Materials and articles intended to come into contact with food
EU legislation
Short summary
This Regulation establishes the general requirements for all materials and articles intended to come into contact with food. This regulation ensures that paints used in food packaging or containers do not transfer harmful substances into food.
Safety of toys
EU legislation
Short summary
The Toys Directive specifies the safety of paints used on toys, ensuring that paints used on children’s products are free from harmful chemicals and are safe for human contact.
Industrial Emissions (IED)
EU legislation
Short summary
The IED Directive regulates emissions from industrial activities, including paint production facilities. It sets emission limits for various pollutants, ensuring that paint manufacturing processes do not harm the environment.
Batteries and accumulators
EU legislation
Short summary
This directive controls the use of hazardous substances in batteries and accumulators, including those that may be used in conjunction with paints in certain applications (e.g., electrical equipment). It limits the use of heavy metals such as mercury and cadmium.
Cosmetics Regulation
EU legislation
Short summary
Although focused on cosmetics, this regulation can also apply to paints used in cosmetic applications (e.g., body paints, face paints).
Specific plastics and articles for food packaging
EU legislation
Short summary
This regulation specifically addresses the safety of materials, including paints and coatings, used in food packaging.
Community eco-label to indoor paints and varnishes
EU legislation
Short summary
The Decision establishes ecological criteria for the award of the Community eco-label to indoor paints and varnishes
Traceability A system ensuring the traceability of the paints back to their manufacturer
EU legislation
Traceability is related also a part of Regulation (EC) No 1907/2006 – REACH
Short summary
Traceability requirements:
- Manufacturers of paints must register chemicals used in their products with the European Chemicals Agency (ECHA).
- Traceability of chemicals is essential in ensuring that all substances used in paints meet safety standards.
- If a hazardous substance is used, manufacturers must keep detailed records of its origin, composition, and usage to ensure compliance with REACH restrictions and provide information if needed.
- Substance Identification: Manufacturers must provide Safety Data Sheets (SDS) for paints and coatings, listing all ingredients and ensuring traceability of each component.
Traceability A system ensuring the traceability of the paints back to their manufacturer
EU legislation
Traceability is also part of Regulation (EU) No 1272/2008
Short summary
Traceability requirements:
- Paint manufacturers must maintain traceability of the chemical substances they use, ensuring that the correct hazard classification is provided for each paint product.
- Batch-specific labeling: Paint products are required to have labels that clearly identify the product batch to which they belong. This ensures that if an issue arises (e.g., a hazardous substance), it can be traced back to a specific batch or manufacturing process.
Tracking and Traceability: Manufacturers must maintain records of the substances used, their hazard classification, and labelling requirements for each product batch. This is vital for recall procedures if a dangerous product reaches the market.
Traceability A system ensuring the traceability of the paints back to their manufacturer
EU legislation
Traceability is also part of Regulation (EC) No 1935/2004
Short summary
Traceability requirements:
- Paints used in food contact materials must be traceable to ensure that they meet migration limits for hazardous chemicals.
- Manufacturers of paints must provide a Declaration of Compliance (DoC) and keep records of the composition and substances used in the production of paints for food contact surfaces.
Traceability of migration tests is required to ensure compliance with the relevant safety standards for food-contact materials.
Traceability A system ensuring the traceability of the paints back to their manufacturer
EU legislation
Traceability is also part of Regulation (EU) No 1183/2012
Short summary
Traceability requirements:
- Similar to Regulation 1935/2004, manufacturers must keep records of the composition, origin, and migration testing of coatings or paints used in food-contact packaging.
Detailed traceability is required to ensure that the coatings do not contain hazardous substances and that any risk to human health is minimized.
Traceability A system ensuring the traceability of the paints back to their manufacturer
EU legislation
Traceability is also part of Directive 2004/42/EC
Short summary
Traceability requirements:
- Manufacturers must track the VOC content in each product batch to ensure it meets the applicable limits.
Traceability of VOC content is critical for compliance with the VOC limits established for different types of paints, including decorative and industrial coatings.
Traceability A system ensuring the traceability of the paints back to their manufacturer
EU legislation
Traceability is also part of Regulation (EC) No 1223/2009
Short summary
Traceability requirements:
- Manufacturers must ensure that paints and coatings used in cosmetics meet the relevant safety standards.
Ingredient traceability and batch-specific documentation are required for safety and recall purposes in case of contamination or adverse effects.
EU Product Specific Standards
Product-Specific Standards
Short summary
These standards ensure that the products you use meet the highest standards of quality and safety.
Decorative paints and varnishes – performance requirements
EU legislation
Short summary
This standard outlines the performance characteristics (e.g., opacity, durability, ease of cleaning) for decorative paints used for interior walls and ceilings.
Safety of toys: migration of certain elements
EU legislation
Short summary
This standard specifies the migration limits of heavy metals, which is important for paints used in toys and children’s products.
Safety of toys: organic chemical compounds
EU legislation
Short summary
This standard covers the safety of organic chemical compounds in paints used on toys, ensuring they do not contain harmful substances.
Fire classification of construction products and building elements
EU legislation
Short summary
This standard includes classification systems for paints used in construction, providing safety guidelines for fire resistance.
Liquid applied waterproofing products for use in concrete - methods of test for determining the resistance to water penetration
EU legislation
Short summary
This standard applies to paints and coatings used for waterproofing applications, particularly for concrete surfaces. It provides the testing methods for determining the resistance of coatings to water penetration, ensuring the durability and performance of the applied paint.
Products and systems for the protection and repair of concrete structures
EU legislation
Short summary
This standard includes specifications for coatings used in the repair and protection of concrete structures, ensuring they provide adequate protection against environmental factors like water, chemicals, and physical wear.
Thermal Insulation Products - Determination of water vapor transmission properties
EU legislation
Short summary
This standard applies to paints and coatings used for thermal insulation and specifies how to determine their water vapor permeability.
Paints and coatings used for insulation must have low water vapor permeability to ensure effective insulation.
Paints and Varnishes – determination of release of toxic elements
EU legislation
Short summary
This standard outlines the methods for testing the release of toxic elements from painted surfaces.
Tests are performed to ensure that paint used on products (e.g., furniture or children’s toys) does not release harmful levels of toxic substances over time, particularly if the paint is subject to wear or abrasion.
Natural Stone Products – slabs for floors and stairs
EU legislation
Short summary
This standard specifies the properties and performance of natural stone slabs, including the paint or coating that might be applied to improve appearance or functionality.
It ensures that the applied paints and coatings are compatible with the natural stone and provide appropriate protection against abrasion, staining, and color fading.
Natural stone products — dimensional stonework
EU legislation
Short summary
Similar to EN 12058, this standard addresses paints used in dimensional stonework applications. It ensures paints meet the required performance standards for coating stone materials. The standard requires the durability of the coating – ensures that the paint or coating provides long-term protection against weathering and stains.
Anti-fungal and algal properties
Industrial coatings — assessment of durability of coatings
EU legislation
Short summary
This standard provides the methodology for assessing the durability of industrial coatings, which can also apply to certain architectural coatings in buildings exposed to demanding environments.
Paints and Varnishes — determination of wet scrub resistance and cleanability of coatings
EU legislation
Short summary
This standard applies to decorative and protective coatings, as well as enamel paints. It defines a test method for wet scrub resistance and the cleanability of painted surfaces. It ensures that enamel paints can withstand washing and cleaning without losing their appearance or durability.
It may be applicable for enamel paints used for high-cleanability surfaces, such as kitchens, bathrooms, or hospital environments.
Paints and varnishes - corrosion protection of steel structures
EU legislation
Short summary
EN ISO 12944 is a series of standards that addresses the corrosion protection of steel structures through the use of protective coatings (paints and varnishes). The standard includes several parts:
- Part 1: General introduction to corrosion protection by coatings.
- Part 2: Classification of environments in which steel structures will be exposed.
- Part 3: Design considerations for coating systems.
- Part 4: Types of protective coatings.
- Part 5-7: Performance requirements and testing methods.
The ISO 12944 series ensures that paints and coatings used for corrosion protection on steel structures are effective and durable in various environmental conditions.
Paints and varnishes - determination of resistance to various liquids
EU legislation
Short summary
This series of standards defines methods for testing the resistance of paints and varnishes to different liquids, such as water, oil, and solvents. This is important for ensuring that paints maintain their integrity when exposed to harsh conditions, especially in industrial applications.
Cosmetics – Good Manufacturing Practices (GMP)
EU legislation
Short summary
This standard outlines the Good Manufacturing Practices (GMP) for the production of cosmetics, ensuring that paints (and other cosmetic products) are manufactured safely and under hygienic conditions.
“Sheen Automatic Scratch Tester”
EU legislation
Short summary
The standard provides complete test report showing that the paint/varnish has satisfactory scratch resistance for its intended purpose
Anti-corrosion paints
EU legislation
Short summary
This standard provides the most suitable requirements for anti-corrosion paints, where test methods for anti-corrosion paints are specified in EN ISO 12944-6 and EN ISO 12944-9.
Water vapour permeability
EU legislation
Short summary
This standard assesses if the exterior masonry and concrete paints are breathable and shall be classified accordingly
ISO Product specific standards
Paints and varnishes — Vocabulary
EU legislation
Short summary
This standard defines terms used in the field of coating materials (paints, varnishes and raw materials for paints and varnishes). Terms relating to specific applications and properties are dealt with in standards concerning those applications and properties, including corrosion protection (ISO 12944 series), coating powders (ISO 8130-14), electro-deposition coatings (ISO 22553-1) and rheology (ISO 3219-1). Terms on nanotechnologies are harmonized with the ISO 80004 series. Terms on pigments and extenders are harmonized with ISO 18451-1.
Driers for paints and varnishes
EU legislation
Short summary
This standard specifies the requirements and the corresponding test methods for driers for paints, varnishes and related products. It applies to driers in the solid or liquid form. It does not apply to emulsifiable driers.
Paints and varnishes - Cross-cut test
EU legislation
Short summary
This document specifies a test method for assessing the resistance of paint coatings and varnishes (including wood stains) to separation from substrates when a right-angle lattice pattern is cut into the coating, penetrating through to the substrate. The property determined by this empirical test procedure depends, among other factors, on the adhesion of the coating to either the preceding coat or the substrate.
Determination of solar reflectance
EU legislation
Short summary
This document specifies a method to determine the solar reflectance of coating systems using a spectrophotometer with a wide spectral range (300 nm to 2 500 nm) and global solar radiation.
Preparation of Steel Substrates Before Application of Paints and Related Products
EU legislation
Short summary
This standard specifies the preparation requirements for steel surfaces before the application of coatings. It provides guidelines on surface cleanliness and roughness, which are critical for ensuring proper adhesion and durability of coatings.
Paints and Varnishes - Evaluation of Degradation of Coatings
EU legislation
Short summary
This standard specifies methods for evaluating the degradation of coatings and varnishes, including colour change, loss of gloss, and surface cracking.
It provides procedures for the visual inspection and grading of degradation in coatings due to environmental exposure.
Paints and Varnishes - Determination of Resistance to Humidity
EU legislation
ISO 11503
Short summary
This standard determines the humidity resistance of paints and varnishes, which is essential for applications exposed to moisture.
Key Requirements: Paints and coatings must be tested to ensure they retain their protective properties when exposed to high humidity.
Paints and Varnishes - Determination of Gloss
EU legislation
Short summary
This standard establishes the method for measuring the gloss of paints and varnishes.
The standard specifies how to measure gloss levels at various angles, which is important for product appearance and performance.
Paints and Varnishes - Determination of the Percentage of Non-Volatile Matter
EU legislation
Short summary
This standard provides a method for determining the non-volatile matter in paints and varnishes, which impacts the durability and consistency of the product.
The percentage of solids in the coating is critical for determining the paint’s performance, coverage, and drying time.
Classification of Oils and Related Products - Part 2: Application to Paints and Varnishes
EU legislation
Short summary
This standard classifies oils and related products used in the formulation of paints and varnishes.
It specifies different classes of oils based on their composition and intended use, affecting the viscosity, drying time, and stability of the final paint product.
Paints and Varnishes - Cross Cut Test
EU legislation
Short summary
This standard specifies the cross-cut test method for evaluating the adhesion of paint and coatings to substrates.
The test determines how well a coating adheres to the substrate and helps assess the durability of the coating under mechanical stress.
Paints and Varnishes - Determination of Volatile Organic Compounds (VOCs)
EU legislation
Short summary
This standard outlines methods for quantifying volatile organic compounds (VOCs) in paints and coatings.
It specifies test methods for measuring the VOC content, which is crucial for compliance with regulations like the VOC Directive (2004/42/EC).
Cosmetics - Guidelines on Technical Definitions and Criteria for Natural and Organic Cosmetic Ingredients
EU legislation
Short summary
While not directly applicable to paints in all cosmetics, this standard provides guidance on the ingredients used in cosmetics, which could include natural pigments or other components used in cosmetic paints.
Quality Management Systems (QMS)
EU legislation
Short summary
The standard provides a framework for establishing and maintaining an effective quality management system in any organization, including manufacturers of paints. The standard helps ensure that products consistently meet customer requirements and regulatory standards.