CEPE said the European Commission “widely incorporated” industry recommendations in the EU “Decorative Paint Directive,” but CEPE added that the proposal includes cost and benefit figures containing “a number of errors.”
As a result, CEPE said the EU directive will result in a greater economic and social impact than forecast and a disproportionate impact on small and medium-sized enterprises, and will create major difficulties for raw-material suppliers such as alkyd resin manufacturers and coatings users such as professional painters.
CEPE said its recommendations were based on “best available techniques” and are viewed as being “applicable on all types of building substrates and under all kinds of climatic conditions.” Even if coatings manufacturers are able to meet the EU directive’s more drastic proposals, “the benefit of the additional VOC reduction will be negligible compared to the additional cost,” the organization said.
Specifically, the CEPE position paper questions the EU directive’s proposed VOC limit of 300 grams per liter for solventborne trim paints, scheduled to go into effect in 2007, and the directive’s provision for an additional reduction in the limit in 2010. CEPE said the 300 g/l limit is the “lowest achievable limit for this product category” and “will only be achievable by 2010.” The CEPE position paper advocates a VOC limit of 400 g/l in 2007 and 300 g/l in 2010.
The organization said extensive research has shown that solventborne trim paints of less than 300 g/l of VOC “have all failed to provide the applicability and durability required by customers.” A 300 g/l limit by 2010 is viewed by industry experts as “what will be achievable and widely acceptable state of the art,” CEPE says. In addition, the organization said an earlier implementation date for the 300 g/l limit would dramatically affect small and medium-sized companies and “create an unacceptable uncertainty for all paint manufacturers, who will need a longer period to develop a new range of low-VOC products.”
CEPE also said new requirements resulting from the recently issued EU Chemicals Policy and possible additional marketing and use restrictions affecting coatings raw materials would make a VOC limit below 300 g/l “totally unworkable.”