Legislation EU VOC

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Legislation EU VOC

• The first EU legislation 1999/13/EC The Solvent
  Emissions Directive (SED) set out the EU rules to
  limit solvent emissions from many industrial
  processes. The rules set are appropriate for
  large scale industrial processes but do not work
  well in small scale industries such as Refinish.
• In recognition of this, the EU has passed
  Directive 2004/42/CE The Paint Products
  Directive (PPD) which governs solvent emissions
  from vehicle repair facilities (and Decorative
  paints)

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Directive 2004/42/CE

• The Directive 2004/42/CE applies to

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Directive 2004/42/CE

• Under European regulations original equipment
  painting is covered by the SED and repair
  painting by the PPD but
• A country may decide to implement or encourage
  the use of VOC controlled paints (i.e. PPD) for
  original equipment painting activities as well as
  vehicle refinishing by confirming that the use of
  PPD products meets all the requirements of the
  SED.

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VOC content limits

• Fixed by Directive 2004/42/CE

Some of the PPD product limits are identical or
similar to those already fixed in some countries
through their implementation of the SED
VOC g/l
Coatings
Subcategory
850 200
Preparatory products Pre-cleaners
Preparatory and Cleaning Products
250
All types
Bodyfillers/Stoppers
540 780
Surfacers / fillers and general (metal)
primers Wash primers
Primers
420
Basecoats, direct gloss, clearcoats, 3-stage
topcoats
Topcoats (each layer)
840
Aerosols, scratch-resistant clears, interior
finishes
Special Finishes
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Exemptions and Member State flexibility

• A special exemption is granted for the painting
  of vintage vehicles with conventional,
  non-compliant products, under strict controls and
  conditions. These conditions are not defined in
  the PPD and would be implemented at Member State
  level.

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The transition period

• As this Directive represents such a major change
  for the Refinishing industry, the legislation
  allows a transition period from 1st January
  2007 to 31st December 2007, during which time the
  paint manufacturer or importer may place
  non-compliant products manufactured before 1st
  January 2007 on the market.
• The PPD does not prevent non-compliant product,
  which has already been placed on the market, from
  being used at any time in the future, although
  Member State legislation may restrict such
  activity.

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SED vs. PPD
Solvent Emissions Directive (SED)
Paint Products Directive (PPD)

• Onus is on the bodyshop to comply
• Compliance can be achieved in a number of ways
  (abatement systems Solvent Reduction Plan).
• Note Product-based VOC limits are not prescribed
  at EU level.
• Only bodyshops above a certain threshold of
  solvent usage are affected
• The threshold depends on solvent use activity
  (e.g. Vehicle Refinish 0.5 ton./year LIC 5
  ton./year)
• The user must keep records of VOC usage and prove
  that the activity is compliant.

• Onus is on the paint manufacturer or importer to
  place compliant products on the market.
• Only product-based VOC limits are applicable
• VOC contents must be printed on the labels to
  clearly identify the compliant products.
• No threshold (all customers covered)

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SED vs. PPD - Timescales
Solvent Emissions Directive (SED)
Paint Products Directive (PPD)

• Passed EU Parliament 11 March 1999
• Active in all Member States (but only since 2004
  in some)
• For bodyshops using the Reduction Scheme there
  are 2 Stages
• For new or substantially changed premises Stage
  2, by 31 October 2004
• For existing premises Stage 1 by 31 October
  2005 Stage 2 by 31 October 2007

• Passed EU Parliament 21 April 2004
• Must be brought into force by Member States by 30
  October 2005
• Product-based VOC limits apply from 1 January 2007