Paints, coatings and varnishes

• Regulation (EC) No 1272/2008 — CLP
• Directive 2004/42/EC — VOC in decorative paints
• Regulation (EC) No 1907/2006 — REACH
• Regulation (EU) 2023/988 — GPSR
• Directive 2009/48/EC where marketed for children

Who has to appoint one

Manufacturers and sellers outside the Union placing paints and coatings on the EU market. The CLP supplier responsible for the label must be established in the Union, and decorative paints must meet the volatile organic compound limits of the Paints Directive.

Thresholds and exemptions

VOC limits apply per subcategory of decorative paint and varnish. CLP applies to any classified mixture regardless of pack size, including small craft and touch-up packs.

What must appear on the label

CLP pictograms, signal word, hazard and precautionary statements, the product identifier, the nominal quantity, the supplier's EU name, address and telephone, the UFI code, and for decorative paints the subcategory and the maximum VOC content in grams per litre alongside the limit value.

Marketplace fields

Marketplaces remove aerosol paints without CLP labelling in the images, and spray products face additional transport and dangerous goods restrictions that limit fulfilment options.

Documentation you must hold

CLP classification file, safety data sheet in the language of each member state, poison centre notification with the UFI, VOC content calculation or measurement, and REACH compliance evidence for pigments, driers and biocidal in-can preservatives.

Standards and testing

VOC content determination under the harmonised methods, classification testing or calculation under CLP, and where the paint is marketed for children EN 71-3 and EN 71-7 for finger paints.

Language requirements

The label, hazard statements and safety data sheet in the official language of each member state of sale.

When it applies

Poison centre notification before the first sale in each member state, and the UFI must appear on the label from that point.

How long records are kept

Ten years for the classification file and the safety data sheets.

What happens if you do not comply

Withdrawal, fines and border rejection. Missing UFI codes and untranslated safety data sheets are among the most common findings in chemical inspections.

Who enforces it

National chemicals authorities, poison centres, environmental authorities for VOC and customs.

Where the boundary lies

In-can preservatives make paints partly a biocidal matter through the treated articles rules, and any antifungal or antibacterial claim on the dry film moves the product into Regulation 528/2012. Craft paints marketed for children are toys with EN 71 testing.

Questions we are asked

Do we need a UFI for every colour?

A UFI is required per formulation. Colour variants with different compositions need separate notifications, though grouping is possible in defined cases.

Can our safety data sheet be in English only?

No. It must be in the official language of each member state where the product is placed on the market.