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Enforcement of Decorative Paints Regulations   |   

Decorative Paints Directive

Painting and decorating has been made easier with the development of many easy-to-use products.  Not only is there a vast array of products for different applications but also many come in a myriad of colours.  In order to reduce the risk to the user and the environment due to exposure to volatile organic compounds (VOC), the Directive on the Limitations of Emissions due to the use of organic solvents in certain Paints, Varnishes and Vehicle Refinishing Products, (Decorative Paints Directive) Directive 2004/42/EC, limits the VOC content of these widely used products.  The Directive was enacted into Irish law by the Limitation of Emissions of Volatile Organic Compounds due to the use of certain Paints, Varnishes and Vehicle Refinishing Products Regulations 2007 (Statutory Instrument 199 of 2007).

Why reduce VOC emissions?

VOCs pose a risk to health and the environment.  In still, sunny conditions and in the presence of nitrogen oxides (contained in vehicle exhaust gases), VOCs react to form ground level ozone.  Ozone is one of the components of summer smog and harms human health through respiratory illness, crops and the general ecosystem.  Ozone can be transported over long distances, possibly hundreds of kilometres, from where it is formed.  It is estimated the introduction of the Directive will reduce the VOC emissions from decorating materials by approximately 297k tonnes per year is 2010.

The Regulations

After 1 January 2007, decorating products listed in Annex 1 of the Directive can be placed on the market only if their VOC contents are equal to or lower than the values outlined in Annex 2 of the Directive.  Additionally, the product containers must be labelled to inform the users of the product category, subcategory (as defined in Annex I of the Directive), the maximum allowable VOC contents of the product (as shown in Annex II of the Directive) and maximum VOC content of the product in its ready to use form.  It is an offence to sell/offer non-compliant products covered by the Regulations.  Also, if a producer, wholesaler or retailer receives non-compliant product, they must alert the Agency of this fact and take measures to minimise the risk to human health and the environment.  These Regulations designate the EPA as the competent enforcement authority, having a monitoring/supervisory role in enforcement.  Local authorities are the competent bodies, carrying out general enforcement activies.

Vehicle Refinishers

The Irish Decorative Paints Regulations (S.I. 199 of 2007) also oblige vehicle refinishers to have a solvent management plan carried out by an Accredited Inspection Contractor (AIC), review their operations and obtain a compliant AIC report.  A list of AICS can be found on the Irish National Accrediation Board's website.  Requirements for a compliant AIC report can be found in the EPAs Best Practice Guidelines for Vehicle Refinishing for Repair Installations.  The resulting compliant AIC report along with a completed Registration Application Form and registration fee must be submitted to and approved by the local authority in whose functional area the facility is located.  All required documentation must be provided to the local authority at least 28 days prior to 31st January, 2008 or in the case of a certificate renewal at least 28 days before the expiry date of the current certificate of approval.  Certificates of approval must be renewed every two years.  Additionally, if an operator receives non-compliant materials, they must notify the Agency of this fact and take appropriate steps to minimise the risk to human health and the environment.  It is an offence to operate a vehicle refinishing for repair installation without a valid certificate of approval.  Other Vehicle Refinisher requirements under this legislation include:-

  • Immediate notification of the local authority by the Vehicle Refinisher on becoming aware of any breaches of the Regulations and restoration of compliance in the shortest possible time.
  • Immediate cessation of any operation which is likely to endanger human health or the environment and the immediate notification of the local authority.
  • Notification of the EPA of receipt of any unauthorised non compliant product.

Learn More

Download legislation
Presentation by Eileen O'Leary (CTC) at VR Workshop, Portlaoise, September 2007
Presentation by Martin Doyle (EPA) at VR Workshop, Portlaoise, September 2007
Vehicle Refinishers - Who Does What?
Download Best Practice Guidelines for VR for Repair Installations
List of Relevant Contacts in Local Authorities