Paints and varnishes

Public hearing concerning proposal for a new set of Nordic Ecolabelling criteria for Paint and varnish.

Nordic Ecolabelling gives you the opportunity to comment on the proposal for new criteria for Paints and varnishes. (Indoor, outdoor and industrial paints and varnishes in the same set of criteria.) Your comments are important and will be considered by the national ecolabelling boards and the Nordic Ecolabelling Board.

We look forward to your comments, which should be sent to Nordic Ecolabelling no later than 8 February 2023 to be taken into consideration.

Nordic Swan Ecolabel Paints and varnishes have a reduced environmental impact throughout its lifecycle. Through strict requirements the product group is a better choice for users and the environment.

With long shelf lives and strict quality requirements, Nordic Ecolabelling requirements for Paints and varnishes help reduce resource use. Furthermore, the requirements promote circular economy and reduces the climate impact of paints and varnishes.


Nordic Swan Ecolabel Paints or varnishes

  • Meet strict quality requirements to promote long-lasting, durable, and efficient paints and varnishes which leads to less use of resources in a lifecycle perspective.
  • Meet strict requirements regarding environmentally hazardous chemicals.
  • Meet strict health requirements for chemicals. It means that the paint/varnish does not contain substances that can cause cancer, damage genes or reproductive capacity.
  • Is free from phthalates, fluorinated substances and identified and potential endocrine disruptors on up-to-date lists from EU and national authorities.
  • Meet strict requirements for emissions from harmful substances. This is positive for the indoor environment.
  • Meet strict requirements for the manufacturing of raw materials with high climate impact such as titanium dioxide and cement/hydraulic binders.
  • Has packaging that includes recycled content – which contributes to a circular economy.
  • Implement a policy to ensure increased use of renewable raw materials that originate from sustainably produced and controlled sources.

Please find the proposed criteria for download further down on this page.


What has been changed?

The focus of this revision has been to reassess paints and varnishes from a life cycle perspective to better identify the impacts of paints and varnishes during its entire life cycle. The requirements focus either directly or indirectly on reduced energy consumption including reduced emissions of greenhouse gases, restriction of hazardous substances, good indoor air quality, circular economy, and use of renewable raw materials.

  • The criteria of Paints and varnishes is based on the current version of Indoor paints and varnishes (gen 3). Paints and varnishes for outdoor use and industrial paints and varnishes have been moved from the criteria for Chemical building products to this proposal for criteria of Paints and varnishes.
  • In the area of energy and climate, new requirements have been added for the raw material manufacturer of cement/hydraulic binders and titanium dioxide.
  • In the area of indoor climate, new requirements have been added and previous requirements have been adjusted with the introduction of emission testing of the final product. The criteria for emissions is in compliance with the EU-Taxonomy and Annex XVII to Regulation (EC) No 1907/2006 regarding restriction on formaldehyde and formaldehyde releasing substances.
  • In the area of ingoing substances, requirements have been revised based on licensing data. Furthermore, new criteria for restriction of endocrine disruptors have been added.
  • In the area of circular economy, previous requirements for packaging have been replaced with new requirements concerning recycled material in plastic pouches and containers.
  • In the area of sustainable raw materials, new requirements have been introduced to different binders to increase the use of renewable raw materials.


We wish to highlight the following points in the consultation draft

  • O9 Titanium dioxide (energy related requirements). The proposed requirement is a first draft. Input on the proposed requirement and suggestions for alternative requirements are most welcome. We have proposed energy limits for the traditional sulphate and chloride processes in point a. If you consider other, emerging processes to be relevant, you are welcome to comment on this as well. 
  • O18 Cement/Hydraulic binder (global warming potential). Input on the proposed requirement is most welcome.
  • O31 Metal packaging (prohibition of metal packaging). Input on the proposed ban is most welcome.
  • O32 Recycled material in hard plastic packaging. Input on the proposed percentage is most welcome.
  • O33 Recycled material in flexible bags and pouches. Input on the proposed percentage is most welcome.
  • O4 Environmentally harmful substances (updated calculation formula and new limit value).
  • O5 Preservatives (limit value lowered for outdoor and industrial paints).
  • O6 Formaldehyde (indoor emission requirement).
  • O12 Prohibited substances (Endocrine disruptor lists I, II and III and bisphenol restriction.
  • O13 Emissions of Volatile and Semi-Volatile Organic Compounds in indoor paints and varnishes.
  • O14 Content of Volatile and Semi-volatile Organic Compounds in outdoor paints and varnishes and industrial paints.
  • O16 Acrylic resins. Requirements on renewable raw materials including a ban on palm oil and PFAD.
  • O17 Alkyd resins. Requirements on renewable raw materials including a ban on palm oil and PFAD.
  • O26 Quality requirements for industrial paints and varnishes for furniture (regarding standards, is the requirement up to date?).
  • O27–O29 Quality requirements for UV-cured applications (are the requirements clear that UV-coatings must fulfil these requirements?).


In addition to the above mentioned, we would also like your comments on the following matters

  • Product group definition, what can be included and what is not considered as a paint or varnish
  • Industrial powder paints (regarding compliance of criteria and interest)
  • UV-curable paints (regarding compliance of criteria and interest)
  • O2 Classification of the product
  • O3 Classification of constituent substances (regarding exemptions)
  • O5 Preservatives (analytical approach of reporting total preservatives as an option)
  • O7 Residual monomers in polymers (vinyl acetate exemption adjusted)
  • O11 Nanomaterials/- particles (new definition according to the EU Commission Recommendation on the Definition of Nanomaterial from 2022. Information if exemption for chemically modified colloidal silica is still needed.)
  • O19–O25 Quality requirements (are the standards still relevant?)
  • O30 Quality requirements for anti-corrosion paints
  • O34 Consumer information (updated information regarding proper waste disposal of unused paints and tools)


Documents for download


Public hearing webinar Friday 9 December at 10:00-11:15 CET

Date and time: Friday 9 December at 10:0011:15 CET.

Place: The webinar will be on Microsoft Teams.

Sign up by e-mail to Thor Hirsch no later than Thursday 8 December at 16:00 CET to get a link to the webinar. E-mail:


Who can provide input?

All people, companies and institutions who are interested in taking part in the development work of Nordic Ecolabelling criteria for Paints and varnishes can provide us with their opinions and comments. We would appreciate if you kindly distribute information about this review to whom it may concern.


How can comments be sent in?

Your input is most valuable to our criteria development. We prefer to receive your answers via mail for each contry.


For further questions, please contact our product specialists


Hamid Ahmadi
E-mail: or


Tove Bræin
E-mail: or


Camilla Kirk Boesena
E-mail: or


Mari Åkerberg
E-mail: or


Birgitta Stefánsdóttir


What happens next?

When the hublic hearing period is complete, the answers will be compiled and evaluated. For this reason, a new revised proposal for criteria will be submitted to the Swedish Ecolabelling Board and the other national committees. On this basis, the Nordic Ecolabelling Board will then decide on new criteria.

Part of the decision document is the summary of all hearaing responses together with answers from Nordic Ecolabelling. The summary will be public and available on the Nordic Swan Ecolabel web page in connection with the publication of the new criteria.

We look forward to receiving your comments no later than 8 February 2023.