Legislation EU VOC

1. 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)

2. Sector Directive Product VOC limits Private car repair PPD Yes Yes Bus & truck repair PPD New car, trailer & vehicle build <15 tonne solvent p.a. SED No Bus & truck coachwork <15 tonne solvent SED No Light Industrial Coatings SED No Directive 2004/42/CE • The Directive 2004/42/CE applies to:

3. 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.

4. Fixed by Directive 2004/42/CE VOC content limits Some of the PPD product limits are identical or similar to those already fixed in some countries through their implementation of the SED: Subcategory Coatings VOC g/l Preparatory and Cleaning Products Preparatory products Pre-cleaners 850 200 Bodyfillers/Stoppers All types 250 Primers Surfacers / fillers and general (metal) primers Wash primers 540 780 Topcoats (each layer) Basecoats, direct gloss, clearcoats, 3-stage topcoats 420 Special Finishes Aerosols, scratch-resistant clears, interior finishes 840

5. 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.

6. 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.

7. 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)

8. 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