Chemical Compliance
Intelligence & Solutions
China VOCs Management
Sep 23, 2020
Horace Wang
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1. Introduction

Volatile organic compounds (VOCs) are a kind of organic chemicals that are easy to emit to the air at room temperature. According to the WHO’s definition, organic chemicals with a boiling point between 50℃ and 260℃ at room temperature shall be identified as VOCs. In China, in accordance with the national standards, VOCs refers to

  • Organic compounds that with an initial boiling point lower than or equal to 250 °C at a standard pressure of 101.3kPa, and/or

  • Organic compounds which participate in atmospheric photochemical reactions, or are determined according to relevant regulations.

VOCs are widely present in various products, such as coatings, inks, adhesives and so on. Due to the wide application of these products in modern industries, the pollution problems caused by VOC emissions in the process have become more and more serious.

Most of VOCs are not acutely toxic, but they may have negative long-term effects on human health and provide important precursors for other air pollutants and cause polluting weather such as urban haze, photochemical smog, etc. Considering the long-term impact of VOCs on health and the environment, the Chinese government pays more attention to VOC emissions in recent years and has incorporated its management into many national policies.

2. Background

So far, there are no regulations that specifically focus on VOCs in China. However, there are various governmental efforts to regulate VOC found in policy documents. Examples are given below.

In 2013, China initiated the five-year Air Pollutant Prevention and Control Act Plan, marking the beginning of China's modern atmospheric environment governance, which focused on the management of PM 2.5 and PM 10.

Then, the Three-year Action Plan on Defending Blue Sky was started in 2018; requirements were imposed on SO2 air pollutants, nitrogen oxides, and particulate matters, and also on the volatile organic compounds (VOCs). The three-year Plan prohibits the production and use of solvent-based coatings, inks, and adhesives with high VOCs content in key areas.

Another revision was made to China’s Air Pollution Prevention and Control Law in 2018, in which the formulation of quality standards for products with VOCs, the encouragement for the production and use of low-VOCs solvent, and the requirement for industrial painting enterprises to use low-VOCs coatings were specified.

In 2019, with the issuance of a batch of draft standards on VOCs limits, MEE released the Comprehensive Management Plan for Volatile Organic Compounds in Key Industries to strengthen the guidance on governance of VOCs on June 26. The Plan clarifies the goal to reduce VOC emission by 10% and requires the promotion of low-VOCs coatings in key industries. The detailed information on key industries and key areas are also provided in this Plan.

On 2020 June 24, MEE issued the 2020 Action Plan for VOCs Management, which specifies 10 major measures and the focused key regions and enterprise clusters. The Action plan also includes incentive policies to promote better VOC emissions management. Enterprises that fully use low-VOC raw materials and auxiliary materials that meet the national requirements will be included in a positive list and the government green procurement list.

3. Requirements

China initiated the Three-year Action Plan on Defending Blue Sky in 2018, in which the formulation of the standards to control the emissions of volatile organic compounds (VOCs) was promoted as a priority target of 2019. In 2019 and 2020, about 10 national standards involving VOCs management have been issued or opened for consultation. Here, we will make a brief introduction of the standards released in 2019 and 2020, and explain what are low-VOC products and green products.

3.1 Standards for coatings

Standard No.

Standard Name


GB 30981-2020

Limit of harmful substances of industrial protective coatings

In force

GB/T 38597-2020

Technical requirement for low-volatile-organic-compound content coatings product

In force

GB 18581-2020

Limit of harmful substances of woodenware coatings

In force

GB 18582-2020

Limit of harmful substances of architectural wall coatings

In force

GB 24409-2020

Limit of harmful substances of vehicle coatings

In force

GB 38468-2019

Limit of harmful substances of interior floor coatings

In force

GB 38469-2019

Limit of harmful substances of marine coatings

In force

GB 30981-2014

Limit of harmful substances for anticorrosive coating in steel construction

In force

GB 24613-2009

Limit of harmful substances for toy coatings

In force

GB 24408-2009

Limit of harmful substances for exterior wall coatings in construction

In force

GB 24410-2009

Limit of harmful substances for interior decoration materials and waterborne wood coatings

In force

There are many types of coating products and they are widely used in industry, so the control of VOCs content in these products will greatly benefit the VOCs emission management during the industrial process and air pollutant management. For this reason, a total of 6 mandatory national standards and 1 recommended national standard for VOCs control in the coating have been formulated in 2019 and 2020.

The 6 standards for different types of coating products are similar in content structure. They mainly consist of the terms and definition, product classification, requirements, test methods, inspection rules, packaging marks, and implementation of standards for the tolerances of substances harmful to humans and the environment in corresponding products, etc. These standards also provide VOCs content limits for different kinds of products as mandatory technical requirements, which means that all involved products must meet these requirements before they can be circulated in China.

Besides the mandatory requirements, GB/T 38597-2020 Technical Requirement for Low-volatile-organic-compound-content Coatings Product and GB/T 35602-2017 Green product assessment-Coating material also provide more stringent limits for enterprise to adopt.

As shown in the Table, for the water-based coating for mechanical equipment coating, take the primer as an example, the limit of VOCs content in GB 30981 is 300 g/L, while in GB/T 38597 is 250 g/L, and in GB/T 35602 is 200 g/L. All water-based coatings for mechanical equipment coating as a primer that circulate in China must comply with the limit of 300g/L, and for those meet the limit 250 g/L, they shall be identified as Low-VOCs products, for those meet the limit 200 g/L, they shall be identified as Green products. For enterprises to manufacture or use products with higher quality, the China government will give preferential treatment.

3.2 Standards for other products

Standard No.

Standard Name


GB 38507-2020

Limits of volatile organic compounds (VOCs) in printing ink

To be enforced (Apr 1, 2021)

GB 38508-2020

Limits for volatile organic compounds content in cleaning agents

In force

GB 33372-2020

Limit of volatile organic compound content in adhesives

In force

GB/T 38608-2020

Method for Determination of the Volatile Organic Compounds (VOCs) Content in the Ink

In force

Besides coatings, printing inks, cleaning agents, and adhesives are also main sources of VOC pollutants. GB 38507-2020, GB 38508-2020, and GB 33372-2020 set VOC content limits for printing ink, cleaning agent, and adhesive products. The content of the standards are similar with the standards for coatings as well. The followings are the description of low-VOCs products specified in the 3 standards.

  • For printing inks, the water-based inks, offset inks, energy curing inks, and engraving gravure inks are regarded as low-VOCs ink products;

  • For adhesives, the water-based adhesives and bulk adhesives are regarded as low-VOCs adhesives;

  • For cleaning agents, as long as a water-based cleaning agent or a semi-water-based cleaning agent with a VOC content of less than 100 g/L, it shall be regarded as a low-VOCs cleaning agent.

4. Management Measures

So far, there are no regulations that specifically focuses on VOCs in China. Here, I will introduce the process VOCs control based on GB 37822-2019 Standard for fugitive emission of volatile organic compounds and the source VOCs control based on the promotion of Low-VOC products.

4.1  Fugitive emission management

GB 37822-2019 is devised to enhance the regulation and management of fugitive emission of VOCs. The standard specifies requirements on controlling fugitive emission of VOCs for certain premises, operations, and facilities, including storage, transfer, and transportation of VOCs-containing materials, relevant technical processes, etc.

According to the standard, the monitoring of VOCs emission within and around the boundaries of factories should be practiced in line with the GB 16297-1996 Integrated Emission Standard of Air Pollutants or relevant industry standards, and local authorities of ecology and environment can implement monitoring programs to meet their own needs. GB 37822 enters into effect for all existing facilities from July 1st, 2020.

4.2  Promotion of low-VOCs products

As a recommended standard, in principle, GB/T 38597 is voluntarily implemented by enterprises. However, the recommended standards are required to be enforced for the following three situations:

  • Standards are cited by laws, regulations and rules

  • If enterprises quote the standard

  • If the contract quotes the standards

The government will also take actions to promote Low-VOCs products in enterprises. Speaking at the online 2020 China International Coating Forum held by the National Coating Industry Association, officials from MEE introduced a management framework for coating enterprises based on the implementation of GB/T 38597-2020 and the promotion of low-VOCs coating products.

Specifically, MEE is planning to set up a differentiated management plan based on grading of the enterprises' environmental protection performance and sort enterprises into A, B, C, D  grades. For enterprises in A grade, they can take voluntary measures to reduce emissions and receive less management from the environmental protection administrations. Enterprises with poor performance in daily air pollutant treatment are very likely to face mandatory production cuts or could even be required to stop production if an early warning of heavily polluted weather is issued.

The differentiated management plan will investigate the enterprises’ performance on daily VOC emission control, in which the ratio of low-VOCs coating products they manufactured or used is an important indicator. Under an assumption of MEE, the grading of coating manufactory enterprises might be completed based on the relative proportion of products with low-VOC content.

In this situation, both coating manufacturers and users will prefer to produce or use low-VOC coatings to perform better under the differentiated management plan, which will bring convenience and competitiveness to their business. Although GB/T 38597 is just a voluntary standard anyway, and the differentiated management plan is also only an incentive policy, the compulsory enforcement of GB/T 38597 could be conducted by the local government through the local standards they set, as long as they include the limits in GB/T 38597 in their local standards.

5. Resources

To access the English translations of the standards and the infographics of the limits for VOC content in coating, inks, cleaning agents, and adhesives, please refer to the ChemLinked-VOC page.

[Webinar] Interpretation of VOCs Limited Standards of Coatings, Inks, Adhesives and Cleaning Agents

[News] May 26, 2020, China to Initiate a Summer Action Plan for VOCs Management

[Analysis] Control from the Source – Promotion of Low-VOCs Coating Products

[News] March 17, 2020, Shanghai Announces a Roadmap and Timeline to Control VOC Emissions in Key Industries

[News] March 10, 2020, China Finalizes 7 National Standards for VOCs Control

[News] October 31, 2019, WTO Notifies Members on Nine Chinese National VOCs Management Standards

[News] October 10, 2019, China’s Supervision of VOCs Emissions Critical to Combating Grave Environmental Issues

[Analysis] China's VOC Management and Impact on the Chemical Industry

[News] August 1, 2019, China Jiangxi Publishes VOCs Emission Standard

[News] July 5, 2019, MEE Releases Comprehensive Management Plan for VOCs in Key Industries

[News] June 14, 2019, MEE Rolls out Three National Standards on Emission of Air Pollutants

[News] June 7, 2019, China Opens Public Consultation on Draft Technical Requirement for Low VOC Content Coatings

[News] April 11, 2019, China Works on VOC Limits for Inks

[News] March 22, 2019, MIIT Consults on Two Mandatory National Standards for Coatings