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

On March 31, 2020, GB/T 38597-2020 Technical Requirement for Low-volatile-organic-compound-content Coatings Product was finally released, which is a milestone in the promotion of low VOC products in China. An additional seven standards were released on March 4, and 2 in December 2019, all the VOC standards that were scheduled to be revised or formulated in 2019 are finalized. (ChemLinked News Ⅰ ^[1])

Many regulations on air pollutant control for the coating industry reference low-VOC coatings, but there was not a specific definition or criteria on whether a coating product is "low-VOC." Many enterprises used to think that water-based coatings are low-VOC coatings, which is not accurate. In this article, I will define low-VOC coatings and detail why a voluntary standard may impact significantly on the industry.

Background

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 ^[2] 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 are 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 ^[3]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.

GB/T 38597-2020 Technical Requirement for Low-volatile-organic-compound-content Coatings Product specifies the requirements, test methods, judgment rules, package marks for low-VOCs coating products, helping fill a major gap in the current regulatory framework.

Introduction to the Standards

The VOC control standards scheduled for release in 2019 include nine mandatory standards on the VOCs limits in different kinds of products and one voluntary standard on the comprehensive requirements for low-VOC coating products, namely GB/T 38597-2020. The English translations of these products are all available on ChemLinked now.

In brief, the nine mandatory standards set the limits of VOCs content in products that the manufactory enterprises must meet, and GB/T 38597-2020 provides stricter requirements for the products based on the mandatory standards to achieve the goal of reducing VOCs emission from the source. As specified in GB/T 38597-2020, "this standard is not intended for the selection of coatings with low VOC content, each type of coating has its specific application requirements," this standard just aims to promote enterprises to adjust products structure and improve the production process to reduce the VOC emissions of upstream and downstream enterprises at the current technical level as far as possible.

The limits for industrial protective coatings for port machinery and chemical machinery are detailed in GB 30981-2020 and compared to GB/T 38597-2020. As shown in Table 1.

Table 1. A Comparison of the Limits in GB 30981-2020 and GB/T 38597-2020

As shown in the Table, the limits for VOC content in GB/T 38597-2020 are lower than those in GB 30981-2020. Only the industrial protective coatings that meet the limits in GB 30981-2020 are permitted to put into the market, and the products meet the limits in GB/T 38597-2020 are allowed to label as “low-VOCs” products.

Of course, to meet the stricter limits in GB/T 38597-2020 means the manufacturers need more advanced production technology and require a higher financial investment. For downstream users, the price of low-VOCs products is higher. So how can the authority persuade the industry to produce and use low-VOCs products and take greater efforts to further improve the environment?

Implementation of the Standard and Impact on the Industry

Speaking at the online 2020 China International Coating Forum ^[4] held by the National Coating Industry Association, Mr. Zhang Haolong and Ms. Ning Miao 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 four grades. For the enterprises in A grade under the Plan, 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. While, as mentioned before, GB/T 38597-2020 is just a voluntary standard anyway, and the differentiated management plan is also only an incentive policy. The compulsory enforcement of GB/T 38597-2020 will be conducted by the local government through the local standards they set.

As we all know, besides the national standards, there are industry standards, group standards, and local standards in China as well. Generally speaking, the other standards shall take stricter measures than the national standards. Of course, no matter what kind of standards, there are mandatory ones and voluntary ones. Promoting local governments, especially the key areas’ governments, to adopt the stricter limits in GB/T 38597-2020 will enable the compulsory local enforcement of the standard. To summarize, the authorities will take both voluntary and compulsory measures to promote the low-VOCs coating products in both manufacturing and using enterprises.

Conclusion

According to the information that has been made public, the 10 VOCs control standards will be gradually implemented from July this year, most of them shall enter into effect this December. For key industries and key areas, the date might be earlier. All in all, it is best for enterprises to complete their own review and take measures to adjust the product structure or improve the production process by next year, so as to increase the production or use ratio of low-VOC content coatings and better face the changes in the market after GB/T 38597-3030 takes effect on February 1, 2021. Stakeholders are suggested to keep focusing on the dynamics of regulations in this field. ChemLinked will also provide the latest information for you.

The following standards are available on ChemLinked now: