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China Introduces Regulatory Limits of Harmful Substances in Coating for Consumer Products (Updated on May 30, 2025)

China is introducing new limits of harmful substances in coating of certain consumer products that come into close contact with human body.

Updates: On May 30, 2025, MIIT released the GB 30981.1-2025 Limit of Harmful Substances of Coating Materials - Part 1: Architectural Coatings and GB 30981.2-2025 Limit of Harmful Substances of Coating Materials - Part 2: Industrial Coatings on the National Public Service Platform for Standard Information. The official text will be available in 20 working days. 


China is revising mandatory national standards on the limit of harmful substances in coating. The draft for approval has been released on March 4, 2025 by the Ministry of Industry and Information Technology (MIIT). The standards being revised are: 

The public shall have until March 11, 2025 to solicit their feedback on these proposals. A transition period of 12 months is proposed after the publication of the standards.

The GB 30981.1 is set to merge some of the existing standards on coatings for architectural wall (GB 18582—2020) and interior floor (GB 38468—2019). In parallel, GB 30981.2 shall merge standards on woodenware coating (GB 18581—2020), coating used for toys (GB 24613—2009), vehicle coatings (GB 24409—2020), marine coatings (GB 38469—2019) and industrial protective coatings (GB 30981—2020)

The revision came partially as concerns for excessive lead content in consumer coating is growing. It also appeals to the international call for control of certain substances of high concern and bases on the List of New Pollutants under Priority Management and Control (2023) to make further improvements.  

New requirements for consumer product coatings 

For the first time, this revision is introducing limits of harmful substances in coatings for consumer products that come into close contact with human body.  

This includes coatings that directly contact food like food containers, drinking water tanks, cookware, tableware and coatings for the exterior surfaces of consumer products like toys, furniture, stationery, music instruments, playground equipment, sports equipment, medical devices, wearable accessories, household appliances, mobile phones and digital products, bicycles, etc. 

The specific requirements are established as follows: 

ItemsLimit value
Phthalate content (limited to toy coatings, nitrocellulose solvent-borne wood coatings, and other coatings for consumer products that come into close contact with the human body)≤ 0.1%
Photoinitiator content (limited to radiation curable coatings)≤ 0.1%
Heavy metal content (limited to colored paints, powder coatings, and alkyd varnishes)Lead (Pb)≤ 90mg/kg
Mercury (Hg)≤ 10mg/kg
Soluble element content (limited to colored paints, powder coatings, and alkyd varnishes)Lead (Pb)≤ 90mg/kg
Cadmium (Cd)≤ 75mg/kg
Chromium (Cr)≤ 60mg/kg
Mercury (Hg)≤ 60mg/kg
Antimony (Sb)≤ 60mg/kg
Arsenic (As)
≤ 25mg/kg
Barium (Ba)≤ 1000mg/kg
Selenium (Se)≤ 500mg/kg

In addition, the toy coatings and woodenware coatings should also meet the requirements for other harmful substances like benzene, polycyclic aromatic hydrocarbons (PAHs), methanol as specified in Article 5.2 of GB 30981.2—XXXX. 

New limits of harmful substances in coating

To align with the international regulatory level, the revision is adopting limit values for several harmful substances for industrial coating, including "Total Benzene Compounds Content", "Toluene Content", "SVOC Content", "Formaldehyde Content", "Biocide Content", "Asbestos Content", "Total Free Isocyanate (TDI and HDI) Content", "Total Alkylphenol Ethoxylates (APEO) Content", "Soluble Element [Chromium (Cr)] Content". 

The new limit values for water-borne wall coatings include "SVOC Content", "Total Arsenic (As) Content", "Methylisothiazolinone (MIT) Content". In particular, the "Total Alkylphenol Ethoxylates (APEO) Content" item has been expanded to include the varieties "Octylphenol and Nonylphenol".

Exemptions for special functional coatings

The revision introduces a new definition for "special functional coating",  which refers to a type of high-VOC content coating that, in addition to protection and decoration, possesses one or more special functions and cannot be replaced by environmentally friendly coatings due to technical limitations. Special functional coatings are exempted from the VOC limit values set for industrial coatings. The revision has also inserted a note to identify 10 or more types of special functional coatings. 

To apply for exemption, enterprises need to comply with the corresponding technical requirements specified in its declared quality documents (standards, specifications, or technical agreements). They also need to indicate the VOC content in its application condition on the packaging or in the product manual. 

Issues with accessory materials

Since the implementation of the mandatory national standards for limiting harmful substances in coatings in 2002, only putty used as an accessory material in water-borne wall coatings and woodenware coatings has been regulated.  

The revision is now expanding the regulation scope to include all accessory materials, including color paste, thinner (including for spray paint cleaning), curing agent, paint remover, interface agent, repair paste, joint water, whitening water, slow-drying water, colorant. 

The regulated harmful substances primarily focus on those of greatest concern to the consumer and architectural coatings industries, such as heavy metals, formaldehyde, benzene, halogenated hydrocarbons, polycyclic aromatic hydrocarbons (PAHs), glycol ethers, and ether esters. 

Other important updates of this revision include: 

  • Adjust the definition of "water-borne coating" to "any coating with a water content exceeding 50% (by mass fraction) in its volatile components under application conditions";

  • Add testing methods for newly introduced harmful substances accordingly.

Meanwhile, further regulatory measures on the fluorine coatings (in particular PFAS) have been deliberated during the formulation of this proposed revision. However, due to the lack of comprehensive testing methods and the essential nature of specific fluorine coatings, the revision doesn't specify individual PFAS substances under regulations. Instead, it has focused more on reflecting the product qualitities by limiting the VOC limits for all pre-coated coil coatings and profile coatings that are highly persistent. 

Here are the drafts for approval for GB 30981.1—XXXX and GB 30981.2—XXXX

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