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China is currently undertaking the revision of two mandatory standards related to the limit of harmful substances in coatings. The National Technical Committee on Paints & Pigments of the Standardization Administration of China is leading this effort. The standards being revised are:
GB 30981.1 Limit of Harmful Substances of Coating Materials - Part 1: Architectural Coatings; and
GB 30981.2 Limit of Harmful Substances of Coating Materials - Part 2: Industrial Coatings.
The intention is to merge existing relevant standards into two with some improvements. GB 30981.1 will combine GB 18582-2020 Limit of Harmful Substances of Architectural Wall Coatings and GB 38468-2019 Limit of Harmful Substances of Interior Floor Coatings. Similarly, GB 30981.2 would be a merged revision of the current GB 30981-2020 Limit of Harmful Substances of Industrial Protective Coatings, GB 18581-2020 Limit of Harmful Substances of Woodenware Coatings, GB 24409-2020 Limit of Harmful Substances of Vehicle Coatings, and GB 38469-2019 Limit of Harmful Substances of Marine Coatings.
The finalization and approval of these standards are expected to occur this year. Subsequently, they will be officially released in September 2025 and implemented from February 2026. However, there is a chance that the revision process will be expedited, and implementation may begin as early as the end of 2025.
The revision work of GB 30981.2 commenced in July 2023, which was prompted by public concerns over excessive lead content in consumer coatings. Currently, the fourth draft of GB 30981.2 has been reported to the Ministry of Industry and Information Technology (MIIT) and the China Petroleum and Chemical Industry Federation (CPCIF). While the main content is not expected to change significantly, some minor adjustments may be made based on industry feedback. Below are several notable changes that will impact the industry:
1. Introduce limits for harmful substances in coatings, especially for consumer products in close contact with the human body, toy coatings, and woodenware coatings for furniture.
2. Clarify the definition of waterborne coatings. The draft clearly states that any coating with a water content exceeding 50% (by mass fraction) in its volatile components under application conditions will be considered a waterborne coating. Additionally, when water-based diluents are used to reduce viscosity during application, the organic solvent content in the diluents should be less than 5% (by mass fraction). However, some companies have questioned the reasonableness of the mass fraction setting, and further improvements may be necessary.
3. Add examples and corresponding requirements for accessory materials for industrial coatings. Except for putty, accessory materials will not have volatile organic compound (VOC) content requirements. The VOC limit for waterborne and non-waterborne putties will be provided.
4. Add labeling requirements, which involve marking in the order of product category, subcategory, total lead (Pb) content (self-declaration), and the GB standard number, with explicit indication of whether the coating is intended for scenarios involving close contact with the human body. When a coating product is suitable for multiple uses, separate markings can be applied. For example, electroplating-silver effect coatings can be marked as "solvent-based coating - special functional coating - total (Pb) content <90 mg/kg - GB 30981.2; used in close contact with the human body".
5. Add the definition of special functional coatings. Under the established standards, special functional coatings are exempt from VOC content limitations. However, there is no comprehensive list or identification criteria for special functional coatings. After the revision, coating types may be enumerated in the standards. Coating types not included in the standard can still apply for exemptions from the MIIT, and the Standardization Committee will work with customs authorities to facilitate smooth customs clearance in such cases.
