Esc

Site search arrives with the platform catalogue. Until then, start from one of these:
PVD Environment & Waste 12 min

PVD: Paints Directive (Directive 2004/42/EC), explained

The Paints Directive caps the volatile organic compound content of decorative paints and varnishes and vehicle refinishing products and requires a label with the subcategory, VOC limit and maximum content, binding manufacturers, importers, wholesalers and retailers. Its Phase I limits have applied since 1 January 2007 and the stricter Phase II limits for paints and varnishes since 1 January 2010.

Try the demo with PVD — freeCheck a product against PVD

Free account · no card · opens in the Demo Company

Reviewed 24 September 2026 by Conphora compliance team · Next review 13 March 2027 · Not legal advice

Open the video page →

Who it applies to

Covered by the act

  • Decorative paints and varnishes, that is coatings applied to buildings, their trim and fittings and associated structures for a decorative, functional and protective purpose, listed in the twelve subcategories (a) to (l) of Annex I, point 1.1, aerosols excluded
  • Vehicle refinishing products, listed in the five subcategories (a) to (e) of Annex I, point 2.1, used to coat road vehicles or parts of them as part of vehicle repair, conservation or decoration outside manufacturing installations
  • Anyone who places such a product on the market, that is makes it available to third parties whether in exchange for payment or not; importation into the Union customs territory is itself placing on the market
  • Products that need solvents or other components containing solvents to be added before use: the limit values apply to the VOC content of the product in its ready for use condition

Derived and downstream products

  • A VOC is any organic compound with an initial boiling point of 250 °C or less measured at a standard pressure of 101,3 kPa, and the VOC content is the mass of VOCs in grams per litre in the formulation of the product ready for use; the mass of VOCs that react chemically during drying to become part of the coating does not count towards the VOC content (Art. 2, points 5 and 6)
  • Aerosols are excluded from the paints and varnishes family by the opening words of Annex I, point 1, but aerosols are expressly named in vehicle refinishing subcategory (e), special finishes, and are therefore covered there (Annex I, point 1 and point 2.1(e))
  • The directive does not define economic operator roles and sets no company-size threshold: Article 3(1) is a placing-on-market prohibition that binds whoever makes the product available, and the Commission's implementation report describes the implementing actors as the manufacturers, importers, wholesalers and retailers of paints and varnishes (Art. 2, point 12, Art. 3(1); COM(2013) 704, section 2.1)
  • Products sold for exclusive use in an activity covered by the former Directive 1999/13/EC and carried out in a registered or authorised installation are exempt from the Article 3(1) requirements; since 7 January 2014 that reference is read as Directive 2010/75/EU on industrial emissions, whose Chapter V and Annex VII cover those solvent activities; note that point 13 of Annex VII, Part 1 covers original coating away from the manufacturing line and the coating of trailers, not the repair refinishing that Article 13 of this directive removed from the solvent regime in 2004 (Art. 3(2); Directive 2010/75/EU, Art. 4(1), Art. 56, Art. 81(1) and (3) and Annex VII)
  • For restoration and maintenance of buildings and vintage vehicles designated by the competent authorities as of particular historical and cultural value, Member States may grant individual licences for the sale and purchase of non-compliant products in strictly limited quantities (Art. 3(3))
  • A product that meets the directive circulates freely: Member States may not, on the grounds the directive deals with, prohibit, restrict or prevent the placing on the market of a product that complies in its ready for use condition (Art. 8)
  • The directive is without prejudice to measures, including labelling requirements, taken at Union or national level to protect the health of consumers and workers and their working environment, so the CLP hazard label, REACH restrictions and biocide rules apply alongside it (Art. 1(4) and recitals 12 and 13)

Roles under the act

Manufacturer, formulator or brand owner

The directive defines no economic operator roles: it prohibits the placing on the market, that is making available to third parties whether in exchange for payment or not, of a product in Annex I whose VOC content exceeds the Annex II limit for its subcategory or that does not carry the Article 4 label. The manufacturer or brand owner is the party that formulates the product and therefore fixes its subcategory, its VOC content in the ready for use condition and the wording of its label; the Commission's implementation report treats manufacturers as the first of the implementing actors.

Source · Art. 2, point 12, Art. 3(1) and Art. 4Source · section 2.1
Importer bringing products into the Union

Whoever brings a product listed in Annex I into the Union customs territory: importation into the customs territory is deemed placing on the market for the purposes of the directive, so the importer is caught by the Article 3(1) prohibition and the Article 4 label duty on its own account. In Denmark the import of a product without the required label is prohibited in terms.

Source · Art. 2, point 12, and Art. 3(1)Source · § 4
Wholesaler, retailer or builders merchant

Anyone further down the chain who makes the product available to third parties, with or without payment, and is therefore placing it on the market within the meaning of the directive. The Commission's implementation report records that the wholesale and retail levels are where most label checks and most product samples are taken.

Source · Art. 2, point 12, and Art. 3(1)Source · section 2.2
Professional user: painting contractor, body shop or coating installation

The applicator who buys and uses the product. The directive itself regulates placing on the market rather than use, but the professional user decides whether the Article 3(2) exemption for products sold for exclusive use in a registered or authorised solvent installation applies, mixes the product to its ready for use condition on site, and in Denmark may not use a product that lacks the required subcategory and VOC information.

Source · Art. 3(1), third subparagraph, and Art. 3(2)Source · § 3, stk. 4, and § 4

Selling from outside the EU? Start here →

Does PVD apply to your product?

Three questions, a first answer from the regulation’s own scope rules. No account needed.

The rules behind this check
  1. Paints or varnishes for buildings supplied as aerosols · any · any Not in scope Annex I, point 1 defines paints and varnishes as the products in subcategories (a) to (l), excluding aerosols, so an aerosol decorative paint or varnish for buildings falls outside the VOC limit values and the label duty of this directive. It still has to meet the CLP hazard labelling, the REACH restrictions and the aerosol dispensers rules, and note the exception: aerosols are expressly named in vehicle refinishing subcategory (e), special finishes, so an aerosol special finish for vehicle refinishing is inside the scope with a limit of 840 g/l. Source · Annex I, point 1, Annex I, point 2.1(e), Annex II, section B, and Art. 1(4)
  2. Coatings that are not applied to buildings, their trim and fittings or associated structures, for example the original coating of vehicles on the manufacturing line and general industrial or marine coatings · any · any Not in scope The directive applies only to the products set out in Annex I: coatings applied to buildings, their trim and fittings and associated structures, and vehicle refinishing products used away from manufacturing installations. A coating for general industrial, marine or original-equipment use, including the original coating of road vehicles on the manufacturing line, is outside its limit values and label duty; solvent emissions from such installations are instead dealt with by Chapter V of Directive 2010/75/EU on industrial emissions. Source · Art. 1(3), Annex I, points 1 and 2Source · Art. 56 and Annex VII, Part 1
  3. Products sold for exclusive use in a solvent activity carried out in a registered or authorised installation · any · any It depends Member States must exempt from the requirements of Article 3(1), the VOC limit values and the Article 4 label, products sold for exclusive use in an activity covered by the former Directive 1999/13/EC and carried out in an installation registered or authorised under that directive, read since 7 January 2014 as Directive 2010/75/EU, whose Article 4(1) allows a permit or a registration procedure for installations covered only by Chapter V. The exemption turns on exclusivity: the same product sold for general use is not exempt. Denmark transposed the derogation narrowly: § 3, stk. 4 of its order disapplies only 'bestemmelserne i stk. 1-3', that is the marketing prohibition, the analytical methods and the ready-for-use rule of § 3, and does not name § 4. The Danish condition is concrete: § 3, stk. 4 exempts only products sold exclusively for use in an activity covered by executive order nr. 1491 of 7 December 2015 on installations and activities using organic solvents, carried out in an installation notified under that order or authorised as a listed activity under the approval order. A product sold for an installation that is neither notified nor authorised stays within § 3. On that reading the ban in § 4 on importing, selling or using an unlabelled product survives the derogation, and the safe course in Denmark is to label these products anyway. The point is not settled: § 4 bites on products 'omfattet af § 3', so a reader who takes § 3, stk. 4 to lift those products out of § 3 altogether would take them out of § 4 with it, and Article 3(2) of the directive obliges Member States to exempt such products from the requirements of Article 3(1), which include Article 4. Take Danish advice before relying on the narrow reading in either direction. Source · § 3, stk. 4Source · title and § 1Source · Art. 3(2)Source · Art. 4(1), Art. 56 and Art. 81(1) and (3)Source · § 3, stk. 4, and § 4
  4. Products supplied under an individual licence for the restoration or maintenance of buildings or vintage vehicles of particular historical and cultural value · any · any It depends For the restoration and maintenance of buildings and vintage vehicles designated by the competent authorities as of particular historical and cultural value, a Member State may grant individual licences for the sale and purchase, in strictly limited quantities, of products that do not meet the Annex II limit values. This is a discretionary national licence, not an automatic exemption; in Denmark Miljøstyrelsen issues it, and breaching a condition of the licence is a criminal offence. Source · Art. 3(3)Source · § 5 and § 7, stk. 1, nr. 3
  5. Matt or glossy coatings for interior walls and ceilings, Annex I subcategories (a) and (b), Coatings for exterior walls of mineral substrate such as masonry, brick or stucco, subcategory (c), Interior or exterior trim and cladding paints for wood, metal or plastic producing an opaque film, including undercoats and intermediate coatings, subcategory (d), Interior or exterior trim varnishes and woodstains, including opaque woodstains and minimal build woodstains, subcategories (e) and (f), Primers with sealing or blocking properties and binding primers for wood, walls and ceilings, subcategories (g) and (h), One-pack and two-pack performance coatings, for example floor coatings, anticorrosion finishes, flame-retardant and graffiti-resistant coatings and primers for plastics or reactive metals, subcategories (i) and (j), Multicoloured coatings and decorative effect coatings, subcategories (k) and (l), Vehicle refinishing products: preparatory and cleaning products, bodyfiller or stopper, primers, topcoats and special finishes used to repair, conserve or decorate road vehicles away from the manufacturing line · Manufacturer, formulator or brand owner, Importer bringing products into the Union, Wholesaler, retailer or builders merchant · any In scope A product in one of the Annex I subcategories may be placed on the market only if its VOC content in the ready for use condition does not exceed the limit value for that subcategory in Annex II, established with an Annex III method, and only if it carries a label stating the subcategory, the relevant VOC limit value in g/l and the maximum VOC content in g/l of the product ready for use. Paints and varnishes are on the Phase II values that have applied since 1 January 2010, from 30 g/l to 750 g/l depending on subcategory and on whether the coating is water-borne or solvent-borne; vehicle refinishing products are on the Annex II section B values of 200 g/l to 850 g/l that have applied since 1 January 2007. There is no company-size threshold and no exemption for small volumes. Source · Art. 3(1), Art. 4, Annex I, Annex II and Annex III
  6. Matt or glossy coatings for interior walls and ceilings, Annex I subcategories (a) and (b), Coatings for exterior walls of mineral substrate such as masonry, brick or stucco, subcategory (c), Interior or exterior trim and cladding paints for wood, metal or plastic producing an opaque film, including undercoats and intermediate coatings, subcategory (d), Interior or exterior trim varnishes and woodstains, including opaque woodstains and minimal build woodstains, subcategories (e) and (f), Primers with sealing or blocking properties and binding primers for wood, walls and ceilings, subcategories (g) and (h), One-pack and two-pack performance coatings, for example floor coatings, anticorrosion finishes, flame-retardant and graffiti-resistant coatings and primers for plastics or reactive metals, subcategories (i) and (j), Multicoloured coatings and decorative effect coatings, subcategories (k) and (l), Vehicle refinishing products: preparatory and cleaning products, bodyfiller or stopper, primers, topcoats and special finishes used to repair, conserve or decorate road vehicles away from the manufacturing line · Professional user: painting contractor, body shop or coating installation · any It depends The directive's prohibition bites on placing on the market rather than on use, so a painting contractor or body shop is not directly bound by the Annex II limits for products it only applies. Three things still reach the professional user: where solvents or other components containing solvents are added before use, the limit value applies to the mixture in its ready for use condition, so on-site thinning must not take the product over the limit; buying products for exclusive use in an installation registered or authorised for an activity in Part 1 of Annex VII to Directive 2010/75/EU triggers the Article 3(2) exemption, but point 13 of that Part, vehicle refinishing, covers only the original coating of road vehicles or parts of them away from the manufacturing line and the coating of trailers, above 0,5 tonnes of solvent a year under item 6 of Part 2, and not the repair refinishing a body shop does, which Article 13 of the Paints Directive removed from the solvent regime in 2004; and in Denmark the use of a product without the required subcategory and VOC information is prohibited in its own right. Source · Art. 3(1), third subparagraph, and Art. 3(2)Source · Art. 4(1), Art. 56, Annex VII, Part 1, point 13, and Part 2, item 6Source · § 4
  7. any · any · any It depends Whether the directive applies turns on whether the product is one of the seventeen subcategories set out in Annex I, whether it is an aerosol, whether it is sold exclusively for use in a registered or authorised solvent installation or under a heritage licence, and on whether you are placing it on the market or only using it. Source · Art. 1(3), Art. 3 and Annex I

Key dates

  1. Directive 2004/42/EC enters into force on the day of its publication in OJ L 143 of 30 April 2004 Source · Art. 15Source
  2. Deadline for Member States to designate the competent authority responsible for fulfilling the obligations under the directive and to inform the Commission of it Source · Art. 5
  3. Transposition deadline: Member States bring into force the laws, regulations and administrative provisions necessary to comply with the directive, and notify their rules on penalties to the Commission by the same date Source · Art. 10 and Art. 14(1)
  4. Phase I maximum VOC content limit values apply to the twelve paint and varnish subcategories of Annex II section A, the single set of limit values applies to the five vehicle refinishing subcategories of Annex II section B, and the subcategory and VOC label of Article 4 becomes mandatory Source · Art. 3(1), Art. 4 and Annex II, sections A and B
  5. Last day on which products shown to have been produced before 1 January 2007 and not meeting the Phase I limits may be placed on the market, the 12-month period running from the date the requirement came into force Source · Art. 3(4)
  6. Regulation (EC) No 1137/2008 enters into force, replacing Article 11 and Article 12(3) so that Annex III is adapted to technical progress under the regulatory procedure with scrutiny Source · Annex, point 4.11
  7. Directive 2008/112/EC enters into force, replacing the word preparation with mixture in Article 2, points 3 and 8, to align the directive with Regulation (EC) No 1272/2008 on classification, labelling and packaging; Member States had to adopt the national measures by 1 April 2010 and apply them from 1 June 2010 Source · Art. 6, Art. 7(1) and Art. 8
  8. Phase II maximum VOC content limit values apply to the twelve paint and varnish subcategories of Annex II section A; the vehicle refinishing limit values of section B are not changed and stay at their 2007 level Source · Annex II, sections A and B
  9. Commission Directive 2010/79/EU enters into force, replacing Annex III with the test methods ISO 11890-2 of 2006, ISO 11890-1 of 2007 and ASTM D 2369 of 2003; Member States had to transpose it by 10 June 2012 Source · Art. 1, Art. 2(1), Art. 3 and the Annex
  10. Last day on which products shown to have been produced before 1 January 2010 and not meeting the Phase II limits may be placed on the market Source · Art. 3(4)
  11. Directive 1999/13/EC on solvent emissions from installations, which Article 3(2) of the Paints Directive refers to and which Article 13 of the Paints Directive amended, is repealed by Directive 2010/75/EU on industrial emissions; references to it are construed as references to that directive, whose Chapter V and Annex VII now govern solvent activities. EUR-Lex records Article 13 of the Paints Directive as itself partly repealed by that directive with effect from the same date, its end of validity being 6 January 2014, since the provision it amended no longer exists. Source · Art. 81(1) and (3), Art. 56 and Annex VII, Part 1, point 13
  12. Danish executive order nr. 1369 of 25 November 2015 on the marketing and labelling of volatile organic compounds in certain paints and varnishes and vehicle refinishing products enters into force, replacing order nr. 1049 of 27 October 2005 Source · § 8
  13. Directive 2001/81/EC on national emission ceilings, the act recital 1 and Article 9(1) of the Paints Directive build on, is repealed by Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants, with its Articles 1 and 4 and Annex I continuing to apply until 31 December 2019 Source · Art. 21(1)
  14. Regulation (EU) 2019/1243 applies: Article 11 becomes a delegated-act empowerment to amend Annex III, Article 11a on the exercise of the delegation is inserted with a five-year tacitly renewable delegation from 26 July 2019, and Article 12(3) is deleted Source · Annex, point 3
  15. Regulation (EU) 2018/858 repeals Directive 2007/46/EC, which had itself repealed Directive 70/156/EEC from 29 April 2009; the reference to road vehicles as defined in Directive 70/156/EEC in Annex I, point 2 of the Paints Directive is therefore read as a reference to Regulation (EU) 2018/858 Source · Art. 88Source · Art. 49
  16. Regulation (EU) 2019/1020 applies: Articles 6 and 7 of the directive, the national monitoring programme and the reporting duty, are deleted, and the directive becomes point 17 of Annex I to that regulation, so its market surveillance powers cover these products; Article 4 of the regulation does not apply, because Article 4(5) does not list the directive Source · Art. 2(1), Art. 4(5), Art. 38, Art. 44 and Annex I, point 17

What you must do

Obligations by role

Manufacturer, formulator or brand owner6
  • Classify every product into exactly one Annex I subcategory: one of the twelve paint and varnish subcategories (a) matt interior wall and ceiling coatings, (b) glossy interior wall and ceiling coatings, (c) exterior mineral wall coatings, (d) interior or exterior trim and cladding paints, (e) trim varnishes and woodstains, (f) minimal build woodstains, (g) primers, (h) binding primers, (i) one-pack performance coatings, (j) two-pack performance coatings, (k) multicoloured coatings and (l) decorative effect coatings, or one of the five vehicle refinishing subcategories (a) preparatory and cleaning, (b) bodyfiller or stopper, (c) primer, (d) topcoat and (e) special finishes. The subcategory decides both the limit value and the label. Annex I, points 1.1 and 2.1
  • Keep the VOC content of the product in its ready for use condition at or below the Annex II limit value for its subcategory, distinguishing water-borne coatings, whose viscosity is adjusted with water, from solvent-borne coatings, whose viscosity is adjusted with organic solvent, because the two carry different limits in eleven of the twelve paint and varnish subcategories. Art. 2, points 10 and 11, Art. 3(1) and Annex II, section A
  • Where solvents or other components containing solvents have to be added for the product to be ready for use, design the mixing ratio so that the limit value is met by the product in its ready for use condition, not by the concentrate in the tin. Art. 3(1), third subparagraph
  • Determine the VOC content with an Annex III method: ISO 11890-2 of 2006 for products below 15 % VOC by mass where reactive diluents are not present, ISO 11890-1 of 2007 or ISO 11890-2 of 2006 at or above 15 % by mass where reactive diluents are not present, and ASTM D 2369 of 2003 where reactive diluents are present. Remember that VOC which react chemically during drying to form part of the coating are not counted, and that for vehicle refinishing products other than subcategory (a) any water content of the ready for use product is discounted. Art. 2, point 6, Art. 3(1), Annex II, section B, footnote, and Annex III
  • Label every product with the subcategory of the product and the relevant VOC limit values in g/l as referred to in Annex II, and the maximum content of VOC in g/l of the product in a ready to use condition. Both elements are mandatory; the limit value on the label is the EU phase limit for that subcategory, not the measured content. Art. 4
  • Apply for an individual licence from the competent authority before supplying a product that exceeds its limit value for the restoration or maintenance of a building or vintage vehicle designated as of particular historical and cultural value, and keep the supply within the strictly limited quantities the licence allows; in Denmark Miljøstyrelsen grants these licences. Art. 3(3)§ 5
Importer bringing products into the Union5
  • Treat import as placing on the market: importation into the Union customs territory is deemed placing on the market under the directive, so the prohibition on over-limit products and the label duty bite on the importer directly and cannot be passed back to a non-EU supplier. Art. 2, point 12, and Art. 3(1)
  • Obtain from the supplier, before the first shipment, the subcategory assignment and the VOC determination of the product in its ready for use condition, made with one of the Annex III methods, because compliance with the Annex II limit values is established with those methods and with no other. Art. 3(1) and Annex III
  • Check the label before the goods are released: it must name the subcategory, the relevant Annex II VOC limit values in g/l and the maximum VOC content in g/l of the product ready for use. Neither Article 4 nor the Danish executive order sets a language rule for that information, but the hazard information the same tin carries under Regulation (EC) No 1272/2008 must be in the language of the Member State of sale, so plan the artwork for the market's language in any case. Art. 4
  • Do not rely on the solvent-installation exemption for general stock: it covers only products sold for exclusive use in an activity carried out in a registered or authorised installation, and in Denmark § 3, stk. 4 lifts only the rules in § 3, stk. 1-3, so on the better reading the labelling ban in § 4 stays intact. Art. 3(2)§ 3, stk. 4, and § 4
  • In Denmark, note that the national order bans the import, the sale and the use of an unlabelled product, so an unlabelled consignment is unlawful at the border and not only at the point of sale. § 4
Wholesaler, retailer or builders merchant2
  • Supply only products whose VOC content is within the Annex II limit for their subcategory: making a product available to third parties, whether in exchange for payment or not, is placing it on the market, so a wholesaler, builders merchant or retailer is covered by the prohibition on its own account. Art. 2, point 12, and Art. 3(1)
  • Check on goods-in that every tin carries the subcategory, the relevant Annex II limit value in g/l and the maximum VOC content in g/l of the product ready for use, and that the stated content is at or below the stated limit; a mislabelled product can be challenged even where its actual content would have been acceptable. Art. 4

PVD in plain terms

The Paints Directive, sometimes called the VOC Directive or the Decopaint Directive, formally Directive 2004/42/EC, is the EU law that caps how much solvent a decorative coating or a vehicle refinishing product may contain. Its purpose is to limit the total content of volatile organic compounds in certain paints and varnishes and vehicle refinishing products in order to prevent or reduce air pollution resulting from the contribution of VOCs to the formation of tropospheric ozone, and to do that by approximating the technical specifications for those products (Art. 1(1) and (2)). A VOC is any organic compound with an initial boiling point of 250 °C or less measured at a standard pressure of 101,3 kPa, and the VOC content is the mass of volatile organic compounds, in grams per litre, in the formulation of the product in its ready to use condition; VOCs that react chemically during drying to form part of the coating do not count towards it (Art. 2, points 5 and 6).

The directive works as a placing-on-market control rather than an emissions permit. Member States must ensure that the products set out in Annex I are placed on their market only if the VOC content does not exceed the Annex II limit value for the product’s subcategory and the product complies with the labelling article; placing on the market means making available to third parties, whether in exchange for payment or not, and importation into the Union customs territory is deemed placing on the market (Art. 2, point 12, and Art. 3(1)). A product that complies in its ready for use condition circulates freely: Member States may not, on the grounds the directive deals with, prohibit, restrict or prevent its placing on the market (Art. 8). The directive also complements rather than replaces the chemicals rules, because it does not prejudice or affect measures, including labelling requirements, taken at Union or national level to protect the health of consumers and workers and their working environment (Art. 1(4)).

The 2004 text was written as a source-specific complement to the national emission ceilings for VOCs then set by Directive 2001/81/EC, since the VOC content of paints, varnishes and vehicle refinishing products gives rise to significant emissions that contribute to the local and transboundary formation of photochemical oxidants (recitals 1 to 7). It entered into force on the day of its publication, 30 April 2004, Member States had to designate a competent authority by 30 April 2005 and transpose the directive by 30 October 2005, and the limit values applied from the dates in Annex II (Art. 5, Art. 14(1) and Art. 15). Directive 2001/81/EC was itself repealed from 1 July 2018 by Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants, so the ceilings the directive supports are now that act’s national reduction commitments.

Scope

Annex I defines the scope in two parts. Paints and varnishes means the products in the twelve subcategories (a) to (l) of point 1.1, excluding aerosols: coatings applied to buildings, their trim and fittings and associated structures for a decorative, functional and protective purpose. The twelve are matt coatings for interior walls and ceilings with a degree of gloss of 25 at 60 degrees or less; glossy coatings for interior walls and ceilings above that gloss; coatings for exterior walls of mineral substrate, that is masonry, brick or stucco; interior and exterior trim and cladding paints for wood, metal or plastic producing an opaque film, including undercoats and intermediate coatings; interior and exterior trim varnishes and woodstains producing a transparent or semi-transparent film, including opaque woodstains as defined in EN 927-1 within the semi-stable category; minimal build woodstains with a mean thickness of less than 5 micrometres tested to ISO 2808:1997, method 5A; primers with sealing or blocking properties for wood, walls and ceilings; binding primers that stabilise loose substrate particles, impart hydrophobic properties or protect wood against blue stain; one-pack performance coatings for applications requiring special performance such as floor coatings, anticorrosion finishes, graffiti resistance, flame retardancy and hygiene standards in the food, drink or health sectors; two-pack performance coatings with the same use but a second component added before application; multicoloured coatings giving a two-tone or multiple-colour effect directly from the primary application; and decorative effect coatings giving special aesthetic effects over prepared pre-painted substrates or base coats.

Vehicle refinishing products means the products in the five subcategories (a) to (e) of point 2.1, used for the coating of road vehicles, or parts of them, carried out as part of vehicle repair, conservation or decoration outside of manufacturing installations. They are preparatory and cleaning products, including gunwash, paint strippers, degreasers, silicone removers and pre-cleaners; bodyfiller or stopper, the heavy-bodied compounds that fill deep surface imperfections; primer, with the sub-types surfacer or filler, general metal primer and wash primer containing at least 0,5 % by weight of phosphoric acid; topcoat, including base coatings and clear coatings; and special finishes such as metallic or pearl effects, anti-scratch and fluorinated clear coats, reflective base coats, texture finishes, anti-slip coatings, under-body sealers, anti-chip coatings, interior finishes and aerosols. The reference in point 2 to road vehicles as defined in Directive 70/156/EEC is read against Regulation (EU) 2018/858, because Directive 70/156/EEC was repealed by Directive 2007/46/EC from 29 April 2009 and that directive by Regulation (EU) 2018/858 from 1 September 2020, with references construed as references to the later act.

Two boundaries are easy to get wrong. Aerosols are excluded from the paints and varnishes family by the opening words of Annex I, point 1, but they are expressly named in vehicle refinishing subcategory (e), so an aerosol special finish for body-shop work is inside the scope with a limit of 840 g/l while an aerosol decorative spray paint for a wall is outside it. And coatings applied outside the two families, notably the original coating of vehicles on the manufacturing line and general industrial coatings, are not covered here at all; solvent emissions from those installations are dealt with by Chapter V and Annex VII of Directive 2010/75/EU on industrial emissions.

The directive names no economic operator roles and sets no company-size threshold. The prohibition attaches to placing on the market, so it reaches the manufacturer, the importer, the wholesaler and the retailer alike, which is how the Commission describes the implementing actors in its implementation report.

What you must do

Classify the product into one subcategory

Every in-scope product belongs to exactly one of the seventeen subcategories, and the subcategory decides both the limit value and the wording of the label (Annex I, points 1.1 and 2.1). For paints and varnishes you must also record whether the coating is water-borne, its viscosity adjusted by the use of water, or solvent-borne, its viscosity adjusted by the use of organic solvent, because eleven of the twelve subcategories carry different limits for the two types (Art. 2, points 10 and 11). The Commission’s report found that most of the products that broke both the VOC limits and the labelling rules in 2010 sat in subcategory (d), interior and exterior trim and cladding paints, and that three further subcategories were reported non-compliant on both counts: (a) matt interior wall and ceiling coatings, (e) trim varnishes and woodstains and (i) one-pack performance coatings. The report does not rank those three against each other, but together with (d) they mark where classification and formulation most often go wrong.

Stay within the limit value

Annex II, section A sets the two phases for paints and varnishes in grams per litre of ready to use product. The Phase I values applied from 1 January 2007, the stricter Phase II values from 1 January 2010. Under Phase II, matt interior wall and ceiling coatings are capped at 30 g/l in both water-borne and solvent-borne form; glossy interior wall and ceiling coatings at 100 g/l in both; exterior mineral wall coatings at 40 g/l water-borne and 430 g/l solvent-borne; trim and cladding paints at 130 and 300 g/l; trim varnishes and woodstains at 130 and 400 g/l; minimal build woodstains at 130 and 700 g/l; primers at 30 and 350 g/l; binding primers at 30 and 750 g/l; one-pack performance coatings at 140 and 500 g/l; two-pack reactive performance coatings for specific end uses such as floors at 140 and 500 g/l; multicoloured coatings at 100 g/l in both; and decorative effect coatings at 200 g/l in both. Annex II, section B sets a single set of values for vehicle refinishing products that has applied since 1 January 2007 and has never been changed: 850 g/l for preparatory products and 200 g/l for pre-cleaners, 250 g/l for bodyfiller or stopper of all types, 540 g/l for surfacer, filler and general metal primer and 780 g/l for wash primer, 420 g/l for topcoats of all types and 840 g/l for special finishes of all types. Except in the preparatory and cleaning subcategory, any water content of the ready for use vehicle refinishing product is discounted.

For products to which solvents or other components containing solvents have to be added before the product is ready for use, the limit applies to the VOC content in the ready for use condition (Art. 3(1), third subparagraph). That is the rule that catches two-pack systems, on-site thinning and spray-gun dilution: the concentrate in the tin is not the figure the authority measures against.

Determine the VOC content

Compliance with the Annex II limits is established with the methods in Annex III and with no others (Art. 3(1)). Since Commission Directive 2010/79/EU replaced that annex, three method blocks apply. For products with a VOC content below 15 % by mass where reactive diluents are not present, the permitted method is ISO 11890-2 of 2006. At or above 15 % by mass where reactive diluents are not present, either ISO 11890-1 of 2007 or ISO 11890-2 of 2006 may be used, the simpler and less expensive ISO 11890-1 having been added in 2010 precisely to reduce testing costs. Where reactive diluents are present, the method is ASTM D 2369 of 2003. Since 26 July 2019 the Commission may amend Annex III by delegated act under Article 11 and Article 11a, so the method list can move without a new directive.

Label the product

Every product set out in Annex I must carry a label when it is placed on the market, and the label must indicate the subcategory of the product and the relevant VOC limit values in g/l as referred to in Annex II, and the maximum content of VOC in g/l of the product in a ready to use condition (Art. 4). Both elements are required: the EU limit for the subcategory and the product’s own maximum content, so that an inspector, a downstream user or a buyer can read the subcategory, the applicable limit and the actual content off the tin and check the one against the other. Miljøstyrelsen advises Danish suppliers to place the information clearly and visibly on the label, preferably next to but outside the field carrying the hazard information. Labelling is where enforcement finds most of its problems: in 2010 some 121 000 labels were checked across the Union and 94,2 % were compliant, an improvement on the roughly 20 % breach rate of 2007 but still the weaker half of the regime.

Exemptions and licences

Three carve-outs exist, and each is narrow. First, Member States must exempt from the requirements of Article 3(1) products sold for exclusive use in an activity covered by Directive 1999/13/EC and carried out in a registered or authorised installation according to Articles 3 and 4 of that directive (Art. 3(2)). Directive 1999/13/EC was repealed with effect from 7 January 2014 by Directive 2010/75/EU on industrial emissions, and references to it are construed as references to that directive, so the exemption now points at the solvent activities of Chapter V and Annex VII, but point 13 of Part 1, vehicle refinishing, covers only the original coating of road vehicles or parts of them away from the manufacturing line and the coating of trailers, above 0,5 tonnes of solvent a year under item 6 of Part 2, and not the repair refinishing a body shop does, which Article 13 of the Paints Directive removed from the solvent regime in 2004; Article 4(1) of that directive requires a permit but lets Member States set up a registration procedure for installations covered only by Chapter V. The exemption turns on the word exclusive: the same product sold into general trade is not exempt. Second, for the restoration and maintenance of buildings and vintage vehicles designated by competent authorities as being of particular historical and cultural value, Member States may grant individual licences for the sale and purchase, in strictly limited quantities, of products that do not meet the Annex II limits (Art. 3(3)). Third, products shown to have been produced before a limit value came into force could be placed on the market for 12 months after that date (Art. 3(4)); that transition expired on 31 December 2007 for Phase I and on 31 December 2010 for Phase II and is now spent.

Obligations by role

The manufacturer or brand owner fixes the subcategory, formulates to the limit for the ready for use product, has the content determined by an Annex III method and writes the label. The importer carries the same duties on its own account, because importation into the Union customs territory is deemed placing on the market. The wholesaler and the retailer are also placing the product on the market whenever they make it available to a third party, so they must supply only labelled, within-limit products. The professional user is not the addressee of the prohibition, but decides the mixing ratio that produces the ready for use product, decides whether the exclusive-use exemption applies, and, in Denmark, may not use a product that lacks the required subcategory and VOC information.

Denmark

Denmark transposes the directive through executive order nr. 1369 of 25 November 2015 on the marketing and labelling of volatile organic compounds in certain paints and varnishes and vehicle refinishing products, issued under the chemicals act and in force since 31 December 2015, when it replaced order nr. 1049 of 27 October 2005. Its § 3 repeats the marketing prohibition, the Annex III methods and the ready for use rule, and its § 3, stk. 4 carries the solvent-installation derogation across by reference to the Danish order on installations and activities using organic solvents and the order on the approval of listed activities. Its § 4 goes further than the directive: it forbids the import, the sale and the use of a covered product that does not carry the subcategory with the relevant VOC limit values in g/l and the maximum VOC content in g/l of the ready to use product, and that ban is not lifted by the § 3, stk. 4 derogation. Miljøstyrelsen may grant individual licences for heritage restoration under § 5 and supervises and controls compliance under § 6; the limit values in bilag 2 of the order reproduce Annex II of the directive exactly.

Enforcement and penalties

The directive leaves enforcement to national law: Member States lay down the rules on penalties applicable to infringements of the national provisions adopted under the directive and take the necessary measures to ensure they are implemented, the penalties must be effective, proportionate and dissuasive, and they had to be notified to the Commission by 30 October 2005 with any later amendment notified without delay (Art. 10). Until 2021 the directive also obliged Member States to run a monitoring programme and to report its results and the quantities licensed under Article 3(3) to the Commission (former Art. 6 and Art. 7). Article 38 of Regulation (EU) 2019/1020 deleted both articles, and the directive is instead point 17 of Annex I to that regulation, so from 16 July 2021 the regulation’s market surveillance regime applies: authorities may require documents and information, carry out inspections and take samples, require corrective action, prohibit or restrict the making available of a product and order its withdrawal, recall or destruction. Article 4 of that regulation, which requires an economic operator established in the Union for certain products, does not apply here, because the list in Article 4(5) does not include this directive.

What enforcement looks like in practice is on record. In 2010 the Member States carried out some 4 700 inspections of premises for VOC content or labelling, analysed more than 19 000 paint and varnish samples and checked about 121 000 labels. Compliance with the Phase I limits stood at 98,7 % and with the Phase II limits at 97,46 %. Against the Phase I limits the highest shares of non-compliant samples were found at wholesalers, 2,5 %, and importers, 2,4 %; against the stricter Phase II limits importers were highest at 6 %. The most common sanction for exceeding a VOC limit was withdrawal of the product from the market; a breach of the labelling requirements was most often met with an order to correct the mistake within a set period in order to avoid prosecution or financial penalties.

In Denmark, executive order nr. 1369/2015 § 7 punishes with a fine whoever breaches the marketing prohibition in § 3, stk. 1 or the import, sale and use ban in § 4, fails to use the analytical methods referred to in § 3, stk. 2, or breaches a condition of a licence under § 5. The penalty rises to imprisonment of up to 2 years where the breach was intentional or grossly negligent and caused or risked harm to human or livestock life or health, caused or risked damage to the environment, or obtained or was intended to obtain an economic advantage, including through savings, for the offender or another; companies can be held criminally liable under chapter 5 of the criminal code. Behind the order stands the chemicals act, consolidated as LBK nr. 1200 of 25 September 2025: the supervisory authority must have an unlawful situation made lawful unless it is of minor significance, must tell the responsible party to stop the unlawful conduct including the sale, and may order it, at its own expense and immediately or within a deadline, to give subsequent information about the danger and how to prevent it, to remedy what causes the danger, to recall the product from dealers or users and to destroy it safely; dealers and users must hand the product back. The authority may carry out ordered measures at the responsible party’s expense, may destroy or render unusable a product that poses a serious risk without a prior order, may seize unlawful goods, has access to premises and vehicles without a court order and may take samples free of charge, may buy products under a hidden identity, may require sellers using an online interface to send sample copies at their own expense, may order the owner of an online interface to change or remove content referring to unlawful products, and may ask the court to block an online interface, which the court orders only to eliminate a serious risk and only where a § 50 order has not been complied with or where non-compliant products have repeatedly been sold or brokered through the interface, and may publish orders, prohibitions and reprimands with the names of the producers, importers or dealers concerned.

How Conphora helps

Conphora monitors the Paints Directive, the Danish executive order and the acts that now sit behind them, Regulation (EU) 2019/1020 for surveillance and Directive 2010/75/EU for the solvent installations, and maps your coatings against the seventeen Annex I subcategories, the water-borne and solvent-borne split and the Annex II limits for the ready for use product, flagging where a subcategory assignment, a VOC figure or a label does not line up before it becomes an enforcement problem. The platform keeps the test reports made with the Annex III methods, the subcategory decisions and the label artwork together per product and per market, combines the VOC label with the CLP and other labelling your tin also carries, and alerts you when a test method, a national order or the enforcement setup changes.

Sources

This guide is for general information and is not legal advice.

Penalties

Enforced by Each Member State designates a competent authority responsible for fulfilling the obligations under the directive and enforces the national law that transposes it; since 16 July 2021 the directive is point 17 of Annex I to Regulation (EU) 2019/1020, so the market surveillance powers of that regulation apply to these products, while Article 4 of that regulation, the duty to have an economic operator established in the Union, does not, because Article 4(5) does not list the directive. In Denmark the rules are executive order nr. 1369 of 25 November 2015 on the marketing and labelling of volatile organic compounds in certain paints and varnishes and vehicle refinishing products, issued under the chemicals act (kemikalieloven), and Miljøstyrelsen, the Danish Environmental Protection Agency, supervises and controls compliance through its chemicals inspection; Miljøstyrelsen is also the authority that grants the individual licences for heritage restoration. The toolkit is sampling and analysis of products and label checks at manufacturers, importers, wholesalers and retailers, an order to end the unlawful situation, including the sale, orders to inform users of the danger, to remedy it, to recall the product from distributors or users and to destroy it at the responsible party's expense, seizure, a prohibition on import, sale or use where the required information is not supplied, orders to change or remove online content, publication of the orders with the names of the firms involved, and fines that rise to imprisonment of up to 2 years in aggravating circumstances.

Member States lay down the rules on penalties applicable to infringements of the national provisions adopted under the directive and take the necessary measures to ensure they are implemented; the penalties must be effective, proportionate and dissuasive, and had to be notified to the Commission by 30 October 2005, with any later amendment notified without delay. The directive contains no Union safeguard procedure of its own: since 16 July 2021 it is point 17 of Annex I to Regulation (EU) 2019/1020, so the surveillance authorities' powers under that regulation apply, including requiring documents and information, carrying out inspections and taking samples, requiring an economic operator to take corrective action, prohibiting or restricting the making available of a product and ordering its withdrawal, recall or destruction; Article 4 of that regulation, which requires an economic operator established in the Union, does not apply to these products because Article 4(5) does not list the directive. The Commission's second implementation report records that withdrawal of the product from the market was the most common response to a breach of the VOC content limits, while a breach of the labelling requirements was usually met with an order to correct the mistake within a set period in order to avoid prosecution or financial penalties. In Denmark, executive order nr. 1369 of 25 November 2015 punishes with a fine the placing on the market of a product whose VOC content exceeds the limit, the import, sale or use of an unlabelled product, the failure to use the prescribed analytical methods and the breach of a condition in a heritage licence; the fine rises to imprisonment of up to 2 years where the breach was intentional or grossly negligent and caused or risked harm to human or livestock life or health, caused or risked damage to the environment, or obtained or was intended to obtain an economic advantage, and companies can be held criminally liable. Behind the order stands the chemicals act: Miljøstyrelsen must have an unlawful situation made lawful and stop the sale, and may order the responsible party at its own expense to inform users of the danger and how to prevent it, to remedy the cause, to recall the product from distributors or users and to destroy it safely, may carry out ordered measures at that party's expense, may seize unlawful products, may prohibit import, sale or use where the required information is not provided, may order the owner of an online interface to change or remove content that refers to unlawful products, and may ask the court to block an online interface, which the court decides by order and only to eliminate a serious risk, either where an order to change or remove content has not been complied with or where non-compliant products have repeatedly been sold or brokered through that interface, and may publish the orders and prohibitions with the names of the producers, importers or dealers concerned.

Source · Art. 10Source · Art. 2(1), Art. 4(5), Art. 14, Art. 16 and Annex I, point 17Source · section 2.3Source · § 6 and § 7Source · § 45(1), § 47 b, § 48, § 48 a, § 48 b, § 49, § 50, § 50 a, § 59(4) and § 60

What changed

Entry into force, amendments and Compliance Radar entries for PVD, newest first.

  1. Guidance

    Guide rebuilt on the SPEC-62 model from the consolidated directive text

    The guide was rewritten from the consolidated text of 16 July 2021, the five amending acts, Directive 2010/75/EU, Regulation (EU) 2018/858, the Commission's implementation report COM(2013) 704 and the Danish executive order nr. 1369/2015 and chemicals act. The twelve paint and varnish subcategories, the five vehicle refinishing subcategories and the actual Annex II figures replace the earlier generic description; the earlier statement that the label carries the EU phase limit value alongside the maximum content is kept and sourced to Article 4; the earlier claim that distributors merely should ensure labelling is corrected, since making available to third parties is itself placing on the market; the three Annex III test methods replace the earlier reference to analytical or calculation methods; the exemptions in Article 3(2), (3) and (4) are added, with the reference to the repealed Directive 1999/13/EC read as Directive 2010/75/EU and the reference to the repealed Directive 70/156/EEC read as Regulation (EU) 2018/858; and the market surveillance basis is stated as Regulation (EU) 2019/1020 with the note that its Article 4 does not apply here. The Danish section now names executive order nr. 1369 of 25 November 2015, Miljøstyrelsen and the penalty and enforcement provisions of the chemicals act.

    Source · Art. 1 to Art. 4, Art. 8, Art. 10 and Annexes I to III
  2. Amendment

    Regulation (EU) 2019/1020 deletes the monitoring and reporting articles and becomes the surveillance basis

    Article 38 of Regulation (EU) 2019/1020 deletes Articles 6 and 7 of the directive, the duty on Member States to set up a monitoring programme and to report its results and the licensed quantities to the Commission. The directive is point 17 of Annex I to the regulation, so from 16 July 2021 the regulation's market surveillance rules and powers apply to these products; Article 4, the duty to have an economic operator established in the Union, does not apply, because Article 4(5) does not list the directive.

    Source · Art. 2(1), Art. 4(5), Art. 38, Art. 44 and Annex I, point 17
  3. Applies

    Regulation (EU) 2018/858 replaces the vehicle type-approval act the directive refers to

    Annex I, point 2 of the directive defines vehicle refinishing products by reference to road vehicles as defined in Directive 70/156/EEC. That directive was repealed by Directive 2007/46/EC from 29 April 2009, and Directive 2007/46/EC by Regulation (EU) 2018/858 from 1 September 2020, with references construed as references to the later act; the definition of the vehicles covered is therefore read against Regulation (EU) 2018/858.

    Source · Art. 88Source · Art. 49
  4. Amendment

    Regulation (EU) 2019/1243 turns the Annex III empowerment into a delegation

    Article 11 is replaced: the Commission is empowered to adopt delegated acts in accordance with a new Article 11a amending Annex III to adapt it to technical progress. The delegation runs for five years from 26 July 2019 and is tacitly extended for identical periods unless the Parliament or the Council opposes it, with a two-month objection period extendable by two months; Article 12(3) is deleted.

    Source · Annex, point 3
  5. Applies

    Danish executive order nr. 1369/2015 in force

    The order on the marketing and labelling of volatile organic compounds in certain paints and varnishes and vehicle refinishing products replaces order nr. 1049 of 27 October 2005. It repeats the scope, definitions, limit values, test methods and the solvent-installation derogation, forbids the import, sale and use of an unlabelled product, lets Miljøstyrelsen grant heritage licences and supervise compliance, and sets fines rising to imprisonment of up to 2 years in aggravating circumstances.

    Source · § 1 to § 8
  6. Applies

    Directive 1999/13/EC repealed by the Industrial Emissions Directive

    Directive 1999/13/EC on solvent emissions from certain activities and installations, which Article 3(2) of the Paints Directive uses to define the exempt installations and which Article 13 of the Paints Directive amended, is repealed with effect from 7 January 2014 by Directive 2010/75/EU. References to it are construed as references to that directive, whose Chapter V and Annex VII now cover solvent activities, vehicle refinishing being point 13 of Annex VII, Part 1.

    Source · Art. 81(1) and (3) and Annex VII, Part 1, point 13
  7. Amendment

    Commission Directive 2010/79/EU replaces Annex III

    The analytical methods are updated to the revised ISO 11890-2 of 2006 for products below 15 % VOC by mass without reactive diluents, ISO 11890-1 of 2007 or ISO 11890-2 of 2006 at or above 15 % by mass without reactive diluents, and ASTM D 2369 of 2003 where reactive diluents are present. Member States had to transpose it by 10 June 2012.

    Source · Art. 1, Art. 2(1) and the Annex
  8. Applies

    Phase II VOC limit values apply to paints and varnishes

    The stricter Annex II section A values apply from 1 January 2010 to the twelve paint and varnish subcategories, running from 30 g/l to 750 g/l depending on subcategory and on whether the coating is water-borne or solvent-borne. The Annex II section B values for vehicle refinishing products are unchanged. Products shown to have been produced before this date and not meeting the Phase II limits could be placed on the market until 31 December 2010.

    Source · Art. 3(4) and Annex II, sections A and B
  9. Amendment

    Directive 2008/112/EC aligns the definitions with the CLP Regulation

    The word preparation is replaced by mixture in Article 2, point 3, the definition of mixture, and in Article 2, point 8, the definition of coating, so that the directive matches Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures. Member States had to adopt the measures by 1 April 2010 and apply them from 1 June 2010.

    Source · Art. 6 and Art. 7(1)
  10. Amendment

    Regulation (EC) No 1137/2008 adapts the comitology provisions

    Article 11 is replaced so that the Commission adapts Annex III to technical progress under the regulatory procedure with scrutiny, and Article 12(3) is replaced with the reference to Article 5a(1) to (4) and Article 7 of Decision 1999/468/EC. The substantive requirements of the directive are not touched.

    Source · Annex, point 4.11
  11. Applies

    Phase I VOC limit values and the label become mandatory

    From 1 January 2007 the products listed in Annex I may be placed on the market only if their VOC content in the ready for use condition does not exceed the Annex II limit value for their subcategory and they carry the Article 4 label stating the subcategory, the relevant VOC limit value in g/l and the maximum VOC content in g/l. The same date starts the single set of limit values for vehicle refinishing products in Annex II, section B.

    Source · Art. 3(1), Art. 4 and Annex II, sections A and B
  12. In force

    Directive 2004/42/EC enters into force

    Adopted on 21 April 2004 and published in OJ L 143 on 30 April 2004, the directive entered into force on the day of its publication. Member States had to designate their competent authority by 30 April 2005, transpose the directive and notify their penalty rules by 30 October 2005.

    Source · Art. 5, Art. 10, Art. 14(1) and Art. 15

Questions people ask about PVD

Which products does the Paints Directive 2004/42/EC cover?

Two families. First, decorative paints and varnishes: the twelve subcategories of Annex I, point 1.1, which are coatings applied to buildings, their trim and fittings and associated structures for a decorative, functional and protective purpose, namely matt and glossy coatings for interior walls and ceilings, coatings for exterior walls of mineral substrate, interior and exterior trim and cladding paints, trim varnishes and woodstains, minimal build woodstains, primers, binding primers, one-pack and two-pack performance coatings, multicoloured coatings and decorative effect coatings, with aerosols excluded. Second, vehicle refinishing products: the five subcategories of Annex I, point 2.1, which are preparatory and cleaning products, bodyfiller or stopper, primers, topcoats and special finishes used to coat road vehicles or parts of them as part of repair, conservation or decoration outside manufacturing installations, and here aerosols are expressly included in the special finishes subcategory.

Source · Art. 1(3) and Annex I, points 1, 1.1, 2 and 2.1
What are the VOC limit values and when did they start to apply?

Annex II, section A sets two sets of limit values in grams per litre of ready to use product for the twelve paint and varnish subcategories, with separate figures for water-borne and solvent-borne coatings. The Phase I values applied from 1 January 2007 and ranged from 50 g/l to 750 g/l; the stricter Phase II values have applied since 1 January 2010 and range from 30 g/l to 750 g/l: 30 g/l applies to matt interior wall and ceiling coatings in both water-borne and solvent-borne form and to water-borne primers and binding primers, and 750 g/l is the highest value in the table, for solvent-borne binding primers. Annex II, section B sets a single set of values for vehicle refinishing products that applied from 1 January 2007 and has not been changed since: 850 g/l for preparatory products and 200 g/l for pre-cleaners, 250 g/l for bodyfiller or stopper, 540 g/l for surfacer, filler and general metal primer and 780 g/l for wash primer, 420 g/l for topcoats and 840 g/l for special finishes.

Source · Annex II, sections A and B
What exactly has to be on the label?

Two things, on every product in Annex I when it is placed on the market: the subcategory of the product together with the relevant VOC limit values in g/l as referred to in Annex II, and the maximum content of VOC in g/l of the product in a ready to use condition. The limit value on the label is the EU value for that subcategory, so a reader can see at a glance whether the stated content sits at or below it. Miljøstyrelsen's factsheet advises Danish suppliers to place the information clearly and visibly on the label, preferably next to but outside the hazard information field.

Source · Art. 4Source
How is the VOC content measured?

With the methods in Annex III, replaced in 2010 by Commission Directive 2010/79/EU. For products with a VOC content below 15 % by mass where reactive diluents are not present, ISO 11890-2 of 2006 is the permitted method. At or above 15 % by mass where reactive diluents are not present, either ISO 11890-1 of 2007 or ISO 11890-2 of 2006 may be used. Where reactive diluents are present, the method is ASTM D 2369 of 2003. The figure to compare with the limit is the VOC content of the product in its ready for use condition, the mass of VOCs in grams per litre, and VOCs that react chemically during drying to form part of the coating are not counted; for vehicle refinishing products other than the preparatory and cleaning subcategory, any water content of the ready for use product is discounted.

Source · Art. 2, point 6, Art. 3(1), Annex II, section B, footnote, and Annex IIISource · Art. 1 and the Annex
Are there any exemptions from the VOC limits?

Three, and they are narrow. Products sold for exclusive use in an activity covered by the former Directive 1999/13/EC and carried out in a registered or authorised installation are exempt from the requirements of Article 3(1); since 7 January 2014 that reference is read as Directive 2010/75/EU on industrial emissions, whose Chapter V and Annex VII cover those solvent activities. For restoration and maintenance of buildings and vintage vehicles designated by the competent authorities as of particular historical and cultural value, a Member State may grant individual licences for the sale and purchase of non-compliant products in strictly limited quantities. And products shown to have been produced before a limit value came into force could be placed on the market for a further 12 months, a transition that ran out on 31 December 2007 for Phase I and 31 December 2010 for Phase II. Aerosol paints and varnishes for buildings are not an exemption but simply outside the scope of the paints and varnishes family.

Source · Art. 3(2), (3) and (4) and Annex I, point 1Source · Art. 81(1) and (3)
Who enforces the Paints Directive in Denmark and what are the penalties?

Miljøstyrelsen, the Danish Environmental Protection Agency, supervises and controls compliance with executive order nr. 1369 of 25 November 2015, which transposes the directive under the chemicals act; the order also makes Miljøstyrelsen the authority that grants heritage licences. Breaching the marketing ban, the labelling requirement, the duty to use the prescribed analytical methods or a licence condition is punishable by a fine, rising to imprisonment of up to 2 years where the breach was intentional or grossly negligent and caused or risked harm to human or livestock life or health, caused or risked damage to the environment, or obtained or was intended to obtain an economic advantage; companies can be held criminally liable. Under the chemicals act the authority must have an unlawful situation made lawful and stop the sale, and may order information to users, remedial action, recall from distributors or users and destruction at the responsible party's expense, seize the goods, and publish the orders with the firms' names.

Source · § 5, § 6 and § 7Source · § 47 b, § 48, § 48 a, § 48 b and § 60
Has the directive been amended, and is it still in force?

It is still in force and no repeal has been adopted. Five acts have amended it: Regulation (EC) No 1137/2008 and Regulation (EU) 2019/1243 changed only the procedure by which Annex III is adapted to technical progress, first to the regulatory procedure with scrutiny and then to delegated acts; Directive 2008/112/EC replaced the word preparation with mixture in two definitions to align the text with the CLP Regulation; Commission Directive 2010/79/EU replaced Annex III with the current test methods; and Regulation (EU) 2019/1020 deleted Articles 6 and 7, the national monitoring programme and the reporting duty, from 16 July 2021, putting the directive in Annex I to that regulation instead. The VOC limit values in Annex II have never been amended. Four corrigenda are recorded on EUR-Lex; the one of 27 June 2019 concerns the English version and corrected the title from 2004/42/CE to 2004/42/EC, while the others concern the Maltese, Finnish and Spanish versions.

Source · the amendment table and Art. 15Source

Follow PVD — one mail a week when it changes

Corrigenda, guidance, Safety Gate trends and new articles for the regulations you follow. Nothing else.

Updates from Conphora ApS about the regulations and topics you follow — by e-mail, weekly by default. You confirm by e-mail and can unsubscribe in one click. We measure whether our e-mails are opened and which links are used, and you can switch that off on the preferences page. Stored in the EU, never sold. Privacy policy. Free account? Choose notifications there instead.

Related

Related regulations

BattRELVDEUDRONDPPWDWEEE

Sources

  1. Directive 2004/42/EC on VOC emissions from certain paints, varnishes and vehicle refinishing products, consolidated text of 16 July 2021 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02004L0042-20210716
  2. Directive 2004/42/EC as published in OJ L 143, 30 April 2004 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32004L0042
  3. Document information, dates, amendments and corrigenda for CELEX 32004L0042 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32004L0042
  4. Regulation (EC) No 1137/2008 adapting acts to Decision 1999/468/EC, which replaced Article 11 and Article 12(3) (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32008R1137
  5. Directive 2008/112/EC aligning the directive with Regulation (EC) No 1272/2008 on classification, labelling and packaging (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32008L0112
  6. Commission Directive 2010/79/EU adapting Annex III to technical progress (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010L0079
  7. Regulation (EU) 2019/1243 replacing the comitology empowerment with delegated acts (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1243
  8. Regulation (EU) 2019/1020 on market surveillance and compliance of products, which deleted Articles 6 and 7 and lists the directive in Annex I (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020
  9. Regulation (EU) 2019/1020 on market surveillance and compliance of products, consolidated text of 23 May 2024 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1020-20240523
  10. Directive 2010/75/EU on industrial emissions, consolidated text of 4 August 2024, which repealed Directive 1999/13/EC and covers solvent activities in Chapter V and Annex VII (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02010L0075-20240804
  11. Regulation (EU) 2018/858 on the approval and market surveillance of motor vehicles, which replaced Directive 2007/46/EC and, through it, Directive 70/156/EEC (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32018R0858
  12. COM(2013) 704, the Commission's second report on the implementation of the Paints Directive (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52013DC0704
  13. Summary of the directive: emissions of volatile organic compounds in paints, varnishes and vehicle refinishing products (EUR-Lex) https://eur-lex.europa.eu/EN/legal-content/summary/emissions-of-volatile-organic-compounds-in-paints-varnishes-and-vehicle-refinishing-products.html
  14. Bekendtgørelse nr. 1369 af 25. november 2015 om markedsføring og mærkning af flygtige organiske forbindelser i visse malinger og lakker samt produkter til autoreparationslakering (Retsinformation) https://www.retsinformation.dk/eli/lta/2015/1369
  15. Bekendtgørelse af lov om kemikalier, LBK nr. 1200 af 25. september 2025 (Retsinformation) https://www.retsinformation.dk/eli/lta/2025/1200
  16. Faktaark: flygtige organiske forbindelser (VOC) i maling og lak til brug i bygninger (Miljøstyrelsen) https://mst.dk/erhverv/sikker-kemi/kemikalier/regler-og-handlingsplaner/faktaark-om-kemikaliereglerne/faktaark-flygtige-organiske-forbindelser-voc-i-maling-og-lak-til-brug-i-bygninger
  17. Faktaark: flygtige organiske forbindelser (VOC) i produkter til auto-reparationslakering (Miljøstyrelsen) https://mst.dk/erhverv/sikker-kemi/kemikalier/regler-og-handlingsplaner/faktaark-om-kemikaliereglerne/faktaark-flygtige-organiske-forbindelser-voc-i-produkter-til-auto-reparationslakering
  18. Maling, lak og andre produkter til overfladebehandling (Miljøstyrelsen) https://mst.dk/erhverv/sikker-kemi/kemikalier/fokus-paa-saerlige-produkter/maling-lak-og-andre-produkter-til-overfladebehandling

About this guide

Reviewed by
Conphora compliance team, Compliance editors, Conphora
Reviewed
24 September 2026
Next review
13 March 2027

Written from the official text on EUR-Lex and the Commission’s guidance, with a source for every fact. It is not legal advice.

Summary PDF JSON
Cite this page 
Conphora (2026). PVD: Paints Directive (Directive 2004/42/EC), explained. Retrieved 13 October 2026 from https://www.conphora.com/regulations/pvd/
Reviewed
Demo Company

See PVD handled end to end

Thirteen products, the documents retailers ask for, supplier requests and this year's deadlines — a complete, read-only example. Open it with a free account; no card, no trial clock.

Try the demo with PVD — freeCompare plans

Free account · no card · opens in the Demo Company