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Understanding the New EU Ecolabel for Paints and Coatings

Performance-based sustainability requirements under Commission Decision (EU) 2025/2607

Explore the revised EU Ecolabel framework, the criteria affecting paint and coating formulations, and how performance, material efficiency and durability are considered within the applicable assessment framework.

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The sustainability framework for paints and coatings is undergoing a structural update with the adoption of Commission Decision (EU) 2025/2607. The revised EU Ecolabel criteria build on an existing framework that already included formulation controls, declarations and performance/use-efficiency testing, while introducing revised product-group structures and updated criteria.

For formulators and coatings chemists, this update affects not only how products are declared, but how they are technically designed, tested, and validated.

This article provides a technical overview of the new EU Ecolabel framework, focusing on the elements that directly impact formulation strategy and product development.

What Has Changed in the New EU Ecolabel

The new Decision replaces the previous single product group with three distinct categories:

Decorative paints, varnishes, and related products
Performance coatings and related products
Water-based aerosol spray paints

This separation reflects a regulatory acknowledgement that different coating functions require different performance and sustainability metrics.

The new criteria are valid until 31 December 2032, providing a clear medium-term regulatory horizon for the coatings industry.

Article 9 of Commission Decision (EU) 2025/2607 includes transition provisions affecting applications and existing awards. These provisions are distinct from the criteria-validity horizon ending on 31 December 2032 and should be considered with the relevant product group and applicable criteria.

Core Principles Behind the Updated Criteria

The revised EU Ecolabel framework evaluates coatings based on their environmental performance across the product life cycle, with a strong emphasis on efficiency in use and verified technical performance.

Key principles include:

Material efficiency

Applicable product-group criteria may include spreading-rate and performance-related requirements that can inform pigment and filler strategy, including claim-dependent opacity and durability considerations where applicable.

Durability and resistance

Depending on product category, intended use and claims, products may need to demonstrate relevant resistance properties through applicable performance testing. Such criteria can support durability-related considerations but do not by themselves guarantee reduced repainting or maintenance needs, and do not establish measured actual service life or guarantee a service-life outcome.

Efficiency during the use phase

While the framework does not mandate full life-cycle assessments, use-phase impacts are addressed indirectly through performance criteria such as coverage, durability, and resistance properties that influence product longevity.

Health and environmental protection

Applicable product-group criteria address certain substance restrictions and emission requirements, including relevant limits for VOC/SVOC content and indoor air emissions where specified. The scope and conditions depend on the applicable product category and criteria.

Overall, sustainability is assessed through measurable technical outcomes rather than marketing claims or administrative declarations alone.

Performance and Efficiency Requirements at Formulation Level

Under the new EU Ecolabel, compliance requires demonstrated performance through standardized testing. Depending on product category and claims, this includes requirements such as:

Minimum spreading rate to ensure efficient material use
Wet scrub resistance and pigment efficiency for interior paints
Resistance to water, alkali, and moisture
Adhesion to relevant substrates
Accelerated weathering resistance for outdoor products
Abrasion, corrosion resistance, or ecotoxicity testing for performance coatings

These requirements directly influence formulation decisions related to binder selection, pigment loading, extender systems, additives, and overall formulation balance.

Products that fail prematurely, require frequent recoating, or rely on excessive material loadings are increasingly misaligned with EU Ecolabel objectives.

VOCs, Emissions, and Hazardous Substances

Contrary to earlier simplified interpretations of “low-VOC” sustainability, the updated EU Ecolabel maintains strict and differentiated limits for:

VOC and SVOC content in ready-to-use products
VOC emissions to indoor air for indoor decorative products
Formaldehyde emissions and cumulative emission thresholds

The framework includes applicable substance-restriction criteria covering relevant categories such as SVHCs and other specified substances, with scope depending on the applicable product group and criteria.

Compliance therefore requires both formulation control and documented verification through testing and supplier declarations.

What This Means for Coatings Chemists

Under the new framework, EU Ecolabel compliance cannot be achieved through administrative adjustments alone.

Formulation-level decisions must support:

Verified coverage and opacity at lower material consumption
Mechanical and chemical durability under defined test conditions
Resistance to water, weathering, abrasion, or corrosion where applicable
Controlled emissions and restricted substance profiles

Sustainability assessment considers formulation composition together with defined performance, emission and use-related criteria applicable to the product group.

Performance Over Declarations

A key aspect of the updated EU Ecolabel is the continued role of demonstrated performance alongside formulation and declaration requirements.

This includes:

How efficiently the product is used
How intended use and applicable criteria relate to maintaining protective or decorative function
Whether relevant performance criteria may support consideration of downstream impacts, without proving actual service life or life-cycle impact reduction

For formulators, sustainability objectives are linked to engineering and formulation strategy as well as meeting applicable criteria.

From Regulatory Framework to Formulation Strategy

Understanding the updated EU Ecolabel criteria is only the first step.

The real challenge lies in translating these requirements into practical formulation solutions that deliver compliance through measurable technical performance.

In the next article, we move from regulatory interpretation to formulation practice, examining how advanced filler technologies such as 3M™ Glass Bubbles and Ceramic Microspheres can be used to support material efficiency, durability, and use-phase performance under the EU Ecolabel (EU) 2025/2607 framework.

Conclusion

The revised EU Ecolabel framework under Commission Decision (EU) 2025/2607 strengthens the role of performance-based evaluation in sustainability assessment for paints and coatings. Durability, material efficiency, controlled emissions and relevant resistance properties are assessed through applicable criteria, formulation design and testing rather than administrative declarations alone.

For coatings chemists, understanding the criteria is essential. Designing products that meet them through real performance is the next and decisive step.