Performance-based sustainability requirements under the updated EU Ecolabel framework
Explore what has changed in the new EU Ecolabel framework, the key criteria affecting paint formulations, and why durability, material efficiency, and life-cycle performance now define compliance.
This article provides a technical overview of the new Ecolabel framework, focusing on the aspects that matter most at formulation level.



The new Decision replaces the previous unified approach with three distinct product categories:
This separation reflects a key regulatory acknowledgement: different coating functions require different sustainability metrics.
At the same time, the validity of the new criteria extends until 31 December 2032, setting a clear medium-term regulatory horizon for the industry.
The updated Ecolabel framework evaluates coatings based on how they perform over their entire life cycle, not only on formulation restrictions.
Key principles include:
Lower material consumption per square meter through optimized formulation design.
Coatings must demonstrate resistance to wear, moisture, and degradation, reducing repainting frequency.
Performance during the use phase is explicitly considered, not just production-stage metrics.
Strict control of hazardous substances, including SVHCs, endocrine disruptors, PFAS, phthalates, organotin compounds, and non-film-forming microplastics.
This means sustainability is now assessed as a technical outcome, not a label-driven claim.
Under the new framework, compliance cannot be achieved through administrative adjustments alone.
It requires formulation-level decisions that influence:
In practical terms, coatings that fail prematurely, require frequent maintenance, or rely on high material loadings are increasingly misaligned with Ecolabel objectives.
A key shift in the new Ecolabel is the move away from “what is inside the can” toward what the coating delivers in real conditions.
This includes:
For formulators, this aligns sustainability directly with engineering choices, not marketing language.
This article provides a technical orientation only.
The complete legal text and detailed criteria are available in full through the official EU publication, in all official EU languages:
Understanding the new Ecolabel is the first step.
The next challenge is translating these criteria into practical formulation solutions that deliver compliance through performance.
In upcoming articles, we will examine how specific formulation technologies and material choices can support Ecolabel-oriented coating design, helping chemists meet sustainability targets through measurable technical improvements.
This is where formulation strategy and material selection become critical.
The updated EU Ecolabel framework under Commission Decision (EU) 2025/2607 shifts sustainability from declaration-based compliance to performance-driven evaluation. For coatings chemists, this means that durability, material efficiency, and life-cycle performance are now determined by formulation design, not administrative adjustments.
Understanding the new criteria is the first step. Translating them into real, high-performing coating systems is the next challenge.

