New EU Ecolabel Criteria: Raw-Material Checks for Coating Formulators
A waterborne formulation is not automatically an EU Ecolabel product. Coating buyers working toward the revised criteria need a document request tied to the intended finished coating and actual raw-material grade. Start
A waterborne formulation is not automatically an EU Ecolabel product. Coating buyers working toward the revised criteria need a document request tied to the intended finished coating and actual raw-material grade. Start with the product group and evidence gaps, then evaluate proposed replacements under the same application conditions.
The current change and its scope
The Commission’s 5 February 2026 announcement describes revised paint/varnish criteria valid to 31 December 2032. Decorative, performance and water-based aerosol groups have differentiated criteria. VOC/SVOC, preservative and fitness-for-use checks matter; the voluntary finished-product scheme does not automatically certify each raw material. Source: European Commission — 2026-02-05.
Define the target before asking for an additive alternative
Name the finished-coating group, application, binder/pigment system and assessment criteria in the enquiry. A material described as water-based or low-emission may still leave unanswered composition questions. Ask what information is available for the offered grade and whether it covers the carrier, relevant constituents and document revision. Do not infer an Ecolabel licence from a raw-material description.
Validate composition and application together
A replacement can look acceptable on a generic environmental summary yet behave differently in dispersion, storage or application. Agree the buyer’s sample checks and acceptance criteria alongside the document request. Keep the formulation version and proposed grade identifiable so that an assessment can be traced to the material actually tested. No improvement in coating performance is promised merely because a carrier or additive changes.
| Buyer check | Question to resolve | Evidence to request |
|---|---|---|
| Product group | Intended decorative/performance/aerosol coating | Applicable criteria and intended label route |
| Composition | Actual grade, carrier and relevant constituents | Supplier statement with scope and revision |
| Application | Binder/pigment and process conditions | Agreed sample acceptance plan |
| Change control | Grade or supplier replacement | Updated evidence and formulation/test record |
Connect the assessment to the actual enquiry
Use the MOS coating raw-material categories to identify the appropriate enquiry route. The additives category can support a component-specific request; these catalogue categories do not establish that a particular material or finished paint holds the EU Ecolabel.
Supporting product/category route: Additives for coatings from China: in-house production and international brands. Confirm its exact scope before adding it to the same procurement specification.
Prepare a specific RFQ
Send an RFQ with coating group, application, binder/pigment system, intended market and criteria, current material, sample acceptance needs, quantity and packaging. Request the actual grade’s TDS/SDS and available composition evidence, including the scope of any statement. Confirm performance in your coating and assess finished-product eligibility separately.
Buyer questions
Is EU Ecolabel compulsory for every coating?
It is a voluntary scheme; distinguish a buyer’s label objective from other applicable legal obligations.
Is every waterborne paint automatically eligible?
No. Product-group criteria, composition and fitness-for-use evidence must be assessed.
Does a raw-material category page prove certification?
No. Request actual-grade evidence and assess the finished product separately.
What should a coating-additive RFQ contain?
Specify the coating system, target criteria, current material, document needs, sample checks, quantity and packaging.