The European Council of the Paint, Printing Ink, and Artist’s Colours Industry (CEPE) has launched a campaign highlighting the threat to the availability of preservatives, which are used to extend the useful life of everyday items such as coatings, inks, cleaning products and personal care items.
The industry is increasingly concerned that the current European Union regulations and review processes are leading to more preservatives being phased out and no new products are being approved to take their place.
Christel Davidson, Managing Director of CEPE said: “The current regulations have created a lengthy and costly system, where manufacturers of preservatives rarely bring new substances to the market. In addition, a new review programme is leading to a reduction in the number of existing preservatives. The situation is now reaching a breaking point.”
Preservatives are important in extending the useful life of products such as consumer paints and inks, which are waterborne. Without preservatives, the presence of water allows micro-organisms (bacteria, yeast, fungi or algae) to grow, causing damage to the coating product in the can or to the finished coated surface.
This would lead to an increase in wasted product and a need for more frequent repainting – directly contradicting the EU’s ‘green’ and ‘circular’ ambitions.
Complex system
The Brussels-based (Belgium) CEPE is urging regulators to amend the requirements of the Biocidal Product Regulation (BPR), which governs authorisation and use of preservatives.
As a first and immediate step, allowing risk assessment at the product authorisation stage should be made possible. This should overall lead to a more holistic approach to impact assessments, contributing to a better decision-making process and avoid de-facto bans.
“The current regulations are simply not fit for purpose, and we face the very real risk of having no preservatives available for key products like paints, printing inks and artists’ colours,” Christel said. “We need action now to make sure that manufacturers can continue to supply existing preservatives, so that our members can continue to make properly preserved paints and inks, while encouraging the innovation and development of new preservatives for the future.”
Since the BPR entered into force, a very complex system has developed. As a consequence, manufacturers of preservatives rarely bring new preservatives to the market. At the same time, there is a safety review mechanism that is reducing the number of existing preservatives that can be used.
The second key issue is that packaging and labelling legislation also contributes to the reduction of available preservatives. When substances receive a harmonised classification (CLP Regulation), specific concentration limits can be set. These limited values can result in a ban of the use in consumer products, such as paints.
Together the BPR and CLP Regulation can eliminate all options to effectively preserve products in the next few years.
Risk assessment
Are there alternative products available? Preserved waterborne paints are safe when used as prescribed by the supplier. For specific applications (for example matt indoor paint), certain paints have become available without preservatives.
However, these are not without drawbacks. These paints require extra care due to their high pH levels and have to be manufactured in a very costly, hygienic setting and are not transferable to general applications.
The CEPE suggests a shift to a broader impact assessment for every substance evaluated under the BPR programme. If the impact assessment discovers no available alternatives, continued use should be allowed.
Risk management measures need to be based on an overall risk assessment instead of a simple alignment with the CLH process. The CLH process uses intrinsic hazards, such as skin-sensitising properties, to define concentration limits and requires the use of warning labels.
However, this does not constitute a safety limit addressing an identified risk. In contrast, the BPR requires an evaluation based on an overall risk assessment and, therefore, should not be simply aligned with the hazard classification limit of the CLH.
When risk assessment is conducted at product level, the assessment takes a holistic view of the product which is most appropriate. It also prevents artificial limitation as when applied at the earlier substance approval.
An in-depth evaluation of the BPR is scheduled for 2025 which can be the basis for further action, feels the CEPE leadership. Given the apparent shortcomings, the preparation for the BPR revision should start as soon as possible in order to bring the review forward.
Coatings have intrinsic sustainability credentials since they protect and extend the lifetime of surfaces and products. In addition, the coatings industry has a long-standing commitment to sustainability, the CEPE stressed.
One of the most significant developments these last years is the shift from solvent-borne to water-borne coatings. This shift is positive, but is only made possible by introducing or increasing the levels of preservatives contained in the coatings, Christel notes. (www.cepe.org).