Paints & Coatings — structured data before the mandate
We will say this plainly: there is no EU digital product passport for paints and coatings, and none is scheduled. Directive 2004/42/EC requires a VOC content declaration in g/l on the label and creates no passport, and paints are not in the ESPR first working plan — only a preparatory-study candidate, with a mid-term review in 2028 at the earliest. What TracePass gives you today is your VOC, REACH and CLP data in one structured, exportable place, so the passport is a publish step rather than a project when it arrives.
Our promise
Compliance-ready in 2–4 weeks, without changing your existing systems.
Who this is for
Manufacturers and importers of decorative paints, varnishes and vehicle refinishing products placed on the EU market.
How TracePass helps — Paints & Coatings
Concrete things TracePass does for this category — not a list of what the regulation requires.
SDS PDF extraction: the AI reads sections 1–16 and fills composition, classification, hazard and safe-use fields automatically.
VOC content and the Annex II limit for your product subcategory captured as separate fields, in g/l, including the ready-to-use value that Directive 2004/42/EC Art. 4(1) requires where solvent is added before use.
Every paint-specific field is offered, never mandated. Nothing in the template tells you the law demands a passport field it does not — the only required fields here are the REACH and CLP duties that bind any chemical mixture.
ECHA SVHC candidate list checked at save time — substances flagged automatically with proof of the check.
CLP pictograms + hazard and precautionary statements as enums — exact regulator vocabulary, no typos.
What's in the Paints & Coatings template
75 fields — The fields aren't abstract — here are the groups you'll actually work with:
- VOC content + Annex II limit value (g/l)
- Ready-to-use VOC content where solvent is added
- Product subcategory under Directive 2004/42/EC Annex I
- Paint type, solvent type and coverage
- CLP classification + hazard / precautionary statements
- SVHC disclosure (ECHA Candidate List)
- Substance / mixture identity (CAS / EC / IUPAC) + SDS URL
Questions buyers in this category ask
Do we actually need a digital product passport for paints?
Not today, and we are not going to tell you otherwise. Directive 2004/42/EC requires a VOC content declaration on the label and creates no passport. Paints appear in the ESPR working plan only as a candidate for a preparatory study, with a mid-term review in 2028 at the earliest, so a delegated act before roughly 2030 is unlikely. If a supplier tells you paints need a DPP now, ask them which article says so.
Then why structure the data at all?
Two reasons that pay off before any mandate. Your VOC, REACH and CLP data usually lives across SDS PDFs, spreadsheets and a PIM, and customers — especially public buyers applying green procurement criteria — increasingly ask for it in a form they can consume. Second, when a delegated act does land, the work is mapping existing fields rather than starting a data project under a deadline.
How is the VOC limit handled when solvent is added before use?
As a separate field. Directive 2004/42/EC Article 4(1) states that for products in Annex I to which solvents have to be added to make them ready for use, the Annex II limit applies to the ready-for-use condition. So we capture VOC content, the applicable Annex II limit for your subcategory, and the ready-to-use value as distinct fields rather than collapsing them into one number.
Which fields here are actually required?
Only the ones a real in-force instrument mandates: REACH safety data sheet content, CLP classification and hazard statements, SVHC disclosure, and basic manufacturer identification. Every paint-specific field — VOC values, paint type, solvent type, coverage — is offered and not required, because no instrument currently demands it in a passport. We would rather show you an honest empty field than a fake obligation.
Related product categories
Ready to generate paints & coatings passports?
We're onboarding design partners now. The manufacturers who land first are the ones who move before the deadline pressure — that's our speed advantage and yours.
Reviewed by Malin Ivanov, Managing Director — on