---
title: Paints & Coatings — structured data before the mandate
description: No EU digital product passport is mandated for paints yet. Structure your VOC, REACH and CLP data now — so you are ready when one is.
canonical: "https://www.tracepass.eu/paints-coatings"
locale: en
source: "https://www.tracepass.eu/paints-coatings"
---

# Paints & Coatings — structured data before the mandate

> No EU digital product passport is mandated for paints yet. Structure your VOC, REACH and CLP data now — so you are ready when one is.

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.

## Who it's for

Manufacturers and importers of decorative paints, varnishes and vehicle refinishing products placed on the EU market.

## How TracePass helps

- 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.
- Structured and exportable from day one, so if an ESPR delegated act lands for paints you are mapping fields, not starting a data project.

## What the template covers

- 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

## FAQ

### 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.