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European Council of the Paint, Printing Ink and Artists' Colours Industry

CEPE

CEPE represents the European paint, printing ink, and artists' colors industry in policy matters.

Lobbying Activity

Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

13 Nov 2025 · Upcoming REACH revision The meeting was an opportunity for CEPE to share their expectations and concerns about the expected REACH revision. These comments are detailed in the attached document.

Meeting with Klaus Berend (Director Health and Food Safety)

17 Sept 2025 · Antifouling biocidal products.

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

4 Jun 2025 · Chemicals

Meeting with Vilija Sysaite (Cabinet of Executive Vice-President Stéphane Séjourné)

5 May 2025 · REACH

Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall)

21 Mar 2025 · Chemicals regulation; upcoming REACH revision

Meeting with Giuseppe Casella (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

10 Mar 2025 · Chemicals Industry Package and REACH revision in relation to overall objectives of competitiveness and simplification

Paint industry seeks practical BPA monitoring for storage tanks

8 Mar 2024
Topic — New EU rules restricting bisphenol A in materials that contact food products.
Message — They request expanding definitions to include all pipelines and simplifying monitoring for large storage containers. The group proposes replacing batch testing with recipe verification supported by raw material certificates.12
Why — This change would reduce heavy administrative burdens and prevent long delays in silo maintenance.3
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Paint industry group seeks cuts to chemical reporting requirements

27 Nov 2023
Topic — The Commission initiative seeks to reduce EU reporting burdens by 25 percent.
Message — The organization requests reducing the level of details required for chemical notifications to minimize frequent database updates. They also suggest streamlining microplastic reporting where general estimates would be sufficient.12
Why — This would lower administrative costs by reducing the volume of mandatory database entries.34
Impact — Environmental regulators might lack the granular data needed to assess future regulatory needs.5
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Response to Drinking water - establishing the European Positive Lists of starting substances

14 Nov 2023

We welcome the opportunity to provide feedback on the establishment of the positive list for drinking water contact. CEPE members make coatings that are used inside drinking water steel pipes, as well as coatings that are used in various drinking water equipment such as pumps or valves. CEPE members were compliant with the various national systems that were in place prior to the new Directive. Hence, we welcome the compilation done by ECHA. Our concern is linked to the future management of that positive list with the intention to ask Industry to re-petition for all these substances by close deadlines, for the following reasons: - Downstream users of chemicals like the coating industry do not have the basic toxicological data, it is in the hands of their suppliers. - It is uncertain that the suppliers will be able to meet the proposed deadlines for so many chemicals due to the administrative burden and cost - Unlike REACH, which is proportionate to the tonnage Registrants place on the market, the same toxicological package is expected for all substances and all players - It is unclear that the niche market of drinking water contact will justify them to invest - In addition, the lack of data protection will allow free-riders to stay on the market which is a clear obstacle to justify investment (unlike REACH with the 'no data no market' principle) - The lack of data protection is also hampering innovation. - The only coating technology in place for decades is based on well established epoxy, any new technology would require the petitioning of new substances, which requires time, investment and business certainty A lack of a workable system will lead to significant consequences for the storage and distribution of potable water in Europe. For these reasons, we call for a re-thinking of the management of the positive list.
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Paint industry demands clear chemical limits in building taxonomy

3 May 2023
Topic — This initiative establishes a classification system for sustainable investments in various economic activities.
Message — The industry requests specific concentration limits for chemicals to ensure compliance is practicable for manufacturers. They also want restrictions limited to substances with official harmonized classifications to ensure legal certainty.12
Why — Using existing standards would allow companies to verify compliance with reasonable effort.3
Impact — Environmental advocates lose as stricter chemical restrictions beyond existing laws are scaled back.4
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Paint industry urges digital labelling and longer transition timelines

30 Jan 2023
Topic — The European Commission is revising rules for classifying, labelling, and packaging chemical substances.
Message — CEPE requests authorities reject the proposed amendment and not set new minimum requirements for labels. They call for an ambitious approach allowing label elements in digital formats from the outset. They also recommend setting a minimum of 24 months for all transition periods for mixtures.123
Why — This would lower operational costs and avoid physically impossible labelling requirements for small containers.45
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

19 Dec 2022 · Chemicals strategy implementation; REACH; CLP; transition pathway

Response to European Critical Raw Materials Act

25 Nov 2022

(Please see the attachment for the full statement) CEPE welcomes the initiative for a European Critical Raw Materials Act. Chemicals are key for the well- functioning of various strategic supply chains and should therefore be considered in the act1. CEPE reminds of the severe raw material shortages that started in 20212 and the continued high prices impacting the sector in its ability to supply. The unavailability of the required raw materials is a major problem, as even a single missing ingredient can affect the final product and its subsequent use. Paints, printing inks and artist colors make an essential contribution to the twin challenge of the green and digital transitions Coatings and inks are essential components in meeting the objectives of the EU Green Deal. They are applied on a variety of substrates such as concrete, paper, plaster, wood, plastic, stone and metal for a variety of functions supporting societal needs (e.g. for safety, health and well-being) and sustainability goals (e.g. increasing the service life of the treated objects, reducing waste). Coatings also help reducing energy consumption for cooling by means of reflective paints. Printing inks are needed for all printed products (e.g. books, newspapers, (food) packaging) and are used for education, guidance and safety. A high number of raw materials is needed for our products Coatings and inks manufacturers are downstream users (formulators) of chemical substances. Manufacturers of coatings and inks are not producers of chemicals, but they take chemical substances and formulate them to produce a paint or printing ink for the various applications. Our industry is using the largest number of REACH registered chemicals, with an estimated amount of 4000. Many of these substances are produced outside of the EU which may affect the EUs autonomy. Our suggestions > Include chemicals in the European Critical Raw Materials Act > Strengthen the chemical production in Europe > Include ECHA in the monitoring network of European agencies > Consult with the relevant stakeholders for key raw materials, e.g. titanium dioxide, carbon black > Include chemicals in Free Trade Agreements > Do not overburden R&D with requirements
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Coatings industry warns new hazard classes harm global competitiveness

17 Oct 2022
Topic — The European Commission is revising chemical classification rules to include new hazards.
Message — The industry requests alignment with global rules to avoid significant deviation from consensus-based standards. They call for clearer scientific criteria and adequately long transitional periods for mixtures. CEPE also questions using delegated acts to implement changes of this magnitude.123
Why — Maintaining current standards would protect the pool of suitable raw materials for industry.45
Impact — Environmental groups lose the ability to quickly restrict chemicals linked to endocrine disruption.6
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Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius)

10 Oct 2022 · Implementation of the EU Chemicals Strategy for Sustainability, including upcoming revision of REACH

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Printing Ink Association

10 Oct 2022 · Implementation of the EU Chemicals Strategy for Sustainability, including upcoming revision of REACH

Response to Sustainable Products Initiative

21 Jun 2022

CEPE welcomes the opportunity to comment on the adopted Ecodesign for Sustainable Product Regulation (ESPR) proposal. CEPE finds the following elements to be critical for its industry sectors. • CEPE finds the ESPR proposal a tool for ensuring a level-playing field for certain product categories. • When assessing the performance of products, the sustainability function of the product under scope should be considered. Products such as paint might already fulfill the ESPR goals by enhancing aspects such as durability, resource efficiency, repairability, less material waste, etc. through its use. • There is a lack of policy coherence and the introduction of a new definition of Substance of Concern (SoCs) has no place in ESPR. Hence, Art. 5 should not include additional criteria for hazardous substances as this is already covered by REACH which will be even strengthened by the CSS. • Double regulation should be avoided. For example, paint products covered under ESPR should not be double-regulated in CPR (Construction Product Regulation) as this leads to an unnecessary burden to the industry. • The ESPR does not sufficiently recognize the lack of potential of recycling technologies. Under the reporting of substances hampering recycling (Art. 2, 28c) should consider the fact that the success of a product being recycled is not solely contingent on the presence of substances, it strongly depends on available technologies. Omitting substances without proper assessment of available and innovative technologies will only create a negative impact on the durability of the product, and ultimately on the environment. Similarly, access to local feedstock for including recycled contents and remanufacturing can be challenging as member states handle waste management practices differently. • On the reporting aspects of SoCs no other substances or concentration levels than CLP should be required in the DPP. This should be aligned with the data already available in Safety Data Sheet (SDS) with the thresholds for reporting (>0,1%).. Allow freeing of space on the packaging for the labeling requirement and allow that information to be communicated to the end-user through the digital product passport. • The ESPR may not sufficiently protect trade secrets: especially the information requirements of the DPP are a concern, as they do not sufficiently protect trade secrets and intellectual property rights. Information disclosed under the DPP should empower consumers and achieve circularity but this should be proportionate to achieve this objective. To reduce administrative burden, the reporting requirements under DPP should be in one format for all the actors in the value chain. • For ESPR product groups, it is mandatory to have a 3rd party conformity assessment, DoC and CE marking. This would be a huge burden to the industry, particularly for SMEs, which would be heavily impacted. • The Ecodesign Forum’s work on developing product performance criteria should be transparent, have equal representation by including industry, and have a clear mandate in the consultation and decision-making process. • To properly translate the ESPR requirements by SMEs, it is crucial that the Commission considers the lack of in-house testing, lack of expert personnel in-house, training costs needed to uptake the ESPR, the availability of the right tools and knowledge, and member states' financial support. • Enforcement on imports from non-EU countries is already a challenge and should be prioritized in the Commission Work Plans to ensure a level playing field. This can have an immense impact on the supply chain and the EU Economy. • Given the empowerment for further product requirements, impact assessments of these delegated acts should cover direct impacts as well as indirect impacts for the entire supply chain to avoid cascading effects.
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Response to Streamlining EU scientific and technical work on chemicals through the EU agencies

8 Apr 2022

CEPE believes that a better use of resources and avoidance of duplication of work could be done but only for the derivation of hazard endpoints. With regard to the open data platform on chemicals, the repository of health-based limit values, or tools to improve access and uptake of academic data in regulatory work, CEPE would like to stress the importance of maintaining a high level of scrutiny on the quality of the data. Further explanation is provided in the attached document. Best regards
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CEPE urges digital labels to reduce waste and costs

20 Sept 2021
Topic — An EU initiative to simplify and digitalise labelling for various chemical products.
Message — The organization proposes a voluntary digital approach to supplement physical labels. They also request longer transition periods to update labels without discarding product stock.12
Why — The industry would avoid massive relabeling costs and the environmental impact of scrapping products.34
Impact — Environmental interests could be harmed if detailed hazard warnings are removed from physical labels.5
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European paint industry warns against new chemical hazard classes

29 May 2021
Topic — Revision of EU rules for the classification, labelling, and packaging of hazardous chemicals.
Message — The industry opposes adding new hazard classes like endocrine disruptors to current regulations. They advocate for multilingual fold-out labels and digital tools to manage limited packaging space.123
Why — This would protect their raw material portfolio from bans and reduce administrative costs.45
Impact — Environmental and health groups lose stricter safety classifications that identify and restrict toxic substances.6
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

29 May 2021

Our industry depends on a broad raw material portfolio to ensure the functionality of the diverse products of the coatings and printing inks industry and is therefore concerned about the proposed development, which may lead to the disappearence of key chemistries simply based on hazard and not on risk. Please find attached our comments.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

CEPE contribution on the roadmap for a Legislative proposal on substantiating green claims CEPE welcomes the opportunity to comment on the European Commission's roadmap for a legislative proposal on substantiating green claims. The paint, printing ink and artists' colours manufacturers are committed to working towards greater sustainability and gladly share their experience and expertise in light of this initiative. Our approach to sustainability CEPE promotes sustainability fundamentally through its CEPE's Sustainability Charter and the sustainability working groups. CEPE members also use European and national product category 1 environmental labels (in accordance with ISO 14024; e.g. Ecolabel, Blue Angel, Nordic Swan) to promote their products. The narrow approach of these product labels is mostly based on the limitation or exclusion of chemical substances with a hazard profile. In our view, this approach is too restrictive. It does not take into account the extension of the lifetime of products that are coated, particularly for exterior and industrial paints. This observation is in line with the following statement by the Joint Research Centre of the European Commission: Unlike many other products, coatings can contribute to sustainability in terms of their abilities to extend the lifetime of products that are coated, avoiding the need for rebuild through decoration and reducing the need for lighting through light refracting qualities. CEPE believes a more holistic approach, such as the Product Environmental Footprint (PEF), that calculates the product footprint of 16 environmental impacts over the full life cycle is a much more accurate and scientific way to determine environmental performance, especially regarding the functionality of the paint (e.g. durability and protective properties) and would thereby underpin the Commission’s ambitions. [...] --> Please read the attachment for our full contribution.
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Paint industry urges EU to protect functional packaging

6 Aug 2020
Topic — The Commission is reviewing requirements to reduce packaging waste and improve recycling design.
Message — CEPE requests that new rules safeguard packaging functions like product protection. They recommend using existing chemical regulations and qualitative definitions for recyclability.123
Why — Qualitative standards would protect innovation and prevent overly restrictive design mandates.4
Impact — Sustainability goals are harmed if inadequate packaging causes product spoilage and resource waste.5
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Response to Chemicals strategy for sustainability

19 Jun 2020

CEPE welcomes the opportunity to provide input on the roadmap for a chemical strategy for sustainability (hereafter ‘CSS’). The manufacturers of paint, printing ink, and artists’ colours are committed to ensuring that people and the environment are protected from exposure to harmful chemicals and mixtures and support the existing EU chemical acquis. In going forward, the chemical strategy for sustainability should take full advantage of the recent evaluations with the identified potential for improvement. CEPE is in favour of simplifying and strengthening the legal framework and to ensure global competitiveness. For the development of the strategy, CEPE wishes to highlight several topics that allow for a sustainable and future oriented chemical management in the framework of the European Green Deal. The existing legislation delivers and should carefully be strengthened: Today the EU is recognised as having one of the most stringent and advanced legislations on chemicals in the world which is a success and a testament to the effect of in particular REACH (Regulation (EC) No 1907/2006). While the legislation becomes increasingly complex, it is not the general orientation that needs redefinition, but it requires proper implementation by the European Commission, Member States and industry alike. CEPE agrees with the ECHA 2016 report on the operation of REACH and CLP that ‘further strengthening and aligning of enforcement is necessary’ as this is a key instrument for a sustainable and harmonised implementation of REACH. In general, economic operators also tend to prefer regulations than directives as this provides them with more legal certainty and tends to also facilitate harmonised enforcement. Alignment with the European Green Deal and applying a holistic approach: Europe’s new growth strategy seeks to increase the level of sustainability, circularity, and resource efficiency. CEPE members continuously develop innovative solutions building on the CEPE Sustainability Charter. We believe that the different dimensions of the European Green Deal represent considerations, especially life cycle assessments, which should be encouraged and applied in a holistic way to chemical management. The concepts for Product/Organisational Environmental Footprints, to which CEPE has contributed with a pilot study for Decorative Paints, is one of many tools for this approach. With a holistic approach, the benefits of e.g. Biocides would be evident. They are a key component for the preservation of aqueous mixtures (e.g. water-based paints & printing inks) that otherwise would deteriorate within days. While biocides are by definition detrimental to organisms, their careful use and low concentration reduces chemical waste significantly and thus contributes to resource efficiency and sustainability. Under the current circumstances the future availability of biocides for paints is at jeopardy which goes against the principles of the European Green Deal. In addition, we would like to see the CSS create incentives for digitisation to provide up to date product information which would improve transparency but also consumer trust. The CSS should also establish stronger links with occupational health and safety regulations. For example, the use of Community Occupational Exposure Limits as an alternative to Restriction or Authorisation of chemicals, where there is no consumer exposure. [...] Please see the attachment for our full opinion on the CSS roadmap.
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Paint industry group seeks delay for poison center rules

8 Jun 2020
Topic — The consultation addresses safety reporting rules for custom-mixed paint and ink products.
Message — The group seeks a three-year delay and higher concentration thresholds for hazardous components. They also request flexibility in how and where labels are placed on paint cans.123
Why — Delaying compliance would reduce the high costs of upgrading thousands of mixing machines.4
Impact — Emergency medical services may have less precise information when treating accidental chemical exposures.56
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European paint industry demands three-year delay for labeling rules

8 Jun 2020
Topic — New EU regulations on emergency health labeling for custom-mixed paint products.
Message — CEPE requests a three-year implementation delay to update thousands of mixing machines. They also propose a 10% reporting threshold to simplify labels.12
Why — Postponing the deadline prevents immediate financial losses from complex hardware and software overhauls.3
Impact — Emergency responders might lack specific chemical data for mixtures making up under 10% of products.4
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Paint industry urges simplification of biocide review program

19 Feb 2020
Topic — Updating data requirements for endocrine disruptors within the EU Biocidal Products Regulation.
Message — CEPE requests simplifying the review program to tackle the most important problems first. They argue that endocrine disruption requirements should not expand to co-formulants.12
Why — This would protect the supply of preservatives and reduce administrative burden.34
Impact — Health advocates lose early protection from substances that interfere with hormones.5
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Paint industry warns of workability issues in chemical labeling

9 Aug 2019
Topic — EU consultation on amending emergency health response requirements for chemical mixtures.
Message — The industry requests removing complex notification rules for products contained within other mixtures. They also propose placing formula identifiers only on inner packaging to reduce waste.12
Why — This would reduce administrative costs and protect the trade secrets of chemical suppliers.34
Impact — Poison centers may receive inconsistent data regarding the composition of complex chemical mixtures.5
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EuACA urges clarity on formaldehyde limits in toy materials

6 Feb 2019
Topic — The consultation proposes setting new limit values for formaldehyde in children's toys.
Message — The organization requests re-phrasing Recital 5 to clarify that all formaldehyde presence is regulated, regardless of origin. They argue the 10 mg/kg limit effectively bans necessary preservatives and is difficult to measure reliably.123
Why — This would prevent a de facto ban on preservatives needed for product safety.4
Impact — Children could face higher microbiological risks if available preservatives are overly restricted.5
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CEPE urges EU to reject titanium dioxide carcinogen classification

25 Jan 2019
Topic — The consultation reviews the proposed hazardous classification and labeling requirements for titanium dioxide.
Message — CEPE wants the Commission to reject the carcinogen classification for titanium dioxide. They suggest using occupational health laws instead of the CLP labeling system.12
Why — Industry players avoid expensive labeling changes and complex downstream waste management requirements.34
Impact — Health advocates lose standardized hazard labels that inform consumers about inhalation risks.5
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Response to Amendments of the Annexes to REACH for registration of nanomaterials

6 Nov 2017

Nanotechnology is of outstanding importance for the development of paints and coatings with much improved or entirely novel functional properties. In these development activities, the paint industry uses not only special nanoparticles but also novel binders with nanostructures. Newly developed paints and coatings based on nanotechnology are becoming ever more important in the market worldwide. CEPE, therefore, welcomes the publication of the draft amendments to Annexes of the REACH Regulation aiming to give more clarity and reducing uncertainty when registering and handling nanomaterials. The paint and coatings industry shares the EU Commission's conclusion in its second regulatory review on nanomaterials that nanomaterials are similar to normal chemicals/substances in that some may be toxic and some may not. Possible risks are related to specific nanomaterials and specific uses. Nanomaterials are not hazardous per se. Many nanomaterials are not new, some of them are used since decades. We support the comments made by Cefic but would like to add the following comment: Recital 7 of the current draft suggests that downstream users must inform the registrants when a nanoform is transformed into another nanoform in the subsequent processing of the nanomaterial. According to the current REACH regulation downstream users must inform the registrants about the use of the substance. Downstream User often use complex mixtures with nanomaterials and it would be impossible to identify the form of a nanomaterial in a complex mixture. We therefore like to ask to delete that part of the recital. The paint and printing ink industry is characterized largely medium-sized and therefore does not have the necessary complex measurement technology to generate this information and pass it in the supply chain. In addition, there is no uniform valid measurement method.
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Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and European Chemical Industry Council and

21 Mar 2017 · Reach evaluation