The Role of the World Coatings Council
in Advocacy and Policy
The World Coatings Council provides a forum for information exchange and cooperation on the major issues and priorities facing paint and printing ink industries worldwide. The council acts as a focal point for monitoring and communicating specified international issues; develops recommendations and analyses on selected issues of common interest to the participating organizations and attempts to derive a common consensus position (considering information from policymakers in the governing bodies of the respective participants); coordinates industry positions and communicates with other international organizations, industry publications and other interested parties.
In 2008, the World Coatings Council (then IPPIC) was granted permanent non-governmental organization (NGO) status at the International Maritime Organization (IMO), the UN’s global standard-setting authority that regulates the safety, security, and environmental performance of international shipping and commerce. The IMO focuses its work on environmental issues particularly affecting the marine environment. Its main role is to create a governing international framework for the shipping industry that is fair and effective, and which is universally adopted and implemented.
The IMO’s regulatory reach extends to coatings used in the marine environment. Not only does the IMO address antifouling coatings under the International Convention on the Control of Harmful Anti-fouling Systems on Ships (AFS Convention), but it has also established demanding international requirements for certain protective coatings through the Performance Standards for Protective Coatings (PSPC).
As a result, the World Coatings Council established two committees dedicated to issues affecting marine coatings: the Antifouling Coatings Committee (AFCC) and Marine Coatings Technical Committee (MCTC). These committees are comprised of international companies that manufacture, supply, and sell marine coatings and their biocides worldwide. The committees engage at the IMO by supporting the development of technically sound regulations for marine coatings around the world.
At the IMO, the World Coatings Council primarily provides technical advice and expertise on critical issues pertaining to the AFS Convention, Biofouling Guidelines, PSPC, and the International Convention for the Control and Management of Ships’ Ballast Water and Sediments (Ballast Water Management Convention). In addition to its work at the IMO, the World Coatings Council also monitors regulatory activities affecting marine coatings and active substances in countries and regions throughout the world, including the United States, European Union, Japan, Australia, and countries in South America, Central America, and Asia.
The World Coatings Council (formerly the International Paint and Printing Ink Council, Inc., or IPPIC) is a contributing member of the Lead Paint Alliance (LPA, formerly the Global Alliance to Eliminate Lead Paint), an organization established under the United Nations Environmental Program (UNEP) and the World Health Organization (WHO).
Since its inception in 2010, and with its reorganization in 2015, the LPA has been working to engage national governments, industry and non-governmental organizations in establishing restrictions on lead use in paints that pose public health and environmental risks, especially to children.
The current focus of the LPA is to assist in the expansion of the number of regions or countries in restricting lead use in paint by virtue of a universal, consistent model regulation. The council’s contribution to the LPA has been to highlight the widespread existing restrictions on lead use in paints, to encourage the adoption of similar restrictions by governments that currently have none, and provide the industry’s expertise on technical issues raised by reformulation challenges.
In 2018, the council (then known as IPPIC) again reaffirmed its 2009 policy statement and updated it to reflect new global developments by the LPA:
“WCC notes the long-standing effectiveness of lead-use restrictions that are already in place in many jurisdictions around the world and recommends their widespread adoption by authorities not currently regulating the use of lead in paint and printing ink. To this end, IPPIC supports the UN’s Lead Paint Alliance “Model Law”, as a useful starting point for both government and industry to collaborate on developing restrictions that ensure widespread and verifiable compliance.”
The council and its members are encouraged by the continued advancement of LPA objectives, aided by the publication of the UN’s “Model Law”, detailed documentation of current effective restrictions, as well as a useful “toolkit” to help policymakers increase awareness and advance required restrictions.
As the LPA continues its efforts to address lead use in paint and coatings, the council also anticipates working with other LPA partners to assist in industry implementation efforts to ensure widespread and verifiable compliance.
For more information on the LPA and efforts to seek restrictions on decorative paints see:
The term “biocides” has come to encompass a wide range of materials that control the growth of unwanted, deleterious microorganisms in the environment. Purification of drinking water sources, cleaning contaminated surfaces in our homes and offices, sanitizing dishes and cookware used in food preparation, sterilizing surgical instruments and treating serious wounds or simple cuts have all become part of the public trust, reinforcing the absolute need for effective biocides to support public health, safety and environmental protection.
The widespread use of biocides in construction products, however, has resulted in increased scrutiny of their inherent safety. The paint and coatings industry acknowledges the need to maintain proper safeguards when using biocides, and cites a long history of effective collaboration with government to protect public health and the environment, and ensure effective policies for biocide use that support continued availability.
Microbial attack (i.e. mold and mildew) on painted surfaces is a wide-ranging and universal concern that has resulted in a global, coordinated strategy to combat it. The participants in this effort include the companies that make biocides, paint manufacturers – who add biocides to their products, users of paints containing biocides – who have come to expect the efficacy of these products to protect the painted surface and maintain desired conditions, and the government agencies charged with protecting public health and the environment – who provide oversight and continued scrutiny of the safety and effectiveness of biocidal product use in paints and coatings.
The impact of microbial growth is not limited to degradation of applied paint films, but also occurs during production and storage of paints and coatings. Increasingly, paint products have embraced waterborne technology, using formulations that are low in volatile organic compounds (VOC’s) with lower emissions during application and drying. As with most waterborne products, paints require the use of “in-can” preservatives to protect them from spoilage. Without these biocides, waterborne paints would spoil in storage. In extreme cases, the microbial decomposition can generate gases that rupture the container.
The importance of biocides use for in-can preservation and microbial attacks cannot be understated. It is a fact that over the past 75 years, market growth and public acceptance of waterborne paints and coatings has only been possible with the use of biocides. In the efforts to protect waterborne paints from microbial growth, manufacturers have enhanced plant hygiene and developed work practice controls that ensure product integrity throughout the supply chain. These efforts are part of a holistic approach to microbial control that ensures protection, but also optimizes the use of biocides to a level that is necessary to do the job.
Additional specialized uses of biocides in certain paints and coatings are critical to protection of the substrates to which they are applied. Wood preservative materials are used to suspend the growth of microorganisms and other lifeforms that are associated with the destruction of wood and wood structures. Marine and offshore protective coatings are used to reduce the growth of marine microorganism and associated biofilms that degrade vessels and steel structures, and slow their propulsion through the water. Both uses are highly regulated and face increased and stringent regulatory controls whereby end users, paint manufacturers, and the producers of the biocides (i.e. active ingredients) work closely with government agencies to ensure safe use, and supports new ideas that help advance consumer protection and reinforce safe use of biocides in paints and coatings.
Responsible Mica Initiative (RMI)
The Responsible Mica Initiative (RMI) is a consortium of companies and NGO partners implementing strategies to assure fair labor practices in production of natural mica. The organization was formed in 2017, based on a long-standing interest of some members who had independently initiated programs to address child labor in the mica supply chain. Interest was further galvanized after a report published by the Dutch NGO TDH (Terre des Hommes) identified India as the largest global supply source of natural mica produced with child labor. TDH’s report called for industries that use mica to work constructively in mica-producing regions to develop a comprehensive strategy to address labor practices, while continuing to source from these regions to provide income in a low-income area.
With support from member companies, RMI developed a strategy and continues to implement programs that allow for improvements in supply chain management for natural mica by working with mines, mica processing units and state and local authorities, while addressing underlying social conditions leading to reliance on child labor in affected Indian regions. In addition to working with regional upstream actors in the mica supply chain, RMI operates programs in these regions to establish education, alternative employment, wage equality for adults, access to government social welfare programs and other programs. In 2018, the UN Forum on Business and Human Rights recognized RMI’s program as the most innovative and inspiring approach to implementing the UN Guiding Principles on Business and Human Rights.
ACA and the World Coatings Council have supported RMI’s efforts by serving on the RMI Board and on RMI working groups that address traceability, legal and community empowerment strategies. ACA also organized responses to media inquiries at both the domestic (ACA) and international (World Coatings Council) level. The World Coatings Council established a working group under its Industry Stewardship Committee to address the natural mica concerns and derive best practices to apply to future supply chain management issues. The council engages in regular communications on the RMI activities with members and for companies that have an interest in supply chain dynamics.
More information about RMI is available online at: http://www.responsible-mica-initiative.com/.
In February 2020 the European Commission codified its adoption of the 14th ATP concerning titanium dioxide (TiO2); classifying TiO2 containing greater than 1% respirable dust content by inhalation as a suspected carcinogen (Cat. 2). Following an eighteen-month transition period, the CLP regulation of TiO2 and TiO2 containing mixtures will be enforceable beginning October 1, 2021.
The result will be that products containing TiO2 will require new warnings.
• mixtures in powder form containing 1% or more of titanium dioxide which is in the form of or incorporated in particles with aerodynamic diameter = 10. This is likely to result in the vast majority of TiO2 powder mixtures being classified as they are likely to contain the requisite threshold percentage of powder form with the aerodynamic diameter less than 10µm. Such product labels would be required to identify TiO2 as a “Suspected of causing cancer” and include the GHS health hazard pictogram, below.
- liquid mixtures containing 1 % or more of titanium dioxide particles with aerodynamic diameter equal to or below 10 µm will need to bear the following statement: “Warning! Hazardous respirable droplets may be formed when sprayed. Do not breathe spray or mist.”
- solid mixtures containing 1 % or more of titanium dioxide (regardless of the presence of respirable dust) shall bear the following statement: “Warning! Hazardous respirable dust may be formed when used. Do not breathe dust.”
- the regulation will also require changes to manufacturer safety datasheets (SDS);
- The downstream impacts include potential for waste containing > 1% TiO2 by weight to be classified as hazardous waste, and new risk assessments under regulations for toys and cosmetics.
The TiO2 Category 2 cancer hazard classification by respirable dust inhalation is intended to focus upon the specific hazard where respirable dust exposures occur (i.e., exposure to particles less than 10 µm in diameter). This has led to the classification entry for TiO 2 being more complex than typical entries, containing several specific notes, annexes, and labels. Some of the terminology in the regulation is being used for the first time under CLP.
Due to the widespread use of TiO2, the regulation that will impose new labeling requirements for many products. The regulated community will be required to interpret and apply the various notes, and annexes of the regulation. Accordingly, the classification creates the potential for misapplication and confusion in the marketplace, complications for downstream users and processors and an impact upon global trade.
The Titanium Dioxide Manufacturers Association (“TDMA”) members filed a legal challenge seeking nullification of the TiO2 Classification before the EU General Court. Billions Europe Ltd. v. Commission. Two additional separate challenges were filed CWS Powder Coatings GmbH v. Commission and Brillux GmbH & Co. KG and Daw SE v. Commission.
Six pleas in the main action are:
a. Regulation was adopted in breach of several mandatory provisions of underlying regulation, specifically, TiO2 does not have the intrinsic property to cause cancer, and therefore could not be lawfully classified.
b. The Regulation breaches the principle of legal certainty.
c. Regulation was adopted in breach of the principle of proportionality, the classification is disproportionate to the aims it pursues.
d. The Commission incorrectly exercised its discretion and breached its duty of care, including reliance upon the RAC Opinion without an assessment of the probative value of such RAC Opinion.
e. The Commission breached its duty of sound administration, and the right of the applicants to be heard, the applicants were denied an adequate opportunity to comment meaningfully on the RAC Opinion itself, which significantly deviated from the original classification proposal both about the scientific rationale used and to the final conclusion on the classification of TiO2.
f. In adopting the Regulation without the prior conduct and documentation of an Impact Assessment, the Commission breached the principle of sound administration.
A joint petition to intervene in the action of ACA, the European Council of the Paint, Printing Ink and Artists‘ Colours Industry (CEPE), and the British Coatings Federation (BCF) was granted in February 2021. Briefing of the ACA, CEPE, BCF coalition is due to be filed by May 4, 2021.
The current expectation is that the EU Court will not rule on the matter until the second half of 2022.
The paint, coating and printing ink industries have a long history of sustainable practices and providing products that protect, sustain and add value to the built environment, our infrastructure, and the objects we depend on every day. The industry continues to reduce its environmental footprint and embraces sustainability by increasing resource recovery, reducing and eliminating hazardous emissions, offering products formulated to meet specific safety requirements, and being supportive of efforts to conduct “life-cycle analyses” that evaluate all of the relevant environmental impacts and benefits from preserving and protecting the global infrastructure. The industry also addresses its social responsibility by creating health and safety programs to protect the workforce that manufactures its products and the communities that use paints, coatings and printing inks.
The World Coatings Council believes that sustainability programs should be developed and implemented by individual associations in a manner that allows for consistency and harmonization across the globe. National or regional paint and printing inks associations are the appropriate organizations to facilitate and help enhance sustainability programs on behalf of the members in their respective country or region. At the same time, The council believes it is essential that national associations create consistent messages and comparable metrics when implementing individual sustainability programs. By pursuing conformity, national associations will be able to compare best practices and indicators of performance, and ultimately, companies can reference consistent programs.
The Council is currently developing a WCC Sustainability Report. WCC’s consultant has completed a materiality survey of WCC members and associated coatings manufacturing companies and is currently conducting interviews of WCC members, associated coatings manufacturing companies and key external industry stakeholders to better understand key sustainability performance indicators and sustainability case studies that will be documented in the final sustainability report that will be completed later in 2021.
Transport of Dangerous Goods
To ensure consistency between regulatory systems throughout the world, the United Nations (UN) established a sub-committee dedicated to forming appropriate harmonization regulations for the transport of dangerous goods. This harmonization occurs in the UN Sub-Committee of Experts (SCE) on the Transport of Dangerous Goods (TDG). The UN SCE TDG considers proposed changes to the UN Model Regulations for the Transport of Dangerous Goods, which is used by many countries as the basis of the country’s TDG regulations. The UN Model Regulation for the Transport of Dangerous Goods is currently in the 22nd Revision (2021).
The UN SCE TDG meets twice per year in Geneva, Switzerland, to consider proposals from governmental and non-governmental delegations that are developed to be incorporated into the model regulation.
In 2005, the World Coatings Council was granted non-governmental organization (NGO) status by the UN to attend and participate in the UN SCE TDG meetings. Since then, the World Coatings Council has been proactively engaged in UN efforts to harmonize the model regulation to ensure efficiency and cost-effectiveness for cross-border and multi-modal shipments of paint and allied products. At the UN SCE TDG meetings, the World Coatings Council submits proposals, records discussions, and advocates on behalf of the paint and coatings industry. Participation in the World Coatings Council’s delegation to the UN SCE TDG is open to those participating companies or country trade associations of the Council.
Globally Harmonized System
In the 1990s, the United Nations Economic Commission for Europe embarked on a journey to design a universal chemical classification system for the entire world. It was believed that a universal chemical classification system would help to decrease the number of accidents in the workplace and home environments resulting from improper use of chemical products. It was also believed that a universal chemical classification system would decrease the cost of doing business around the world because in theory one label could be used for the same product sold in many different countries. The development and maintenance of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) was formally commissioned by the United Nations and assigned to the Subcommittee of Experts on the GHS (UNSCEGHS).
As noted above, the reasons for setting the objective of harmonization were many. The UNSCEGHS operates with the goal that, when fully implemented, the GHS will:
- Enhance the protection of human health and the environment by providing an internationally comprehensible system for hazard communication;
- Provide a recognized framework for those countries without an existing system;
- Reduce the need for testing and evaluation of chemicals; and
- Facilitate international trade in chemicals whose hazards have been properly assessed and identified on an international basis.
The World Coatings Council sends representatives to the UNSCEGHS Meetings held twice annually in Geneva, Switzerland. At these meetings, the council’s representatives meet the environmental, health, and safety representatives from member countries who work on each revision of the GHS. The council can submit white papers to support its member associations’ viewpoints on certain technical issues before the UNSCEGHS. Input from council representatives has been well-received by the UNSCEGHS.
For more information:
Volatile Organic Compounds (VOC)
Advancements in coatings technology have led to significant reductions in volatile organic compound (VOC) emissions from the paint and coatings industry, despite increased sales. The data collected in this area demonstrates that, despite increasing sales. As an example, data from the California Air Resources Board (CARB) suggests that the average VOC content of architectural coatings decreased by 80% since 1982. This dramatic reduction in emissions illustrates industry’s commitment to reducing its environmental footprint and improving air quality. Contributing factors for these large additional reductions include researching and implementing new paints and coatings chemistries, implementation of regulations with lower VOC limits, and increased consumer demand for low-VOC coatings.
Indoor Air Quality
As a customer-oriented industry, the global paint industry has been actively engaged in minimizing the indoor air emissions from coatings products, to address increased consumer demand for low emitting and low odor products. Another driver has been the implementation of indoor air quality standards as well as green building standards like the Leadership in Energy and Environmental Design (LEED) that provide credits for low emitting coatings, adhesives and sealants.
Plastic pollution has become one of the most pressing environmental issues to confront our world. Not only plastic containers, readily visible to naked eye, but also microplastic pollution, that is the result the breakdown of plastics and hard films that spread throughout the water and surface environment in tiny microscopic pieces.
Macroplastics, Single Use Plastics (SUPs), Plastic Packaging
Increasingly, the fate of plastic materials is coming under scrutiny by government, environmental organizations, and academic researchers around the world. This is due in large part to the widespread and highly visible problem of how to manage the large volume of discarded plastic containers and packaging products that end up in the waste stream.
These highly visible discarded materials in the environment are known as “macroplastic” wastes. Policymakers around the globe are struggling to develop and apply waste management principles, specifically stimulating efforts to “reduce, re-use and recycle” these materials, and meaningful waste management discussions by diverse stakeholders are emerging. “The circular economy” and “extended producer responsibility (EPR)” are dominant agenda items in those discussions. Given the widespread and visible nature of this waste problem, these efforts are welcome, and all parties are hopeful that a comprehensive, sustainable solution can be established.
Extended Producer Responsibility (EPR) legislation and regulations seek to hold producers responsible for the collection and recycling of plastic and other products, typically by establishing a “producer stewardship organization” or “producer responsibility organization.” The paint and coatings industry has responded with the creation of several stewardship programs that specifically address post-consumer paint and as well as paint containers (Product Care, PaintCare, and Paintback). These organizations operated by the industry. There will likely be additional pressure on our industry to further address single use plastics with labeling requirements, additional fees, or other issues.
Environmental researchers are focusing efforts on new categories of waste found in the environment, in some cases arising from use of a variety of plastic materials in formulations for consumer and industrial products. The first major category is the so-called “primary microplastics” which refer to intentionally-added materials such as “micro-beads” or “microfibers” that provide certain desirable performance properties but without any attendant release to the environment as they become embedded in the applied paint film.
The other major category is known as “secondary microplastics”, which have yet to be formally defined, but can best be described as the “polymeric fragments” released into the environment over time from plastic-containing products, largely through the degradation of larger (i.e. macroplastic) materials. These secondary microplastics include releases from synthetic fibers in clothing (primarily from the laundering process), weathering of macroplastic wastes, degradation of polymeric surfaces (like paint) on exterior substrates, and wastewater streams that may receive discharges and/or releases of secondary microplastics from all sources.
Numerous studies on the environmental prevalence and fate of secondary microplastics have been published, but differ widely in how they have collected, characterized and quantified the sources and pathways of secondary microplastic releases.
In general, paint is a resinous product intended to provide a continuous protective or decorative film to a substrate, imparting desirable properties that last for a long time. Extensive efforts are made to ensure economical transfer efficiency and to minimize loss of paint product to the environment during application and subsequent clean-up of application equipment (i.e. brushes and rollers).
All known mitigating factors need to be considered in any effort to quantify the potential release of microplastics from products. This is especially true for academic researchers, government agencies and advocacy groups as they work to address concerns regarding microplastics in the environment. For its part, the paint industry stands ready to advance its understanding of the issue and our commitment to product stewardship.
Post Consumer Paint Stewardship Programs
As much as 10% of all household latex and oil-based paint (post consumer paint) goes unused.
Management of this waste stream has proven to be difficult for consumers and expensive for local government agencies.
The paint and coatings industry has proactively responded to this challenge by developing stewardship programs to collect leftover consumer paint and manage the end-of-life of this waste stream. These programs include Product Care in several Canadian provinces, PaintCare in the United States, and Paintback in Australia. These programs provide a system for the management of postconsumer architectural paint in an environmentally sound manner that includes collection, transportation, processing, recycling, and proper disposal.
Product Care – originally started in British Columbia in 1994, Product Care is now operating in eight Canadian provinces. Over 10.3 million liters (2.7 million gallons) of paint recovered in 2019. More information about Product Care is available online at: https://www.productcare.org/products/paint/
PaintCare – launched in Oregon in 2009 and has been adopted in 11 additional jurisdictions in the United States. To date, PaintCare has collected over 48 million gallons of paint. More information about PaintCare is available online at: https://www.paintcare.org/
Paintback – started in 2016, is an industry led post consumer paint management program in Australia. In 2020, Paintback collected approximately 8,100 tonnes of paint and packaging, up from 6,300 tonnes in the previous year. More information about Paintback is available online at: https://www.paintback.com.au/