Hugo-Maria Schally
Head of Unit
Eco-innovation and Circular economy
Directorate-General for Environment
European Commission
Danish EPA Environmental
Technology
J.nr. 001-14038
Ref. san
January 8 2016
Dear Mr Hugo-Maria Schally,
The latest amendment of the ecological criteria for EU ecolabelled paint and
varnishes (sent by the Commission on October 29th 2015) has raised concern in
the Danish Parliament due to the acceptance of using substances labelled
environmentally hazardous in EU ecolabelled products, especially in the case
where this results in a hazard labelling.
More specifically, the concern relates to the decision to allow continued use of
Adipic acid dihydrazide (ADH) and the biocide active substance IPBC in eco-
labelled paint and varnishes in spite of their new classification as environmentally
hazardous substances.
Denmark generally supports the principle of avoiding changes to the criteria in
between planned revisions to ensure certainty for the license holders. Thus,
Denmark voted positive to the proposal that would maintain status quo and allow
continued use of these two substances.
The national consultation, however, revealed that there might be a less hazardous
alternative to the use of the adhesion promoter and cross linker ADH. The
consultation process referred to paint manufacturers using such an alternative.
It is clear from the EU ecolabel regulation that the substitution of hazardous
substances by safer substances, wherever it is technically feasible, is a very
important requirement.
Therefore, Denmark shall kindly ask the Commission as part of the next revision
process of the criteria to thoroughly investigate less hazardous alternatives to ADH
binder and less hazardous biocides, which have similar or higher effectiveness and
environmental performance throughout the product’s entire lifecycle compared to
those used today. Such an investigation should also include an evaluation of other
paint techniques, e.g. linseed oil paint systems, and the market shares and
availability of the alternatives.
For further details please contact Søren Mørch Andersen ([email protected]).
Yours sincerely,
Søren Bukh Svenningsen
Head of Division
Environmental Protection Agency • Strandgade 29 • DK-1401 Copenhagen K Denmark
Tel +45 72 54 40 00 • CVR 25798376 • EAN (drift)5798000863002 (tilskud)5798000863019 • [email protected] • www.mst.dk