DECOPAINT Directive 2004/42/EC

303 Pages·2009·4 MB·English

EUROPEAN COMMISSION SERVICE CONTRACT
N°070307/2007/483710/MAR/C3
IMPLEMENTATION AND REVIEW
OF DIRECTIVE 2004/42/EC
(EUROPEAN DIRECTIVE LIMITING THE VOC CONTENT
IN CERTAIN PRODUCTS – CURRENT SCOPE: DECORATIVE
PAINTS AND VARNISHES, VEHICLE REFINISHING PRODUCTS)
FINAL REPORT (2 PARTS)
PART 2: ANNEXES 26-59
10 NOVEMBER 2009
Project co-ordination
Institute for Environmental Strategies
Ökopol GmbH
Institute for Environmental Strategies
Nernstweg 32 – 34
DE 22765 Hamburg
info/at/oekopol.de
http://www.oekopol.de
EUROPEAN COMMISSION SERVICE CONTRACT
N°070307/2007/483710/MAR/C3
IMPLEMENTATION AND REVIEW
OF DIRECTIVE 2004/42/EC
FINAL REPORT – PART 2: ANNEXES 26-59
DRAFT VERSION: 21 MAY 2009, COMMENTED: 8 JUNE 2009
1ST FINAL VERSION: 21 JUNE 2009, COMMENTED: 17 JULY 2009
2ND FINAL VERSION: 25 AUGUST 2009, COMMENTED: 26/27/28 AUGUST 2009
3ND FINAL VERSION: 28 SEPTEMBER 2009, COMMENTED: 9 OKTOBER, 1/10 NOVEMBER 2009
4TH FINAL VERSION: 10 NOVEMBER 2009
Main Contributors:
Christian Tebert, Susanne Volz Institute for Environmental Strategies
ÖKOPOL, Hamburg/DE, http://www.oekopol.de
Jeroen Terwoert
IVAM, Amsterdam/NL, http://www.ivam.nl
Volker Klotz, Wolf Müller, Jochen Theloke
IER, University of Stuttgart/DE, http://www.ier.uni-stuttgart.de
Daniel Vencovsky, David Fleet
RPA, Loddon/UK, http://www.rpaltd.co.uk
Tamas Kristof Kallay
REC, Szentendre/HU, http://www.rec.org
This report represents the views of Ökopol and its project partners and in no way
reflects the views of the European Commission.
The technical background information of this report was supported by Member
State authorities and industrial stakeholders, in particular by European industry
associations and individual companies related to VOC containing products. We
appreciate very much all their contributions to the study.
In particular, we would like to thank CEPE staff and working group members for
their input on several types of coating products. Furthermore, we thank AIRC,
CECRA and UNIEP for their feedback on coatings regulated under the scope of
the current directive, Colipa for information on cosmetics, FEICA for information
on adhesives, A.I.S.E. for information on glass cleaners and insecticides, FEA
and AEROBAL for information on aerosol products, EURMIG for information on
yachts coatings, CEFIC-CES for information on water-repellant impregnation
products, and all other associations, individual companies and research institutes
for their efforts in support of the project.
Annex v4 November 2009
Assessment and Review of Directive 2004/42/EC Final Report
CONTENT
ANNEX 26 STAKEHOLDER DOCUMENT
(EUROPEAN COATINGS INDUSTRY)
26. CEPE - CEPE ESTIMATE OF RE-LABELLING COSTS FOR THE
CHANGES IN 2010 FOR DECORATIVE PAINTS. BRUSSELS, 16.01.2009
ANNEX 27 STAKEHOLDER DOCUMENT
(EUROPEAN COATINGS INDUSTRY)
27. CEPE - REVISION OF DIRECTIVE 2004/42/EC – PROPOSED
CHANGES AND JUSTIFICATION, VERSION # 9, BRUSSELS, 20.3.2008
ANNEX 28 STAKEHOLDER DOCUMENT
(EUROPEAN COATINGS INDUSTRY)
28. CEPE’S POSITION (OPINION AND IMPROVEMENTS) ON REVIEW
OF THE PAINTS DIRECTIVE 2004/42/EC, BRUSSELS, 9.4.2008
ANNEX 29 STAKEHOLDER DOCUMENT
(EUROPEAN COATINGS INDUSTRY)
29. CEPE - PRODUCT DIRECTIVE 2004/42 (PD) - A CLEAR
REGULATION WHEN IT COMES TO IN-SITU APPLIED PAINTS AND
VARNISHES. RECOMMENDATION TO IMPROVE THE PD. BRUSSELS,
7.11.2008
ANNEX 30 STAKEHOLDER DOCUMENT
(EUROPEAN COATINGS INDUSTRY)
30. CEPE - REVISION OF DIRECTIVE 2004/42/EC - DECORATIVE
PAINTS AND VARNISHES - RATIONALE FOR NO FURTHER REDUCTIONS
BEYOND THE 2010 VOC LIMITS, BRUSSELS, 22.8.2008
ANNEX 31 STAKEHOLDER DOCUMENT
(EUROPEAN PROFESSIONAL PAINTERS)
31. UNIEP - RESPONSE TO REVIEW OF DIRECTIVE 2004/42/EC
IMPACT ASSESSMENT OF PROPOSED OPTIONS FOR AMENDMENT AND
OF PHASE II FOR DECORATIVE PAINTS, BRUSSELS, 13.05.2009
ANNEX 32 STAKEHOLDER DOCUMENT
(EUROPEAN COATINGS INDUSTRY)
32. CEPE - REVISION OF DIRECTIVE 2004/42/EC - VEHICLE
REFINISHES PRODUCTS - RATIONALE FOR KEEPING CURRENT VOC
LIMITS OR PROPOSED AMENDMENTS TO LOWER VALUES, BRUSSELS,
6.6.2008
November 2009 v4 Annex
Assessment and Review of Directive 2004/42/EC Final Report
ANNEX 33 STAKEHOLDER DOCUMENT
(EUROPEAN COATINGS INDUSTRY)
33. CEPE - COMMENTS WITH THE SUPPLY OF VEHICLE REFINISHES
DATA TO ÖKOPOL. BRUSSELS, 13.02.2009
ANNEX 34 STAKEHOLDER INTERVIEW
(EUROPEAN AND DUTCH VEHICLE REPAIR SHOPS)
34. AIRC/FOCWA INTERVIEW, JENDA HORAK, SASSENHEIM/THE
NETHERLANDS, 19.5.2008
ANNEX 35 STAKEHOLDER INTERVIEW
(EUROPEAN AND DUTCH VEHICLE REPAIR SHOPS)
35. AIRC/FOCWA INTERVIEW, JENDA HORAK, SASSENHEIM/THE
NETHERLANDS, 13.1.2009
ANNEX 36 STAKEHOLDER DOCUMENT
(EUROPEAN COATINGS INDUSTRY)
36. CEPE – VOCS AND NON-AUTOMOTIVE PAINT AEROSOLS,
BRIEFING PAPER, BRUSSELS, 29.08.2008
ANNEX 37 STAKEHOLDER DOCUMENT
(EUROPEAN COATINGS INDUSTRY/ EUROPEAN AEROSOL INDUSTRY)
37. CEPE/FEA – VOCS AND NON-AUTOMOTIVE PAINT AEROSOLS,
BRIEFING PAPER (II) – ADDITIONAL INFORMATION, BRUSSELS,
19.11.2008
ANNEX 38 STAKEHOLDER DOCUMENT
(EUROPEAN COATINGS INDUSTRY)
38. CEPE – INCORPORATION OF PROTECTIVE COATINGS INTO
DIRECTIVE 2004/42/CE, BRUSSELS, 9.10.2008
ANNEX 39 STAKEHOLDER DOCUMENT
(EUROPEAN COATINGS INDUSTRY)
39. CEPE – PROTECTIVE COATINGS PROPOSAL, RESPONSE TO
OKOPOL QUERIES, BRUSSELS, 14.01.2009
ANNEX 40 STAKEHOLDER DOCUMENT
(EUROPEAN COATINGS INDUSTRY)
40. CEPE – IMPACT ASSESSMENT – PROTECTIVE COATINGS
PROPOSAL FOR INCLUSION IN DIRECTIVE 2004/42/CE, BRUSSELS,
24.04.2009
November 2009 v4 Annex
Assessment and Review of Directive 2004/42/EC Final Report
ANNEX 41 RESEARCH INSTITUTE INTERVIEW
(WOOD RESEARCH INSTITUTE)
41. SHR TIMBER RESEARCH, LUTKE SCHIPHOLT, INTERVIEW WITH
JEROEN TERWOERT/IVAM, WAGENINGEN/THE NETHERLANDS,
29.4.2008
ANNEX 42 STAKEHOLDER DOCUMENT
(EUROPEAN COATINGS INDUSTRY)
42. CEPE – CEPE’S ACCOMPANYING NOTE WITH THE RESPONSES
ON THE IMPACT ASSESSMENT OF OPTION 8, BRUSSELS, 28.04.2009
ANNEX 43 STAKEHOLDER DOCUMENT
(EUROPEAN COATINGS INDUSTRY)
43. CEPE - CEPE’S POSITION FOR NON INCLUSION OF THE MARINE
PAINTS IN A REVISED PRODUCT DIRECTIVE, BRUSSELS, 11.02.2009
ANNEX 44 STAKEHOLDER DOCUMENT
(EUROPEAN RECREATION MARINE INDUSTRY)
44. EURMIG - POSITION FOR NON INCLUSION OF THE PLEASURE
CRAFT- AND SUPER YACHT INDUSTRY IN A REVIEWED PRODUCT
DIRECTIVE- 2004/42/CE, BRUSSELS, SEPTEMBER 2008
ANNEX 45 STAKEHOLDER DOCUMENT
(EUROPEAN RECREATION MARINE INDUSTRY)
45. EURMIG - ADDITIONAL INFORMATION ON REQUEST OF
CONSULTANT – ÖKOPOL, BRUSSELS, 5.5.2009
ANNEX 46 STAKEHOLDER DOCUMENT
(EUROPEAN SILICONES INDUSTRY)
46. CEFIC-CES, EUROPEAN WATER-REPELLENT IMPREGNATION
PRODUCTS - MARKETS AND TECHNICAL REQUIREMENTS, BRUSSELS,
20.03.2009
ANNEX 47 STAKEHOLDER DOCUMENT
(EUROPEAN ADHESIVES INDUSTRY)
47. FEICA – POSITION ON THE REVIEW OF THE DIRECTIVE
2004/42/EC, BRUSSELS, OCTOBER 2008
ANNEX 48 STAKEHOLDER DOCUMENT
(EUROPEAN ADHESIVES INDUSTRY)
48. FEICA – COMMENTS ON OPTION 11 AND OPTION 6 OF THE
OEKOPOL INTERIM REPORT ON THE REVIEW OF DIRECTIVE 2004/42/EC,
BRUSSELS, 23.04. 2009
November 2009 v4 Annex
Assessment and Review of Directive 2004/42/EC Final Report
ANNEX 49 STAKEHOLDER DOCUMENT
(EUROPEAN ADHESIVES INDUSTRY)
49. FEICA – THE IMPORTANCE OF AN OFFICIAL REFERENCE TO A
CALCULATION METHOD IN THE LEGISLATIVE TEXT, BRUSSELS,
OCTOBER 2008
ANNEX 50 STAKEHOLDER DOCUMENT
(EUROPEAN ADHESIVES PRODUCERS)
50. FEICA – INPUT ON TECHNICAL SPECIFICATIONS OF
ALTERNATIVES TO SOLVENT-BASED ADHESIVES, BRUSSELS,
19.05.2009
ANNEX 51 STAKEHOLDER DOCUMENT
(EUROPEAN ADHESIVES PRODUCERS)
51. FEICA – INPUT ON STATISTICS ON SOLVENTS IN FLOORING
ADHESIVES, BRUSSELS, 19.05.2009
ANNEX 52
52. GOOD PRACTICES FLOOR COVERERS/ KITCHEN & BATHROOM
INSTALLERS, JEROEN TERWOERT/IVAM, AMSTERDAM, 2005
ANNEX 53 STAKEHOLDER DOCUMENT
(EUROPEAN COSMETICS INDUSTRY)
53. COLIPA – PRODUCT CATEGORIES, ANNUAL REVIEW 2007,
BRUSSELS, 2008
ANNEX 54 STAKEHOLDER MEETING
(EUROPEAN COSMETICS INDUSTRY, EUROPEAN AEROSOL INDUSTRY)
54. COLIPA/FEA – VOCS IN DEODORANTS/ ANTIPERSPIRANTS AND
HAIRSPRAYS, TECHNICAL BRIEFING PAPER, BRUSSELS, 18.12.2008
ANNEX 55 STAKEHOLDER DOCUMENT
(EUROPEAN HOUSEHOLD PRODUCTS INDUSTRY)
55. A.I.S.E., RESPONSE TO DECOPAINT REVISION PROJECT,
BRUSSELS, 08.10.2009
ANNEX 56 STAKEHOLDER DOCUMENT
(EUROPEAN HOUSEHOLD PRODUCTS INDUSTRY, EUROPEAN
AEROSOL INDUSTRY)
56. A.I.S.E./FEA - VOCS IN HOUSEHOLD AEROSOL INSECT-
CONTROL PRODUCTS, BRIEFING PAPER, BRUSSELS, 02.04.2009
November 2009 v4 Annex
Assessment and Review of Directive 2004/42/EC Final Report
ANNEX 57 STAKEHOLDER DOCUMENT
(EUROPEAN ALUMINIUM AEROSOL CAN INDUSTRY)
57. AEROBAL - POSITION PAPER ON ÖKOPOL INTERIM REPORT,
IMPLEMENTATION AND REVIEW OF DIRECTIVE 2004/42/EC, BRUSSELS,
03.04.2009
ANNEX 58 STAKEHOLDER DOCUMENT
(EUROPEAN SOLVENTS INDUSTRY)
58. ESIG – ESIG COMMENTS ON THE PAINT DIRECTIVE INTERIM
REPORT BY OKOPOL AND ITS ECONOMIC IMPACT ON THE SOLVENTS
INDUSTRY, BRUSSELS, 15.05.2009
ANNEX 59 - REGIONAL ENVIRONMENTAL CENTRE (REC)
59. DATA COLLECTION IN EASTERN EUROPE
November 2009 v4 Annex
Assessment and Review of Directive 2004/42/EC Final Report
November 2009 v4 Annex
Assessment and Review of Directive 2004/42/EC Final Report – Annex 26
Annex 26 Stakeholder Document
(European Coatings Industry)
26. CEPE - CEPE estimate of
re-labelling costs for the changes in
2010 for decorative paints.
Brussels, 16.01.2009
November 2009 v4 Annex
Cost impact of Directive 2004/42/EC
CEPE estimate of re-labelling costs for the changes in 2010
for decorative paints
CEPE expert group reviewed the costs incurred by companies in the EU to adapt their
labels in order to comply with Directive 2004/42/EC.
Following cost elements are identified:
a) Origination and approval for the livery
b) Scrapping of stocks of obsolete labels or pre-decorated containers
c) Generation of stickers/over labels to make existing stock (all through supply
chain)
d) Generation and dissemination of modified datasheets
e) Take back and destruction of non compliant product from customer refusing to
sell through
All elements are reviewed and cost for the industry is estimated:
a) Origination and approval for the livery:
Basic assumptions (sku = stock keeping units):
- 175€ per sku = cost for design / generation new litho container
- 125€ per sku = cost for design / generation new paper labelled container
It is agreed to take as an average a cost of 150€ per sku as a base of our
calculation.
We have typically 4 000 companies in EU with 1 000 to 2 000 sku’s each, leading
to a total cost between 600 MM€ to 1,2 Bn€ (cost of 150M€ to 300M€ per
company).
It is estimated that 50% of the packaging changes linked to VOC compliance
would have been planned in the normal product life cycle, leading finally to a total
cost between 300 MM€ to 600 MM€. An average of 450 MM€ will be taken into
account.
b) Scrapping of stocks of obsolete labels or pre-decorated containers: 25K€ per
company leading to total cost of 1 MM€.
c) Re-labelling: Estimate (based on German data) of market size = 25 Bn litres –
average can size of 5 litre leading to 5 Bn cans sold in EU /year. Assuming that
5% would have to be relabelled (slow movers at big retailers or own depots) at a
cost of 0,5€/can, this is leading to a cost of 125 MM€.
d) Modified datasheets: Basic assumption is that cost for renewing both technical
and safety datasheets is 150€ per product range. It is also estimated that a