Paints and Coatings Digital Product Passport Guide

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Why Paints and Coatings Face Unique DPP Challenges

The paints and coatings industry sits at the intersection of chemical regulation, environmental policy, and consumer safety. Products in this sector contain complex formulations with dozens of chemical constituents, many of which fall under existing regulatory frameworks such as REACH and CLP. The introduction of Digital Product Passports under the EU Ecodesign for Sustainable Products Regulation (ESPR) adds a new layer of transparency requirements that will fundamentally change how manufacturers communicate product information.

Unlike many consumer goods where material composition is relatively straightforward, paints and coatings present a distinctive challenge. A single tin of interior paint may contain binders, pigments, solvents, additives, rheology modifiers, biocides, and preservatives, each sourced from different suppliers and each carrying its own environmental and health profile. The DPP must capture this complexity in a structured, machine-readable format that serves regulators, professional users, and consumers alike.

The sector is also characterised by enormous product variety. From architectural paints to industrial coatings, marine antifouling systems to automotive refinish products, the range of formulations and use cases is vast. Each sub-category will likely face tailored delegated acts under the ESPR, meaning manufacturers must prepare for sector-specific data requirements that go well beyond generic product information.

Key Data Fields for Paints and Coatings DPPs

The Digital Product Passport for paints and coatings will need to capture an extensive range of data points. While the final delegated acts are still being developed, the framework established by the ESPR regulation provides clear direction on the categories of information required. Manufacturers should begin structuring their data systems around these anticipated requirements.

• Volatile organic compound (VOC) content in grams per litre, aligned with the EU Paints Directive 2004/42/EC classifications
• Full chemical composition disclosure, including substances of concern above 0.1% weight concentration
• Environmental footprint data covering carbon emissions from raw material extraction through to end-of-life
• Coverage rates and expected lifespan under standard application conditions
• Recyclability of packaging, including material composition of tins, lids, and labels
• Application instructions, surface preparation requirements, and recommended disposal methods
• Supply chain traceability for key raw materials, particularly titanium dioxide and petrochemical-derived solvents
• Batch-level production data including manufacturing date, facility location, and quality certifications

Each of these data fields must be maintained in a format compatible with the EU's digital infrastructure. This means adopting standardised identifiers, using recognised chemical nomenclature such as CAS numbers, and ensuring data can be accessed via QR codes or other digital carriers affixed to the product.

Substances of Concern in Paint Formulations

The substances of concern requirements within the ESPR will have a particularly significant impact on the paints and coatings sector. Many formulations contain chemicals that are classified as hazardous under CLP regulation, restricted under REACH, or identified as substances of very high concern (SVHCs). The DPP must provide transparent disclosure of these substances to enable informed purchasing decisions and safe handling throughout the product lifecycle.

Titanium dioxide, the most widely used white pigment in paints, was classified in 2020 as a suspected carcinogen by inhalation in powder form (Category 2), but the EU General Court annulled that harmonised classification in November 2022 and the Court of Justice upheld the annulment in August 2025. The DPP will still need to communicate the inhalation hazard of powder forms clearly. Similarly, many coatings contain isocyanates, biocides, or heavy metal-based pigments that require careful disclosure.

For industrial and marine coatings, the challenge intensifies. Antifouling paints may contain copper compounds, zinc pyrithione, or other biocidal active substances. Fire-retardant coatings often incorporate halogenated compounds. The DPP framework demands that manufacturers trace these substances back through their supply chains and disclose their presence in a standardised format, creating unprecedented transparency in an industry that has traditionally guarded formulation details as trade secrets.

Manufacturers must balance intellectual property protection with regulatory compliance. The ESPR recognises this tension and provides mechanisms for restricting access to commercially sensitive formulation details whilst still ensuring that safety-critical information reaches the appropriate audiences.

VOC Reporting and Environmental Performance

Volatile organic compounds represent one of the most scrutinised aspects of paint and coating products. The EU Paints Directive already mandates VOC content limits for decorative paints and vehicle refinishing products, but the DPP will extend reporting requirements significantly. Rather than simply confirming compliance with maximum thresholds, manufacturers will need to declare actual VOC content, enabling consumers and specifiers to compare products and choose lower-emission options.

The carbon footprint tracking capabilities of Digital Product Passports will also transform how environmental performance is communicated. Paints and coatings have complex carbon profiles that encompass petrochemical feedstock production, energy-intensive manufacturing processes, solvent evaporation during application, and the long-term durability that determines recoating frequency.

Water-based formulations generally offer lower VOC emissions than solvent-based alternatives, but their overall environmental footprint is not always superior when full lifecycle analysis is considered. The DPP provides a platform for communicating these nuances, helping professional specifiers make genuinely informed choices rather than relying on simplistic VOC-only comparisons.

Manufacturers investing in bio-based raw materials, renewable energy in production, or innovative low-emission technologies will find the DPP a powerful tool for differentiating their products. The structured data format ensures that genuine environmental improvements are visible and verifiable, rather than lost in marketing claims.

Packaging and End-of-Life Considerations

Paint packaging presents its own set of DPP challenges. Metal tins, plastic containers, and aerosol cans each have different recycling pathways, and residual paint contamination often prevents effective recycling. The DPP must include clear recycling information that helps consumers dispose of both the product and its packaging responsibly.

The information required extends beyond simple recycling symbols. DPPs for paints will need to specify whether containers can be recycled with residual product, identify local collection schemes for hazardous waste paints, and provide guidance on how to safely use up remaining product to minimise waste. This level of detail represents a significant advance over current labelling practices.

• Material composition of all packaging components, including coatings applied to metal tins
• Recommended disposal methods for unused product, including hazardous waste classification where applicable
• Guidance on container cleaning for recycling, with specific instructions per packaging type
• Information on take-back schemes or collection points operated by the manufacturer or industry bodies
• Shelf life data to help consumers avoid purchasing quantities they cannot use before expiry

For professional users in the construction and maintenance sectors, the DPP will also support better waste management planning on project sites, contributing to circular economy objectives in the built environment.

Compliance Timeline for the Paints Sector

The ESPR follows a phased implementation approach, with delegated acts being developed for specific product categories over several years. While batteries and textiles are among the first sectors to receive detailed requirements, paints and coatings were assessed for the ESPR working plan and left out of the 2025-2030 list, so no delegated act is currently scheduled; the 2028 mid-term review could change that. Manufacturers should monitor the ESPR timeline and deadlines closely.

Any future preparatory study for paints would draw on existing regulatory frameworks, including the Paints Directive, REACH, and the Construction Products Regulation. This means that many of the data requirements will build upon information manufacturers are already obliged to collect and report.

Industry bodies such as CEPE (the European Council of the Paint, Printing Ink and Artists' Colours Industry) are actively engaging with the Commission on the development of sector-specific requirements. Manufacturers who participate in these consultations through their trade associations will be better positioned to anticipate final requirements and influence practical implementation details.

A prudent approach is to begin DPP preparation now, even before final delegated acts are published. By auditing existing data systems, identifying gaps in supply chain information, and establishing digital infrastructure for product-level data management, manufacturers can avoid a scramble when compliance deadlines are confirmed.

Supply Chain Data Collection Challenges

The paints and coatings supply chain is highly globalised, with raw materials sourced from chemical producers, mining operations, and agricultural processors spanning multiple continents. Collecting the granular data required for DPPs demands effective material traceability and supply chain transparency mechanisms that extend well beyond current industry practice.

Pigment suppliers, resin manufacturers, and additive producers will all need to provide upstream data to paint manufacturers. This creates a cascade of data requests through multiple tiers of the supply chain, requiring standardised data exchange formats and clear contractual obligations regarding information provision.

Small and medium-sized manufacturers face particular challenges. While large multinational coatings companies may have the resources to build dedicated data management systems, smaller formulators often rely on manual processes and supplier technical data sheets. The transition to structured, digital data exchange will require investment in systems and skills that may strain limited budgets.

Industry-wide data platforms and collaborative approaches to supply chain data collection will be essential. Initiatives such as the Together for Sustainability (TfS) programme, which already facilitates environmental and social data sharing in the chemical industry, could provide models for paint-sector-specific solutions.

Practical Steps to Prepare Your Paint Business

Preparing for DPP compliance requires a structured approach that addresses technology, data, processes, and people. The following steps provide a practical roadmap for paints and coatings manufacturers looking to get ahead of regulatory requirements.

• Conduct a comprehensive data audit to identify which DPP-required information you already hold and where critical gaps exist
• Engage your raw material suppliers early with clear communication about the data you will need them to provide
• Evaluate digital product passport platforms such as MyProductPassport that can manage structured product data at scale
• Review your VOC testing and reporting processes to ensure actual content data is captured at batch level
• Map your packaging materials and recycling pathways to prepare end-of-life information for each product format
• Train your regulatory and product management teams on ESPR requirements and DPP data structures
• Participate in industry consultations through CEPE or national trade associations to stay informed on delegated act development

The paints and coatings industry has a strong track record of adapting to regulatory change, from the elimination of lead-based paints to the reduction of VOC emissions. Digital Product Passports represent the next chapter in this evolution, and manufacturers who embrace the transition early will find competitive advantages in transparency, sustainability credentials, and customer trust.

The Competitive Opportunity for Forward-Thinking Manufacturers

While DPP compliance is a regulatory obligation, it also presents genuine commercial opportunities. Professional specifiers in construction, marine, and industrial sectors increasingly factor sustainability credentials into procurement decisions. A well-structured DPP that demonstrates low environmental impact, responsible chemical management, and circular packaging solutions can differentiate products in competitive tender processes.

The structured data within DPPs will also enable new digital services. Manufacturers could offer specification tools that help architects and designers select coatings based on verified environmental performance data, or maintenance planning services that use product lifespan information to optimise recoating schedules. These value-added applications transform the DPP from a compliance cost into a platform for innovation and customer engagement.

As the regulatory landscape continues to evolve, manufacturers who have invested in robust data infrastructure and transparent communication will be best positioned to adapt. The DPP is not merely a label requirement, it is a fundamental shift towards data-driven product stewardship that will reshape the paints and coatings industry for decades to come.