Environmental Claims - lead

Guide on ‘no added lead’ and other environmental claims and statements in the Decorative Coatings Sector

Who should read this guidance?

All companies that develop, manufacture or retail decorative coatings and:

• Currently make environmental claims about products;
• Are considering how to market the environmental attributes of their products
• Are receiving queries from customers about environmental performance of their products and are considering how to respond.

Giving clear, straightforward, environmental information, as outlined in this guidance, has benefits for consumers and business alike. By providing information about the environmental effects and qualities of products, and how to use and dispose of them, environmental claims (sometimes called ‘green’ claims) help consumers to make informed buying choices. They also help to raise awareness of the issues, enhance consumer understanding and improve product standards overall. At the same time business can enhance their credentials and demonstrate that they are acting responsibly to consumers, other business partners and regulators.

This document has been developed by the British Coatings Federation (BCF) to supplement Green Claims Guidance (2011) produced by the Department for Environment, Food and Rural Affairs (Defra) specfically for the coatings sector.

Defra's Green Claims Guidance set out the three main steps to making a good environmental claim, with guidance and examples to illustrate the main principles:
1. Check the content is relevant and reflects genuine environmental benefit
2. Present the claim clearly and accurately
3. Check the claim can be readily substantiated

 This guide focuses specifically on providing clear, user-friendly advice for companies in the decorative coatings sector, who wish to make environmental claims such as ‘lead free’ about their products. It covers the following areas:
• Claims relating to lead content
• Health and safety warning regarding the stripping of ‘old’ painted surfaces
• VOC (volatile organic compounds) statements
 

Claims relating to lead content

Defra's Green Claims Guidance states ''Make sure that a claim is used only in circumstances where there is a genuine additional environmental benefit or advantage, which is relevant or significant'' (page 13). An important aspect of this is ensuring where something only reflects current complinance with the law (i.e. meets the minimum legal requirements), it should not be implied that this represents an additional environmental benefit.
The retail sale of all lead-containing decorative coatings to the general public has been prohibited for some time. The BCF therefore agrees that companies should not be making claims confirming the absence of lead in retail decorative coatings, given that this is a legislative requirement. BCF members also apply this restriction to decorative coatings supplied for professional use. As a result, claims such as:

• ‘lead free’
• ‘this product contains no added lead’

Should not be made, as they are considered misleading to consumers and in breach of the UK Green Claims Guidance

http://www.defra.gov.uk/environment/economy/products-consumers/green-claims-labels/

 Health and Safety Warning regarding the stripping of painted surfaces

Given that old painted surfaces may containing lead, decorative coatings manufacturers may wish to include relevant health and safety information to this effect. The BCF has developed the following standard phrase for this purpose for companies to use on products and in product literature:

‘’special precautions should be taken during surface preparation of pre-1980s paint surfaces over wood and metal as they may contain harmful lead. For further advice contact.....[advice centre name, address and telephone number]’’

Guidance on the removal and repainting of old lead-painted surfaces is available from the BCF here.

VOC (volatile organic compound) statements

The British coatings industry has adopted a VOC labelling scheme for decorative coatings to inform customers about the levels of organic solvents and other volatile materials present in products. Coatings manufacturers use standard terminology, text and categories for all products. Information is provided according to 5 ‘bands’ and manufacturers have a choice of label design to use, either a BCF text box (shown below) or a ‘globe label’ (shown below), the latter is subject to signing a licence agreement with B&Q plc. Further information on VOCs can be found from the BCF here. 

All decorative coatings will carry labelling giving the actual VOC content of the product in accordance with the legal requirements as set out in Statutory Instrument (SI 2005:2773) and the above voluntary labelling is no substitute to the legal requirements.      

 
Other Environmental Claims and Statements for Decorative Coatings

If you intend to make an environmental claim not covered by one of the above areas, you may find it useful to refer to the more general advice produced by the Green Claims Guidance – How to make a good environmental claim, available on line from

http://www.defra.gov.uk/environment/economy/products-consumers/green-claims-labels/

By following the Green Claims Guidance companies can ensure that claims are meaningful and in line with existing standards and codes, International Standard ISO 14021 and the European Commission Guidelines
 (http://www.ec.europa.eu./comm/consumers/cons_safe/news/green/guidelines_en.pdf ) for making and assessing environmental claims. The guidance is not intended to replace these codes but to provide user-friendly interpretative guidance on how to apply them.

Contacts

British Coatings Federation
Riverbridge House
Guildford Road
Leatherhead
Surrey  KT22 9AD
Tel: 01372 365989
Website www.coatings.org.uk
E-mail enquiry@bcf.co.uk

Department for Environment Food and Rural Affairs
Ergon House
17 Smith Square
London SW1P 3JR
Telephone 0207 238 6000
Website www.defra.gov.uk