I managed a wry smile when US president Donald Trump complained about the difficulty of the USA trading more heavily with the EU given the complexity of its structures and operations, since it coincided the time that the European Council for Paints and Printing Inks and Artists’ Colours (CEPE) presented a set of proposals to the European Commission (EC) in response to the EC’s drive to lighten the administrative burden for industry.

The paint and coatings sector supply chain is, of course, very heavily burdened by the effects of EU legislation. The first part of this article looks in detail at some of the changes proposed by CEPE with a focus on those simplifying harmonization and digitalization, the latter being at the forefront of many industry and business leaders’ minds these days.

The final part of this piece provides an update on coatings end-use sectors that have been placed firmly in the spotlight of the new ESPR framework legislation (at this juncture, chiefly white goods – but more about that later).

Proposals on Simplifying Digitalization

Digitalization is a growing trend for all industries and will be even more significant for the coatings and other sectors in the future, given that the framework legislation aims at having digital product passports for every item, probably a QR code that can be scanned to access product history and information.

That area of development is still some time away, however, with the current focus on digitalization being concerned with REACH activities. Three areas ripe for improvement in the digital aspects of REACH compliance were targeted by CEPE, as follows:

• Providing affordable compliance solutions for industry, especially for SMEs – this proposal targets the excessive costs of compliance software suites. SMEs often eschew the high costs of purchasing such packages and opt to report compliance manually.

Other precedents offer an example of how this might be effected; CEPE cites the management of Poison Centre Notification procedures as a tool that could be templated by ECHA as an example. An alternative might be subsidies for SMEs to make regulatory compliance software more affordable.

• Moving towards a standard for the digital importing of safety data sheets (SDSs) – the continuous updating and exchange of SDSs between raw materials producers and formulators is propagated throughout the entire supply chain in efforts to ensure that all stakeholders access the most recent safety information.

Although the content of SDSs is standardized, their formats are not. CEPE is calling for the development of a standardized digital format that would simplify data extraction by all concerned parties, as well as reduce the related costs and time taken by industry. CEPE asked for SDSs to be made available in XML format to facilitate these matters throughout the entire supply chain.

• Allowing QR codes for the distribution of SDSs – given that QR codes are a relatively recent invention in data management that could easily streamline the interconnected management of SDSs throughout a supply chain, CEPE is seeking that this kind of technological development is adopted and exploited for good use on the part of industry.

Email is how SDSs are shared, but the reality is that excessive emails overburden the wrong people with what might be considered spam, and although it is technically desirable for professional painters to have immediate access to safety data, the likelihood is that that kind of material is data that would be held by the purchaser rather than the professional applier.

Proposals on Simplifying Harmonization

A further four of CEPE’s 19 proposals last month fell in the area of harmonization:
• CEPE is seeking a greater harmonization of environmental legislation between member states. There is considerable variation in the legislative landscapes of different EU countries, and national legislation that is independent of EU requirements often adds additional burdens for industry.

CEPE suggested that a future action plan in this area is driven by regulatory demands as opposed to directive compliance. In addition, it seeks to overcome the uneven playing field that exists between different countries with a view to improving matters within the single market.

• Also at the national level, some member states are implementing their own national legislation on product labelling for sustainability performance. This is already the experience in Spain, France and the UK. National legislation flies in the face of single market principles, and CEPE is seeking EC intervention to stop the introduction of national product labelling requirements where they diverge from those required by the EU’s harmonized rules.

• Some member states impose fees on companies submitting data through Poison Centre Notification dossiers, but not others.  Charges are levied either per dossier or as annual fees. CEPE is calling for the prohibition of such charges, which not only reduce competitiveness but also add further administrative burdens to companies. The existence of such charges is considered to be at odds with single market principles.

• Before moving on to ESPR, this final bullet ties REACH and ESPR together insofar never the twain shall meet. CEPE is seeking that the all-encompassing nature of REACH since its adoption in 2007 is a comprehensive legislative system for the safety of chemicals. It doesn’t want to see new legislation introduced that starts setting different definitions, possibilities and concerns for chemicals; instead, it wants to REACH become the reference mechanism for managing chemical risks.

Briefly, to highlight some of the other points that CEPE has targeted, these relate to improving the process time for biocides and biocidal products registration (BPR legislation) to free up the materials available to formulators, relaxation of CLP font size requirements, and the taking of action against providers of digital product passports at the national level, even though the EU’s DPP concept has not been fully discussed and finalized.

Some companies are already trying to get ahead with the DPP concept, seeing it as a gateway to information management for all, but at this stage, it’s feasible that companies may be sold systems or encouraged down paths that may not be EU-compliant in the long run.

Latest Information on ESPR

The European Commission has also recently adopted the 2025-2030 working plan for the Ecodesign for Sustainable Products Regulation (ESPR) and Energy Labelling Regulation – the first such plan as part of the framework legislation aimed at the greening of European industries and markets.

White goods and electronic goods have been included in the first working plan and are likely to be of interest to the powder coatings sector. Timelines for compliance in these segments run as follows: dishwashers – 2026; fridges and freezers, electric motors and EV chargers – all 2028; mobile phones and tablets – 2030.

It appears that these segments are first up for early EC prioritization because these are the fruits on the lower branches of the tree that should offer relatively easier routes to circularity and ESPR compliance, yet also account for almost a third (31%) of any total environmental impacts and drawing on a closely similar percentage of fossil fuel use. Supposedly easy wins.

Chemicals have not been included in the first list, but they are not far behind. Studies are already being undertaken on how chemicals should be included in a future ESPR plan, and the expectation is that this should be completed by the end of 2025, indicating that they are still a priority area. 

Falling under the chemical umbrella are steel, aluminum, textiles, furniture, mattresses and tires. Adoption timelines have already been published for these sectors: iron and steel – 2026; furniture and textiles – 2027; and aluminum and furniture – 2028. Mattresses – which may be of relevance to the polyurethane sector for foam consumption – have a target adoption date of 2029.

You can find all of the details on CEPE’s proposals to the EC here:
https://cepe.org/wp-content/uploads/2025/05/2025.05.08-CEPE-Simplification-Proposals_FINAL.pdf