Fact sheet: Volatile organic compounds (VOCs) in vehicle refinishing products

Vehicle paint and varnish products must comply with VOC limit values, and must be labelled with their VOC content, product category and VOC limit value.

Import, sale and use of products that do not comply with the regulations is prohibited within the EU.

VOCs are harmful to the environment

The purpose of the regulation isto protect the environment. VOCs contribute to the formation of low atmosphere ozone and photochemical air pollution which is harmful to plants and materials. Under certain conditions, concentrations may reach levels high enough to cause airway complaints in humans.

Products for pretreatment, painting and finishing are covered by the rules

The regulations apply to products used for sheet metal work, repairs and changes of topcoat after vehicles have left the factory. They apply to solid, viscous and fluid products as well as products applied by atomization. The regulation only apply to products that form a film or membrane after drying or hardening.

If a product requires mixing or thinning before use, it is the final mixture that must comply with the VOC limit.

The products are divided into categories a, b and c for preparation, category d for topcoat and category e for special applications and aerosols. Please note that there are subdivisions for category a [a(i) and a(ii)] and category c [c(i) and c(ii)] with their own VOC limit values.

VOC limit values

Products for vehicle preparation paint is divided into 5 categories, grouped according to use, and which have different limit values.
The limit values also apply to products used industrially. Companies that work with  subjects for vehicle refinishing products is therefore covered by the rules. There are exceptions to the rules for industrial use of vehicle refinishing products.

Products used in vehicle refinishing products

Product category


VOC limit value

Preparation products

a (i)

Preparation and cleaning

850 g/litre

Pre-cleaning products

a (ii)


200 g/litre

Body filler


Body filling

250 g/litre


c (i)


540 g/litre

Wash primer

c (ii)


780 g/litre




420 g/litre

Special finishes


Special applications

840 g/litre

Products to be mixed or diluted before they are ready for use must comply with the VOC limit in the final mixture , e.g. both products for two-component products must be labelled with VOC in the ready-to-use solution according to the mixing instructions on the product. Except for subcategory a any possible water content in the product ready for use will be disregarded.


Product labels must indicate: 1) The product’s VOC content in g/litre, 2) the product category, and 3) the VOC limit value for the category. The information must appear on the label in clearly legible print, and the label must be visible to the consumer. The VOC content must be indicated for the final mixture, i.e. after thinning, if applicable.

Example product label

This product contains max. 300 g VOC/l.
EU limit value for this product (cat. d): <420 g VOC/l .
Example of product types for each category
The descriptions and lists of product types for each category below serve as a guide only and are not complete.
Category a: Preparation and cleaning products

Category a (i): Preparation products

Preparation products used to clean items prior to painting. Cleaning products include rust, varnish, and paint removers.

Various products for cleaning spray guns. Preparation products used to prepare items for varnishing, including degreasers, antistatic degreasers, silicon removers and cleaning fluids.

Category a (ii): Pre-cleaning products, degreasers and silicon removers

Category b: Body filler
Body fillers are products used to smooth out surfaces All body fillers belong to this category.

Surfacer/filler products belong to category c(i) or c(ii).

Category c: Primers

Category c (i): Primer/surfacer products and general metal primers.
Primer/surfacers, base fillers, sanded fillers, wet-in-wet fillers, metal primers, undercoats, plastic primers and sealers.

Category c (ii): Wash primer
Wash primer contains at least 0.5 per cent phosphoric acid by weight.Wash primers are designed to be applied directly to bare metal surfaces to provide corrosion resistance and better adhesion for subsequent layers.

Category d: Topcoat
Topcoat includes finishing varnish and top varnish, where finishing varnish includes uni varnish and basic varnish. The uni varnish is a one layer application, which means that supplementary varnish layers are not required. The basic varnish is a two layer varnish, which requires subsequent layer of clear varnish. The clear varnish is transparent and ensures sufficient resistance and brilliance of the surface.

Category e: Special finishes
These include effect coatings such as pearl colour and metallic paint that do not require a subsequent clear coating, scratch resistant clear varnish, , , texture finishes, underbody sealers, anti-chip coatings, interior varnish, and aerosols.

Please note that various effect coatings that require a clear varnish overcoat belong to category d (Topcoat).

Producers, importers, distributors and users are responsible

Producers, importers, and distributors must ensure products comply with the maximum VOC limit values and that products are labelled. Professional users must ensure that they only use correctly labelled products.

The Environmental Protection Agency’s chemical inspectors monitor compliance with the regulations and will ensure that illegal situations are brought into compliance. This may involve withdrawing the product from the Danish market if it cannot be made legal in some other way. Anyone who breaches the regulations may additionally face a fine or prison sentence of up to two years.

Exemptions for veteran vehicles

The Danish Environmental Protection Agency may grant an exemption if there is a special need associated with the restoration or maintenance of a veteran vehicle of particular cultural and historical value.

More information

The full text of the Danish regulations is available at retsinformation.dk:
Environmental Protection Agency Statutory Order no. 1049 of 27 October 2005 on the marketing and labelling of volatile organic compounds in certain paints and varnishes and vehicle refinishing products . (in Danish)

From 1 March 2011 it is allowed to use one more analysis when determine the VOC content at retsinformaion.dk:
https://www.retsinformation.dk/Forms/R0710.aspx?id=135510 (in Danish)

The Danish regulations are based on

Directive 2004/42/EC of the European Parliament and of the Council of 21 April 2004 on the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain paints and varnishes and vehicle refinishing products (PDF, at the EUR-lex website)

A new analysis for determination of VOC content has been added to the directive (PDF, on eur-lex website)

Relevant links and documents

The Commission collects questions and answers to the VOC regulation on EU homepage about VOC under frequent asked questions (FAQ).

EU Commission’s guide and FAQ regarding the VOC regulation for paint and varnish (On the European Commission website)

EU’s guide on reduction of VOC in paint (On the European Commission website)