March 9th, 2022
The General Administration of Customs of the People's Republic of China issued an order abolishing the “Measures for the Supervision and Administration of the Inspection of Imported Paints and Coatings.”
As a result of Order No. 257, the filing and mandatory testing requirements of imported paint and coatings in China has been revoked, among other repealed regulations. The order officially went into effect at the time of its announcement on March 1.
Import Paint History
According to the Chemical Inspection and Regulation Service Group, the filing and testing of imported paint and coatings in China was first implemented in 2018. The requirement was filed under the “Measures for the Supervision and Administration of the Inspection of Imported Paints and Coatings.”
At the time, the new requirement, also known as Order No. 18, was filed by the General Administration of Quality Inspection. Sometime later, the requirement was amended by the General Administration of Customs through Order No. 238 and 240.
According to the order, manufacturers, importers or importing agents of certain imported paints and coatings were required to submit product filings to designated bodies affiliated with Chinese Customs and have mandatory testing accepted at least two months prior to the import.
Upon meeting these import requirements and testing successfully, manufacturers, importers or the importing agent would receive a filing certificate.
What Now
As a result of the Decision of the General Administration of Customs on Abolishing Certain Regulations, as of March 1, the filing of imported paints and coatings in China has been abolished.
However, while the filing and testing measures have been canceled, reports note that China’s national standard for harmful limits related to paints and coatings will remain in effect. Furthermore, it continues to be important that related enterprises conduct self-checks after the abolishment of the filing of imported paints and coatings as Customs will still spot-check the products.
The national standards for harmful limits relating to imported paints and coatings are as follows:
Limit of Harmful Substances of Woodenware Coatings (GB 18581-2020);
Limit of Harmful Substances of Agricultural Wall Coatings (GB 18582-2020);
Limit of Harmful Substances of Industrial Protective Coatings (GB 30981-2020);
Limit of Harmful Substances of Vehicle Coatings (GB 24409-2020);
Limit of Harmful Substances of Coatings for Toys (GB 24613-2009);
Limit of Harmful Substances of Interior Floor Coatings (GB 38468-2019);
Limit of Harmful Substances of Marine Coatings (GB 38469-2019);
Paints and Coatings for Food Contact (GB 4806.10-2016); and
General-Specification for Drinking Water Tank Coating of Shipbuilding (GB 5369-2008).
In addition to abiding by harmful limits, paint and coatings will still need to meet the requirements of the “Volatile Organic Compound Content Limit Standard for architectural coatings and Adhesives.”
Recent Manufacturing, Import Rules in the U.S.
Two years ago, in March 2019, the U.S. Environmental Protection Agency issued a final rule to prohibit the manufacture and importing, processing and distribution of methylene chloride in all paint removers for consumer use.
The rule arrived some years after the EPA announced that it would be considering a ban on the use of the chemical, having determined under the Obama administration that methylene chloride in paint-strippers placed consumers, workers and bystanders at an unreasonable risk of injury.
The rule was slated to take place 180 days after the effective date of the final rule, which was meant to provide time for establishments selling the chemical to consumers to come into a compliance with EPA’s ban. With companies had already discontinued the manufacture and sale of products containing methylene chloride at the time, the EPA expected that many suppliers would implement the rule sooner.
That November, the EPA announced that its decision to ban all retail distribution of methylene chloride to consumers for paint and coatings removal officially went into effect.
At the time, the EPA was continuing to work through the Toxic Substances Control Act process to review the chemical’s risks, and accepted comments on the draft risk evaluation until Dec. 30, 2020. The EPA also hosted a public peer review meeting of the Agency's Science Advisory Committee on Chemicals from at the beginning of that month.
Methylene chloride was the fifth of the first 10 chemicals to undergo the risk evaluation under the amended TSCA. The evaluation will review the risks associated with the uses of methylene chloride before the agency decides what, if any, further actions to take.