GPP comments form
Comments from FCIO Austria
No.
1
2
3
Reference:
Criteria
document
General
comment
Section 1.1.
Page 1 to 3
and Annex 1
Section 1.1.
Page 3
Subject
of the comment
Comment
GPP more stringent than Ecolabel
GPP criteria should not be more stringent than Ecolabel criteria. The ecolabel criteria
are per definition the best products on the market, so actually it does not make sense
to make the GPP criteria more stringent. Products, which fulfill ecolabel criteria should
automatically considered as fit for GPP!
The comprehensive Criteria are too stringent and there will not be enough products
available on the market. SDS or Self Declaration should be sufficient instead of costly
external certificates.
UV curing systems, which are widely used are not tackled .This is a big deficit.
Why are the subcategories of the DeCo paints Directive “2004/42/CE not used
throughout the whole document? This is a very well-known categorization and would
enhance consistency and clarity
Suggestion to use the same wording as in the EU ecolabel criteria document, i.e.
‘product which primary function is not to form a film over the substrate, e.g. oils and
waxes;’
Question on chosen product
definitions and sub categories
PG shall not comprise: products
that do not form film over the
substrate, with the exemption of
road markings,
The quantity of paint used is
therefore an important factor
which in turn is influenced by how
much residual paint is left unused
4
Section 2.
Page 3
5
Section 3.1
Criteria 1.1
Page 5
Paints white pigment content
6
Section 3.1
Criteria 1.1
Page 5
Undercoat and primer white
content
Strange logic in this sentence. Yes the amount of paint is important, and also the
amount of unused residual paint. Importance of estimating the correct amount of paint
that is needed (so practically no leftovers will result). But the amount of paint used is
not influenced by the amount residual paint left unused. Suggestion to rephrase the
sentence
Paints shall have a white pigment content (white inorganic pigments with a refractive
index higher than 1,8) per m2 of dry film equal to or lower than 38g/m2for indoor
paints, with the exception of indoor wall paints claiming Class 1 wet scrub resistance
(WSR) for which 40 g/m2 shall apply, and 40 g/m2 for all outdoor paints.
The requested TiO2 content per m2 should be more then 25 g/m2. Under 2.1
spreading rate (table 7 on page 11) the expected spreading rate for primers and
undercoats is the same as for finishing layers (8m²/L) with this spreading rate applying
at a hiding power of 98%. This is according to the Belgian sector not feasible if the
TiO2 content is limited to 25g/m².
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8
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10
11
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Section 3.1
Criteria 1.1
Page 5
Section 3.1
Criteria 1.2
Page 6
Section 3.1
Criteria 1.2
Page 6
Section 3.1
Criteria 1.2
Page 6
Criteria 1.2
VOC p 6
Section 3.1
Criteria 1.2
Page 7
Verification
VOC
VOC classification
Table 1 VOC content limits
The requested testing results should be specified in order to be practical for public
procurers. These general specifications should be made more specific in order to
make it easy for a procurer to verify the criterion
Please add VOC definition
Request to use the subcategories of the DeCo paints Directive “2004/42/CE
throughout the whole document? (cfr comment n°.2). This is a very well-known
categorization and would enhance consistency and clarity
These VOC content limits imply that solvent based varnishes and paints can no longer
be purchased. Is that correct, the intention of these stringent limit values? I.e. is this
consistent with market information in other Member States? And is it correct to
interpret this then as an ambition to no longer want to procure solvent based
products? The sector states that even for water based products it will be hard to meet
these limits. The Belgian sector federation will gather market information on which
share of the products on the market can meet these limit values
If old buildings have to be restored, sometimes the only solution is to use (old
VOC testing (former comment not
fashioned) solvent borne products. In such cases exemptions from this criterion
addressed by JRC)
should remain possible.
VOC content verification
Please specify this, when (under which conditions) and within which time period test
results can be requested by the CA?
VOC values are calculated by producers. Most of the tenderers will be paint
wholesale/painters/suppliers and will have to request this information/test at the
manufacturers.
A general remark of the Belgian sector is that these tests (required in the whole GPP
criteria document) represent (supplementary) costs.
The question is raised whether it is an option to work with the Material Safety Data
Sheets if these mention this information
A suggestion of the Flemish government (environment administration) is to work with a
declaration of honor, but the CA retains the right to request test result. On the issue
who has to pay for the test, the following formulation was used:
Evidence = declaration of honor + CA can request test results of test according to
ISOxxx to verify the declaration of honor
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13
14
15
16
17
18
Section 3.1.
Criteria 1.3
Page 8
Section 3.1.
Criteria 1.3
Page 8
Aquatic Chronic toxicity 3 (H412)
Section 3.1
Criteria 1.4
Page 9
Section 3.1
Criteria
1.4Page 10
Preservatives - Table 5 Paint
hazardous ingredient
requirements
Metals
Section 3.1
Criteria 1.4
Page 10
Section 3.1
Criteria 2.1
Page 11
Verification:
Addition of sentence on P
statements
Spreading rates for specific paints
(outdoor)
When – based on the test- the supplied product does not comply to the
requirements set in the tender , the provider has to pay for the tests;
When – based on the test- the supplied product does comply to the requirements
set in the tender , the CA pays for the tests
The goal of this was to allow for a simple/practical way of providing evidence, but to
create a failsafe when having doubts. In this way a supplier/provider acting in good
faith has the guarantee not to incur the costs of additional tests, while
suppliers/providers who are acting is less good faith have a reason to doubt to supply
an incorrect declaration of honor. When the product does not satisfy, the costs of the
tests are supplementary to all other sanctioning mechanisms for suppliers that do not
deliver what they claimed.
To ensure good protection against both algae and Fungi, H412 is “required”. Could
H412 labelled product be authorized?
„or shall not carry a precautionary statements required for products with these
classifications.“
This newly added sentence raises a lot of questions. What is meant by „required“? P
statements are always recommended as the producer has to select the most
appropriate 6 P statements among all the applicable ones.
Additionally, a lot of paint manufacturers automatically include the consumer product P
statements (P101, P102 and P103) on all cans, regardless of the classification of the
paint. This is best practice, and ensures consistency.
Please delete this sentence or clarify it.
Preservatives concentration limits of 0,10% and 0,30%
Is this concentration limit (%) per preservative or total concentration?
We assume it is defined as total concentration (cfr as it is in the EU ecolabel criteria)
0,01% per metal
Is this percentage expressed on the metal itself or on the metallic complex/salt??
Example for Chromium(6) this formulation is clear, but for other metals such as Cd or
Pb, they often occur as complexes/salts
for preservatives: If requested by the contracting authority, a test report shall be
provided confirming that the preservatives used are non-bioaccumulative.
Please specify which test (methods) are required for the test report
For Outdoor applications, sometimes a number of coatings are necessary to be able to
guarantee a certain quality (such as impermeability for example)…The requested
spreading rates are too ambitious/not feasible for outdoor paints for a number of
(Table 7)
19
Section 3.1
Criteria 2.1
Page 11
Spreading rate elastomeric
outdoor paints
20
Section 3.1
Criteria 2.5
Page 15
Section 3.1
Award criteria
1. Page 15
Verification
21
22
23
24
Content SVOC
Section 3.1
Award criteria
2. Page 17
Section 3.1
Award criteria
3. Page 18
Isothiazolinone content
Section 3.3
Award criteria
1.2 Page 29
Potential for savings
Reusable systems
surfaces.
The Belgian sector federation will gather market information on which share of the
products on the market can meet these spreading rates (efficiencies)
Spreading rate set at 4 m²/L?
(superior) paints with long life span. These high quality paints only need a repaint after
for example 10 years (instead of the 7 year which is used in the base case in the
background document), which implies less paint used over a total lifespan of 21 years.
Suggestion to advice procurers on this aspect with a nuancing/awareness raising
paragraph on these life span/time between repaints period, somewhere in the criteria
document (referring to more extensive LCC information in the technical background
document)
Suggestion to add test method EN 13892-4 as equivalent
Here the same remarks as formulated for VOC content apply:
Request for addition of the definition of SVOC
Specify under which conditions the CA can request test results
The Belgian sector federation will gather market information on which share of the
products on the market can meet these limit values. For sub category e and f these
are non-realistic demands according to the Belgian sector
It is very confusing to include in can limits for isothiazolinones in the indoor air quality
section. These limits should be included in the hazardous ingredients section (table 6).
Which types of reusable systems exist on the European market? According to the
Belgian sector federation most packaging are metal tins, that when fully empty are
recycled as metal waste, and when not fully empty are treated as hazardous waste
A clear distinction should be made between paint waste and packaging waste
The potential for savings in the use of paint during the contract period, as well as
related savings in related overheads such as access, stopping up of highways (in the
case of road markings) shall be calculated on the basis of the planned program and
the assumptions provided.
The assumptions provided, will be provided by the CA? To determine a base case
reference for the calculation of the potential savings, right?