Analytics on paints and coatings production
1. Definition and types
In Russian legislation, the concepts of “paints” and “paint and varnish materials” (LKM) are defined in state standards (GOST), which establish terms and definitions in this area.
Paint is a paint and varnish material containing pigment, intended for application to a surface to create an opaque coating with protective and decorative properties (GOST 28246-2017 “Paint and varnish materials. Terms and definitions”).
Paint and varnish material is a liquid, paste or powder material, which, when applied to the surface to be painted, forms a coating with protective, decorative and/or special technical properties (GOST 28246-2017 “Paint and varnish materials. Terms and definitions”).
In other words, paints and paint and varnish materials are understood as substances intended to be applied to various surfaces in order to protect, decorate and give them special properties.
The production of paints and coating materials (paint and varnish materials) in the Russian Federation is regulated by a number of regulatory documents that establish requirements for the quality, safety and environmental friendliness of products.
Paints and coating materials can be qualified on various grounds and criteria, in particular, such as composition, purpose, method of application and type of protective coating.
The following types of paints and coating materials (LKM) are distinguished:
1. By composition:
Oil paints - are made on the basis of vegetable oils or their modifications and are used for interior and exterior works.
Alkyd materials - materials, the basis of which are alkyd resins, and have good adhesion and resistance to weathering.
Acrylic paints - water-based paints or paints using acrylic polymers that are resistant to moisture and sunlight.
Epoxy and polyurethane materials - materials that are characterized by high abrasion and chemical resistance and are used for industrial facilities.
Silicate and silicone paints - paints that are based on alkaline glass or silicone resins and are used for facade works.
Water emulsion paints - paints that contain water base, are environmentally safe and are used for interior works.
2. By purpose:
Decorative paints - paints that create a decorative effect, such as pearlescent, matte, glossy, and are used in interiors and exteriors.
Protective materials - materials that are designed to protect against corrosion, moisture, ultraviolet light, and other factors, including enamels.
Technical coatings - coatings that are used for specific applications, such as heat resistance or electrical insulation.
Specialty paints - paints used for road markings, aerosol paints, and flame retardants.
3. By type of protective coating:
Varnishes - transparent materials that create a glossy or matte film and emphasize the grain of wood or metal.
Primers are preparatory materials that improve the adhesion of the paint to the surface.
Enamels are color coatings with high hiding power and durability.
Putties are a material used to level the surface before painting.
4. According to the method of application:
Brush paints - paints to be applied with a brush.
Roller materials - materials that are used to work with rollers.
Sprays and aerosols - paints that are convenient for uniform coating of complex shapes.
5. By application:
Facade paints - paints that are weather resistant.
Interior paints - paints, environmentally safe, which are used indoors.
Industrial - paints and varnishes for protection and decoration of industrial structures.
Automotive paints - specialized coating paints for vehicles.
The specific type of paint or coating material is selected depending on the purpose of application, operating conditions and the type of surface to which it will be applied. Regulatory regulations for different types of paints and paintwork materials are almost identical.
2. Legal regulation and regulatory requirements
The main regulatory documents governing the production and sale of paints and coating materials are as follows:
1. GOST 28246-2017 “Paint and varnish materials. Terms and definitions”
Fixes the basic concepts and definitions affecting the sphere of production and realization of paints and paint and varnish materials.
2. GOST R 59952-2021 “Paint and varnish materials. Technical conditions. General requirements for development and design”
Defines general requirements for the construction, presentation, content, designation, design, coordination and approval of technical specifications for paint and varnish materials.
3. GOST 33290-2015 “Paint and varnish materials used in construction. General technical conditions”
Establishes technical requirements for paintwork materials used in construction, including classification, quality indicators and test methods.
4. GOST 9980.5-2009 “Paint and varnish materials. Transportation and storage”
Defines requirements for transportation and storage of paintwork materials, including conditions of transportation by different modes of transport and rules of product storage.
5. GOST 9980.3-86 “Paint and varnish materials. Packaging”
Establishes the standards of paintwork materials packaging, ensuring product safety during transportation and storage.
6. GOST 9980.4-2002 “Paint and varnish materials. Labeling”
Regulates the requirements for labeling of paintwork materials, including information on composition, date of manufacture, expiration date and storage conditions.
7. GOST 12.1.044-89 “System of labor safety standards. Fire and explosion hazard of substances and materials. Nomenclature of indicators and methods of their determination”
Regulates the methods of determination of fire-explosive properties of paintwork materials and establishes the relevant indicators.
Also a number of regulatory legal acts determine the procedure for working with paints and paintwork materials, including the Order of the Ministry of Labor of Russia from 02.12.2020 № 849n “On approval of the Rules for occupational safety in the performance of painting works” and GOST 12.3.005-75 “System of labor safety standards. Painting works. General safety requirements”.
3. Declaration of conformity, obtaining SGR and fire safety certificate
3.1 Declaration of Conformity
Production and sale of paints and paintwork materials (paintwork materials) in the Russian Federation require confirmation of conformity of products to the established quality and safety standards, which is ensured in the course of the procedure of declaration of conformity.
In accordance with the Resolution of the Government of the Russian Federation No. 2425 dated 23.12.2021, mandatory declaration of conformity applies to the following types of paints and paintwork materials:
1. enamels: pigmented varnishes forming an opaque coating.
2. Anticorrosive primers: materials preventing corrosion of surfaces.
3. Olives: oil-based formulations for impregnating and protecting wood.
For the remaining types of paints and varnishes there is a voluntary declaration procedure. Manufacturers have the right, on their own initiative, to undergo voluntary certification, confirming the compliance of products with additional quality standards. As a rule, the availability of such a certificate increases consumer confidence and competitiveness of products on the market.
The declaration procedure is multi-stage and includes the following steps:
Stage 1 - testing
Samples of products are sent to a special accredited laboratory for testing for compliance with the established requirements and standards. Specialists and experts conduct appropriate tests and determine the suitability (unsuitability) of paint or paintwork materials for use.
Stage 2 - collection and preparation of documents
The necessary package of documents is collected, which should include an application for declaration acceptance (filled in according to the form), technical documentation for the products (developed by the direct manufacturer), test reports (issued by accredited laboratories) and documents confirming the quality and safety of products (submitted in confirmation by the manufacturer).
Stage 3 - registration of the declaration
The Federal Accreditation Service (Rosakkreditatsiya) checks the entire list of documents, analyzes the test results and in case of proper compliance with all requirements - a declaration is issued, which is registered in the Unified Register of Rosakkreditatsiya.
Only after passing all the stages paints and varnishes can be put into production. Moreover, the fact of receipt of the declaration must be confirmed by appropriate product labeling. Products are labeled with the mark of circulation on the EAEU market (EAC), confirming their compliance with the requirements of technical regulations.
3.2 Obtaining SGR
State Registration Certificate (SRC) confirms the compliance of products with sanitary, epidemiological and hygienic requirements established in the territory of the Eurasian Economic Union (EAEU).
According to the Decision of the Customs Union Commission No. 299 of 28.05.2010 the list of paints and paintwork materials subject to mandatory obtaining of the State Registration Certificate (SGR) is defined.
Obtaining SGR is required for paints and paintwork materials (paintwork materials) of the following categories:
1. Paints and varnishes based on synthetic polymers dissolved in a non-aqueous medium (HS code 3208) - includes materials that include synthetic polymers dissolved in organic solvents.
2. Paints and varnishes based on synthetic polymers dissolved in aqueous medium (HS code 3209) - includes materials in which synthetic polymers dissolved in water.
3. Paints and varnishes based on acrylic or vinyl polymers (HS code 3208 or 3209) - qualify depending on the dissolution medium.
4. Pigments packaged for retail sale (HS code 3212) - includes colorants prepared for direct use by consumers.
SGR is issued by the Federal Service for Supervision of Consumer Rights Protection and Human Welfare (Rospotrebnadzor).
Issuance of SGR, as well as the declaration procedure, is a multi-stage procedure, including:
Stage 1 - preparation of documents
The package includes the following documents: application for obtaining SGR, technical documentation for products (standards, technical specifications, specifications, formulations, information on composition), product safety data sheet, instructions for the use of products (if available), layouts of labels or product packaging, registration documents of the applicant as a legal entity (certificates of OGRN, TIN, extract from the Unified State Register of Legal Entities), contract for the supply of products (in case of import of goods).
For products manufactured outside the customs territory of the EAEU, not only the manufacturer but also the importer may act as an applicant for obtaining SGR. In this case, additional documents confirming the importation of samples into the territory of the EEU, as well as a free sale certificate or a similar document from the country of manufacture, shall be provided.
Stage 2 - sampling and testing
Samples are taken to conduct special laboratory tests on the materials. Sanitary-hygienic and toxicological tests are carried out on paints and paintwork materials. Such tests can be conducted only in special accredited laboratories in order to confirm the safety of products.
Stage 3 - examination of documents and test results
Rospotrebnadzor checks the completeness and correctness of the submitted documents, as well as analyzes the results of laboratory tests for compliance with the established norms.
Stage 4 - making a decision on registration and issuance of SGR
In case of positive results of expertise and correct collection of all necessary documents, the applicant is issued a Certificate of State Registration, which confirms the safety of products and is a permit for its production and sale. Also information about the product is entered into the Register of State Registration Certificates.
Certificate of state registration is issued for a period of up to 5 years. In some cases the validity period may be limited by the shelf life of the product. A refusal to issue a SGR does not prevent a repeated application to Rospotrebnadzor for the same purpose.
3.3 Obtaining a fire safety certificate
Obtaining a fire safety certificate for paints and coating materials confirms their compliance with the established fire safety requirements, which is associated with their authorization for circulation in the Russian Federation.
According to the Decree of the Government of the Russian Federation № 241 of 17.03.2009 to paint and varnish materials for which it is necessary to obtain a certificate of fire safety, include fire retardant paints and coatings. These materials are designed to increase the fire resistance of various structures and surfaces and are used to treat metal, wooden and other surfaces to prevent ignition and slow down the spread of fire.
The procedure for obtaining a fire safety certificate consists of the following stages:
Stage 1 - application submission
The application for product certification is submitted to a special accredited body. Information about these bodies is available in the register of the Federal Accreditation Service (Rosakkreditatsiya). Control and supervision over the issuance of such certificates is carried out by the Ministry of Emergency Situations of Russia.
In addition to the application, the package of documents should include: technical documentation for the product (composition, characteristics, technical specifications), constituent documents of the applicant company (charter, extract from the Unified State Register of Natural Resources), supply contract (for imported products), ISO certificate for the quality management system (if available).
Stage 2 - product identification, sampling and testing
Experts of the certification body carry out product identification, determining its compliance with the characteristics declared by the manufacturer, as well as current regulatory requirements.
Samples of paintwork materials are selected for special tests in accredited laboratories, namely samples are tested for:
- combustibility (according to GOST 30244-94);
- flammability (according to GOST 30402-96);
- toxicity of combustion products (according to GOST 12.1.044-89);
- smoke-forming ability.
The test results are recorded in the protocol, which serves as a basis for making a decision on issuance or non-issuance of the certificate.
Stage 3 (optional) - analysis of production status
In some cases, an assessment of the state of production is carried out to confirm the manufacturer's ability to consistently produce products that meet fire safety requirements.
Stage 4 - decision on issuance (non-issuance) of the certificate
Based on the documents submitted by the manufacturer and test results, the certification body decides whether to issue or refuse to issue a fire safety certificate.
In case of a positive decision, the certificate is registered in a special register of certificates of Rosakkreditation and issued to the applicant. The said certificate is valid from 1 to 5 years. For some types of paintwork materials the certificate is valid during the shelf life of the product.
4. production requirements
According to the sanitary rules SP 2.2.3670-20, production facilities engaged in the production of paintwork materials must meet certain sanitary and hygienic requirements:
1 - proper ventilation and air purification
The ventilation system shall ensure removal of solvent vapors, dyes and other volatile substances. The concentration of harmful substances in the air of the working area should not exceed the maximum permissible concentrations (MPC) established by sanitary norms. Places where processes involving the release of toxic vapors (e.g. resin dissolution, mixing of paints) are carried out should be equipped with local exhaust systems.
2 - compliance with noise and vibration standards
The maximum noise level in production premises shall not exceed 80 dB, according to GOST 12.1.003-83. Vibration impact at workplaces shall comply with permissible levels established by GOST 12.1.012-2004. Installations for mixing, grinding and packing of paintwork materials shall be equipped with noise-protective covers, and production equipment shall be installed on vibration-absorbing bases.
3 - organization of the production waste management system
Specialized temporary storage areas shall be provided for each type of waste to prevent its release into the environment. Waste storages shall be equipped taking into account their chemical and physical-chemical properties, including resistance to aggressive substances. Wastes containing toxic substances are subject to mandatory neutralization in specialized organizations.
Producers are obliged to maintain regular control of air monitoring, noise level, equipment condition, as well as the level of emissions and pollution.
In accordance with the Resolution of the Government of the Russian Federation No. 752 dated 27.06.2017, the manufacturer of paints and paintwork materials must have:
- develop and have appropriate technical documentation for paintwork materials;
- have structural subdivisions or accredited laboratories to check the quality and safety of raw materials and materials used;
- comply with the requirement to have a share of foreign raw material components in production: not more than 50% from 01.01.2021.
All paints and varnishes in the course of production shall comply with product quality indicators, such as coating appearance, mass fraction of non-volatile substances, degree of rubbing, drying time and others. Appropriate requirements shall be established for each type of paints and varnishes and paintwork materials.
5. Requirements for storage and transportation
Paints and varnishes are subject to certain storage conditions, in particular:
1. paints and varnishes must be stored in closed storage rooms at an ambient temperature of -40 °C to +40 °C.
2. Paints and varnishes may be stored on planned sites under a canopy, but only those that are protected from direct sunlight and atmospheric precipitation.
3 The containers with paintwork materials should be placed with the caps and lids upwards.
4. When stored in metal transport containers it is allowed to stack not more than 5.5 meters high.
5. Paints and varnishes belonging to dangerous goods shall be stored separately from other particularly dangerous and hazardous substances.
Regarding the transportation of paints and varnishes it is worth mentioning the following requirements:
1. paints and varnishes shall be transported in covered vehicles providing protection from atmospheric precipitation and direct sunlight.
2. It is allowed to transport paints and varnishes by road in open specialized vehicles, provided that the cargo is protected from the external environment.
3. For rail transportation in small consignments, consumer and transport packaging conforming to GOST standards shall be used.
Paints and varnishes classified as dangerous goods according to GOST 19433-88 “Dangerous Goods. Classification and marking”, must be transported in accordance with the rules of transportation of dangerous goods on the appropriate mode of transport. Packaging of such materials must comply with the requirements of GOST 26319-84 “Dangerous Goods. Packaging”.
During transportation and storage of paintwork materials it is necessary to comply with fire safety requirements established by GOST 12.1.004-91. Fire hazard of a particular paintwork material is specified in the normative or technical documentation for this material.
Compliance with storage and transportation requirements ensures safety of paintwork materials, personnel safety and minimizes the impact of paintwork materials on the environment during their transportation and storage.
6. Requirements for packaging and labeling
GOST standard establishes requirements for packaging of paintwork materials to ensure their safety and security during storage and transportation. Labeling of paints and varnishes should be applied directly to the container or on the label attached to the container, using materials resistant to external influences.
The following mandatory requirements are imposed on the packaging of paints and varnishes:
1. paints and varnishes should be packed in containers that correspond to their physical and chemical properties and provide protection from external influences.
2. It is allowed to use metal, glass, plastic and combined containers that meet the requirements of standards for specific types of paints and varnishes in the packaging of paints and varnishes.
3. Packaging shall ensure tightness, preventing leakage of contents and protection from moisture, dust and other contaminants.
4 The packaging shall have sufficient strength to withstand mechanical loads during transportation and storage.
5. The packaging material must be chemically compatible with the contents, excluding the possibility of reaction with the paintwork materials.
A number of requirements for labeling of paintwork materials are necessary to inform consumers and ensure safety when handling the products.
The mandatory elements of marking of varnishes and paintwork materials are as follows:
1. Product name - the exact name of the paintwork materials.
2. Name and trademark of the manufacturer - detailed information about the manufacturer, including postal address for sending claims.
3. mass or volume - the quantity of the contents in the specified unit of measurement.
4. Date of manufacture - the date, month, and year of manufacture.
5. Shelf life or storage period - the period during which the paintwork product retains its properties.
6. Storage conditions - recommendations on temperature regime and other storage conditions.
7. Standard or technical conditions designation - reference to the normative document, in accordance with which the product is manufactured.
If necessary, danger signs are placed on the package in accordance with GOST 19433-88 “Dangerous Goods. Classification and marking” and GOST 14192-96 ‘Marking of cargoes’.
Labeling should be made in Russian. For products intended for export, additional labeling in the language of the importing country is allowed.
7. Occupational safety in production
Since paints are specific goods, the current legislation sets a number of requirements to the organization of labor in the production and sale of paints and varnishes in order to ensure the safety of employees and protection of their life and health. These requirements should also be taken into account when organizing such production.
Ensuring labor safety in the production of paintwork materials includes:
1. training and instruction of personnel:
- Conducting introductory, primary and periodic briefing on labor safety;
- training in safe methods of working with paintwork materials.
2. Medical examinations of personnel:
- preliminary and periodic medical examinations of employees;
- control over the state of health of employees.
3. technical measures:
- control of concentration of harmful substances in the air of the working area;
- use of closed systems of mixing and supply of paintwork materials;
- installation of effective systems of general exchange and local exhaust ventilation.
4. electrical safety:
- Use of explosion-proof electrical equipment;
- regular checks of earthing and condition of electrical wiring.
5. Personal Protective Equipment (PPE):
- Use of respirators or masks with filters when working with volatile substances;
- wearing overalls, gloves, goggles or face shields.
6. Fire safety:
- storage of paintwork materials in special premises equipped with fire extinguishing system;
- compliance with the norms on the quantity of stored materials and their compatibility;
- availability of fire extinguishers and other fire extinguishing equipment at workplaces.
7. Control of working hours:
- limitation of time spent in areas with increased concentration of harmful substances;
- organization of breaks between working hours for recovery.
8. Waste management:
- Use of special containers for paintwork waste;
- transfer of waste to specialized organizations for disposal.
9. Pollution prevention:
- prevention of paintwork materials getting into soil and water bodies;
- cleaning of equipment and containers from material residues.
10. Monitoring and control:
- Carrying out industrial control over labor conditions;
- laboratory tests of the working area air;
- keeping logs of briefings, medical examinations, equipment inspections.
Ensuring labor safety when working with varnishes and paintwork materials is a complex and comprehensive task requiring compliance with a large number of regulatory requirements, preventive measures and constant monitoring of the condition of workplaces and health of employees.
8. Key findings
The production and sale of paints and coating materials (LKM) require compliance with strict sanitary, fire and environmental regulations, as well as mandatory confirmation of product conformity. This includes the use of certified raw materials, quality control, proper packaging and labeling, and ensuring workplace safety. Special attention is paid to mandatory conformity confirmation procedures, such as declaration, obtaining state registration certificate (SGR) and fire safety certificates for certain types of paint and varnish products.
Compliance with the requirements guarantees the safety of consumers and employees, strengthens the company's market position and reduces environmental risks. Violation of the norms leads to administrative, civil or criminal liability, which emphasizes the importance of compliance with the established regulations. For this reason, in case of launching a business related to the production and sale of paints and varnishes or having an existing enterprise in this area, it is worth contacting competent lawyers.
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David Glickstein, manager. I write articles, looking for interesting information and suggesting ways to use it in practice. I believe that through quality legal analytics, clients come to the law firm, not the other way around. Wouldn't you agree?
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