PUBLIC CONSULTATION ON THE PROPOSED CONTROLS FOR FORMALDEHYDE IN PAINTS
National Environment Agency - Chemical Control and Management Department
- Consultation Period:
- 22 Nov 2023 - 13 Dec 2023
- Status:
- Closed - Summary of Responses
Consultation Outcome
NEA’S RESPONSES TO COMMENTS RECEIVED FROM THE PUBLIC CONSULTATION ON THE PROPOSED CONTROL OF FORMALDEHYDE IN PAINTS
1The National Environment Agency (NEA) has concluded its public consultation on the proposed control of formaldehyde in paints. The 3-week consultation exercise was open for public comments from 22 Nov to 13 Dec 2023.
2NEA received 9 responses from this consultation exercise. Overall, the respondents were supportive of the proposed control, with some providing feedback. NEA’s responses to the feedback are summarised in the table below.
| S/N | Key Feedback | NEA's Response |
| 1 | Better clarity on the definition of interior paints and industrial paints | The formaldehyde content limit only applies to interior paints, i.e. paints intended for application on interior surfaces of buildings. Exterior paints and industrial paints that are sold in Singapore will be subjected to labelling requirements if they contain formaldehyde. Industrial paints refer to paints for industrial application including, but not limited to, those conferring anti-fouling properties for marine vessels, and anti-corrosion properties for metal structures and equipment. |
| 2 | There are industrial products which are designed for both indoor and outdoor uses. The proposed restriction may inadvertently affect businesses involved in the industrial sector that utilise such paints. | Industrial paints1 with added formaldehyde are allowed to be sold in Singapore if they are properly labelled. |
| 3 | Consider collaborating with Singapore Environmental Council (SEC) to incorporate NEA’s required test method into Singapore Green Label Scheme | We understand that the Singapore Environment Council (SEC) does not currently specify a test method for formaldehyde in paint. NEA will engage SEC to consider alignment of test methods to the regulatory one. |
3NEA would like to thank all stakeholders who participated in the consultation exercise. We look forward to your active participation in our future public consultation.
1Paints for industrial application include, but are not limited to, those conferring anti-fouling properties for marine vessels, and anti-corrosion properties for metal structures and equipment.
Detailed Description
Introduction
The National Environment Agency (NEA) is conducting a public consultation on the proposed controls of formaldehyde (CAS Number 50-00-0) in paints. The consultation exercise will start on 22 Nov 2023 and end on 13 Dec 2023.
Background
2 Formaldehyde is a chemical which is used extensively in the manufacture of resins, as a disinfectant, or as a preservative in building products. Exposure to formaldehyde may cause adverse health effects.
Proposed Controls for Formaldehyde in Indoor Paints
3 To better safeguard public health, NEA is proposing to prohibit the sales (e.g. retail, online) of paints with formaldehyde, used for indoor applications. The details are as follows:
i. Only indoor paints with no-added formaldehyde will be allowed to be sold in Singapore.
The total in-can formaldehyde content in each paint product shall be determined for the white or transparent tinting base and for the colour tint predicted to contain the highest theoretical amount of formaldehyde. Companies will have to submit test reports to NEA indicating that the measured total in-can formaldehyde content in each product is below 0.01% w/w. Tests shall be conducted by laboratories accredited by accreditation bodies (e.g., Singapore Accreditation Council (SAC)) that are signatories to the International Laboratory Accreditation Cooperation Mutual Recognition Arrangement (ILAC MRA), for total formaldehyde content measurement in paints in accordance with the methods indicated in the table below.
| Type of paint | Total formaldehyde content measurement method | |
| Extraction of formaldehyde | Analysis of extracted formaldehyde | |
| Water-based | Acid-steam distillation [1] | (a) Photometric determination using acetyl acetone reagent [1]; or (b) High performance liquid chromatographic (HPLC) determination using 2,4-dinitrophenylhydrazine reagent [3-4]. |
| Solvent-based | An appropriate method [2] | |
[1] VdL Guideline 03: Guideline for the determination of the formaldehyde concentration in water-dilutable paints and varnishes, and polymer dispersions; or equivalent.
[2] In the absence of international standard methods, NEA is amenable to appropriate test methods validated for extraction of total formaldehyde from solvent-based paints, which the test laboratories have been accredited for.
[3] GB/T 34683: Determination of formaldehyde content in water-borne coatings – High performance liquid chromatographic method; or equivalent.
[4] HPLC method shall be used for pigmented paint products due to potential interference by pigments in the photometric method.
ii. Test reports will be valid as long as there are no changes in the paint formulations.
iii. Companies manufacturing and/or importing indoor paints with added formaldehyde for export or re-export purposes will be required to apply for a Hazardous Substances (HS) licence from NEA.
iv. Industrial paints1 and paints used for outdoor application sold in Singapore would be excluded from this requirement. Instead, such paints containing formaldehyde will have to be labelled to inform users that they contain added formaldehyde and are meant for industrial or outdoor use only and not for indoor use. More details of this label will be shared with the industry in due course but companies are welcome to share your proposed label designs and dimensions with us.
4 The proposed controls will tentatively take effect from 1 July 2025 to allow time for the industry to prepare for the proposed controls.
5 Active market surveillance and enforcement will be carried out to ensure that indoor paints sold are in compliant with the regulation. NEA may also consider extending the proposed controls to paints used for outdoor applications in future.
1Examples of paints for industrial applications include those conferring anti-fouling properties for marine vessels, and anti-corrosion properties for metal structures and equipment.
Feedback on the Proposed Controls for Formaldehyde in Indoor Paints
6 Feedback or comments on the proposed controls for formaldehyde in paints can be submitted to primus_ong@nea.gov.sg and lim_jia_fang@nea.gov.sg by 13 Dec 2023. The information provided in this exercise will be kept strictly confidential, and solely for NEA’s internal use. The information provided in this exercise will be kept strictly confidential, and solely for NEA’s internal use.
7 To ensure that the consultation is productive and focused, respondents are requested to observe the following guidelines when providing their feedback:
a) Identify yourself as well as the organization you represent (if any) so that we may follow up with you to clarify any issues, if necessary.
b) Be clear and concise in your comments.
c) Focus your comments on the proposal and how it can be improved.
d) As far as possible, substantiate your points with illustrations, examples, data or alternative suggestions.