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NEA’S RESPONSE TO COMMENTS RECEIVED FROM THE PUBLIC CONSULTATION ON THE ENHANCED CONTROL OF LEAD IN PAINTS IN SINGAPORE
1 The National Environment Agency (NEA) has concluded the public consultation on the enhanced control of lead in paints in Singapore. The three-week consultation exercise was open for public comments from 10 to 31 Aug 2020.
2 NEA received 13 responses from this consultation exercise. The respondents were generally supportive of the enhanced controls and suggested some refinements. NEA’s responses to the key suggestions made are summarised in the table below.
| Key Suggestions | NEA’s Response |
| Exclude the labelling requirement for zinc-based anti-corrosion paints and copper-based anti-fouling paints exceeding 90 ppm lead that are meant for re-export as the proposed labelling is specific to Singapore and not required by other countries. | NEA will not require zinc-based anti-corrosion paints and copper-based anti-fouling paints that are only meant for re-export to be affixed with the proposed labelling. |
| Allow the import of paints with total lead concentration exceeding 90 ppm for re-export to allow trading with other countries that do not restrict the lead content of imported paints. | NEA will not restrict the import of paints exceeding 90 ppm lead for re-export. Companies can continue trading in such paints with other countries. Companies will be required to obtain a Hazardous Substance Licence to import and re-export these paints. Nonetheless, NEA will continue to monitor the development in other countries and assess the need to restrict the import for re-export of paints with total lead concentration exceeding 90 ppm. |
| Extend the proposed Sep 2021 implementation date. | NEA will implement the enhanced control in Jan 2022 to allow companies sufficient time to comply with the new regulations. |
| Elaborate on the term “industrial applications” that was mentioned in the REACH consultation by including more examples relating to the use of marine paints, in particular paints for yacht. | Industrial applications also include paints that are used in the marine industry, including those for yachts. NEA will include illustrations relating to the use of marine paints when we publish the enhanced control of lead in paints on NEA’s website and in the circular that will be sent to the industry before the control measures are implemented. |
3 NEA would like to thank all stakeholders who participated in the consultation exercise. We look forward to your active participation again in our future public consultation.
Introduction
The National Environment Agency (NEA) of Singapore is seeking feedback on the proposed phase-out of paints containing intentionally-added lead. The consultation period will last 3 weeks from 10 Aug 2020 to 31 Aug 2020.
Background
2 Lead is a cumulative toxicant that poses serious risks to the environment and human health. The exposure to lead can be from occupational and environmental sources (i.e. via inhalation of lead particles and/or ingestion of lead-contaminated dust, water and food). Lead is particularly harmful to children as it permanently affects the development of their brain and nervous system. In adults, exposure to lead can increase the risk of high blood pressure and kidney damage.
3 According to the United Nations Environment Programme (UNEP), paint producers have increasingly eliminated the use of intentionally-added lead additives in their paints for architectural1 and industrial2 applications. Many countries like the United States, Canada, Philippines and India have adopted the 90 ppm total lead concentration limit, in line with the recommendation from UNEP.
Current Control of Lead in Paints
4 Since 1 Feb 1995, paints with total lead concentrations exceeding 0.06 wt% (600 ppm) are required to be labelled in Singapore. The Second Schedule of the Environmental Protection and Management Act3 (EPMA) stipulates the following:
a. Paints with red lead oxide exceeding 1 wt% (10,000 ppm) total lead concentration or other lead compounds exceeding 5 wt% (50,000 ppm) total lead concentration are to be affixed with Type 1 labels; and
b. Paints with red lead oxide between 0.06 wt% (600ppm) and 1 wt% (10,000 ppm) total lead concentration or other lead compounds between 0.06 wt% (600 ppm) and 5 wt% (50,000 ppm) total lead concentration are to be affixed with Type II labels.
Enhanced Control Measures for Lead in Paints in Singapore
5 To further protect our environment and public health, and taking into account the technological developments in the paint industry and control measures implemented by other countries, we will be making the following enhancements to the control of lead in paints:
a. The manufacture, import, export and sale of all paints, except zinc-based anti-corrosion and copper-based anti-fouling paints, with total lead concentration exceeding 90 ppm will not be allowed; and
b. Zinc-based anti-corrosion and copper-based anti-fouling paints with total lead concentration exceeding the limit of 90 ppm can only be used for industrial applications and the following label must be affixed on the paint containers:
“This paint contains lead. Restricted to industrial applications only. Do not use on furniture, buildings or in publicly accessible areas”.
6 Tentatively, the enhanced control measures will come into effect on 1 Sep 2021. Existing stocks of paints not meeting the enhanced control measures that are manufactured or imported before the effective date will be allowed to be sold until they are depleted.
Public Consultation
7 This proposal is released for the purpose of consultation. All comments received during the consultation exercise will be reviewed and may be incorporated into the final measure. Parties wishing to provide feedback should submit their comments to stefanie_koh@nea.gov.sg by 31 Aug 2020.
8 In order to ensure that the consultation is productive and focused, respondents are requested to adhere to the following guidelines when providing their feedback:
a. Identify yourself as well as the organisation you represent (if any) so that NEA may follow up with you to clarify any issues where necessary.
b. Be clear and concise in your comments.
c. Focus your comments on the proposal and how it can be improved.
d. Substantiate your points with illustrations, examples, data or alternative suggestions.
1Examples of paints for architectural applications include those for interior and exterior of buildings such as walls and roofs.
2Examples of paints for industrial applications include those conferring anti-fouling properties for marine vessels, and anti-corrosion properties for metal structures and equipment.
3More information on the labelling requirements can be found under Second Schedule of the EPMA at https://sso.agc.gov.sg/Act/EPMA1999.
