Important regulatory information on small containers of architectural coatings

Environment and Climate Change Canada have sent the following message regarding the manufacture, import or sale of architectural coating products, such as paints, stains, varnishes, lacquers and other types of structural coatings. These goods are regulated under the Volatile Organic Compound (VOC) Concentration Limits for Architectural Coatings Regulations (the Regulations) which can found by clicking on “Architectural coatings” at www.canada.ca/volatile-organic-compounds. The objective of the Regulations is to protect the environment and the health of Canadians from the effects of air pollution by setting mandatory VOC concentration limits for 53 product categories of architectural coatings. These limits are listed in the Schedule of the Regulations.

Environment and Climate Change Canada has recently been made aware of the marketing and sale of bundled small containers. Under subsection 2(3) of the Regulations there is an exemption covering ten architectural coatings categories (listed below) that allows containers with a capacity of one litre or less to have no VOC content limit. Please note that the practice of combining multiple smaller containers of one litre or less into a larger bundle for sale does not align with the intended purpose of the Regulations and would directly contribute to ground-level ozone, smog and a general decrease in the quality of the air we breathe.

List of architectural coating exempted if their container has a capacity of one litre or less:
(a) Faux finish;
(b) Any other high-temperature coating;
(c) Any other lacquer, including lacquer sanding sealers;
(d) Any other varnish; (e) Low solids coating;
(f) Quick-dry enamel;
(g) Interior wiping stain;
(h) Exterior wood stain;
(i) Any other stain; and (j) Rust preventive coating.

Environment and Climate Change Canada will continue to monitor this issue and assess whether a new approach is necessary to achieve the objective of the Regulations. For more information on architectural coatings in general, please visit our website above.

If you have any questions, please contact the Products Division of Environment and Climate Change Canada by telephone at 1‑888‑391‑3426 or by email at ec.produits-products.ec@canada.ca.