The Finnish Commerce Federation and the Finnish Grocery Trade Association wish to express as their common view regarding the proposal for revision of ecolabelling of indoor paints and varnishes the following:

General aspects

Promotion of environmentally friendly products is important and we appreciate different efforts towards development of less hazardous chemical products. However, we also see that transparency, scientific soundness and uniformity of evaluation criteria of similar labellling systems are important in reaching the goal in a broader context. We think that although being a voluntary system, ecolabelling, should not hinder free movement of products. Also unnecessary burden and costs are faced by companies as a result of certain differences in the basic definitions between two systems.

More stringent environmental and health criteria and difference between EU and Nordic requirements

In our view the Nordic ecolabelling criteria for indoor paints and varnishes should be as harmonized as possible compared to the corresponding  EU Ecolabelling criteria. Especially the use patterns of this particular group of products is pretty similar around Europe. Thus, there is hardly any need for tighter health-based criteria in Nordic countries. In principle, any deviation to more stringent requirements should be evidence-based.

Secondly, as CLP and the “old” classification and labelling system have certain differences in the classification thresholds, the inclusion of hazard classes should be considered at category level and avoid automatic inclusion of more stringent criteria if not justified for other reasons. We hope that this has been taken into account.

New or emerging issues and precautionary principle

The precautionary principle is widely applied in managing risks both form more convenient techniques and products and, even more importantly, from new and less studied sources. However, in our view the proposed approach for nanoparticles is overly ambiguous in the light of prevailing understanding of the nature and behavior of nano-size particles and finished nano-based materials. Excluding the manufacturing phase where worker safety issues are taken care by specific legislation together with the precautionary principle, finished nanomaterials should not be categorically regarded as a threat and risk for human beings nor for the environment.

All the latest scientific evidence should be taken into account in considering this criteria, e.g. the final opinion of the Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR), "Scientific Basis for the Definition of the Term “nanomaterial” where it is stated that "It should be stressed that “nanomaterial” is a categorisation of a material by the size of its constituent parts. It neither implies a specific risk nor does it necessarily mean that this material actually has new hazard properties compared to its constituent parts."  (final opinion 2010, p31)


Finnish Commerce Federation Finnish Hardware Association, DIY Finnish Grocery Trade Association
Juhani Pekkala Harri Fagerlund  Kari Luoto
Managing Director Managing Director Managing Director