For chemists and formulators in the paints and coatings industry, the regulatory landscape is rapidly shifting from controlling a few specific chemicals to a comprehensive, group-based approach driven by the central theme of sustainability. The following recap highlights the most significant regulatory changes in 2025 and outlines the critical shifts expected in 2026 and beyond.
I. Major Regulatory Changes in 2025
The defining regulatory actions of 2025 centered on the intensification of PFAS restrictions and the continued tightening of VOC (Volatile Organic Compound) standards.
A. Per- and Polyfluoroalkyl Substances (PFAS) – The Global Hotspot
The proposed, wide-ranging EU REACH restriction on PFAS moved into a critical phase in 2025, forcing immediate action from the industry.
- Expanded Scope and Timeline: The restriction proposal, submitted by five EU nations, covers virtually all fluorinated substances. The updated version published in August 2025 broadened its scope, listing additional industrial areas.
- Implication for Formulators: Every fluorinated raw material (surfactants, binders, waxes) must be analytically mapped and assessed for substitution.
- Initial Restrictions: The EU formally adopted a sector-specific restriction in April 2025, banning PFAS in firefighting foams, signaling that restrictions in sectors with available alternatives will be swift.
- Reporting Thresholds: The proposal introduced concentration thresholds for enforcement, including a total fluorine content threshold (including polymeric PFAS) of 50 ppm.
B. Volatile Organic Compounds (VOC) – US and Global Alignment
The drive for low- or zero-VOC formulations remains the single most influential global trend.
- US Aerosol Coatings Compliance: The U.S. EPA finalized amendments to the National VOC Emission Standards for Aerosol Coatings. The major action in 2025 was the EPA subsequently extending the final compliance deadline for manufacturers from July 2025 to January 17, 2027, providing a critical window for reformulation and supply chain adaptation.
- Global Low-VOC Shift: The demand for water-borne, powder, and high-solids coatings grew significantly, driven by stringent environmental regulations and consumer demand for healthier, “green” building initiatives.
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II. What to Expect: 2026 and Beyond
The coming years will be marked by the conclusion of major regulatory processes and a growing reliance on technology to meet high-performance, low-impact specifications.
A. The PFAS Tipping Point (2026-2028)
The EU restriction is moving toward its legislative finale, forcing irreversible changes in the raw material supply chain.
- Finalized ECHA Opinion (End of 2026): The Risk Assessment Committee (RAC) and Socio-Economic Assessment Committee (SEAC) evaluations are expected to conclude by the end of 2026.
- EU Binding Legislation (2027-2028): A final, binding regulation is unlikely before 2027–2028, but the decision process itself will create immense market pressure.
- Phased Ban: We expect to see the final restriction utilizing an 18-month general transition period, with longer, use-specific derogations (five or 12 years) for applications where alternatives are not yet technically or economically feasible.
- State-Level Spreads: US state-level bans and mandatory reporting on PFAS use will continue to expand, creating a complex, multi-jurisdictional compliance challenge for any formulator selling nationwide.
B. Broader Global Regulatory Convergence and Green Chemistry
Future regulations will focus less on single substances and more on broader hazard categories and product lifecycle impacts.
- EU CLP Amendments: Europe’s upcoming CLP amendments are anticipated to add new requirements, notably focusing on endocrine-disrupting properties, obliging manufacturers to review raw material portfolios and update Safety Data Sheets (SDS).
- China’s Architectural Standard: China is expected to implement a unified architectural standard that will extend VOC limits to auxiliary materials, such as primers and sealers, significantly broadening the scope of compliance.
- Push for Bio-based Materials: Governments and consumers are driving demand for coatings derived from renewable resources and bio-based materials to reduce the carbon footprint and reliance on fossil fuels, making sustainability a core competency for all major suppliers.
- Advanced Coatings Demand: Regulatory pressure to extend product lifecycles and reduce maintenance (e.g., anti-corrosion for offshore wind, fire protection for EV batteries) will drive demand for high-performance, advanced coating technologies.
III. Actionable Steps
- Map Your PFAS Exposure Now: Use Prospector’s ingredient data and analytical testing (e.g., Total Fluorine) to identify all fluorinated components, regardless of perceived exemption status. Prepare substitution pathways for the likely 18-month ban categories.
- Plan for Zero-VOC: Target formulations that meet the strictest North American standards (like CARB) and utilize water-borne, powder, or high-solids technologies to future-proof against tightening national and regional VOC rules.
- Engage in Consultations: Pay attention to regulatory announcements from bodies like ECHA and the EPA. Public consultations are the primary opportunity for industry to provide data on the feasibility of substitutions and influence transition timelines.
Sources
- Painting the Future: A Deep Dive into the Coatings Industry Trends for 2025 and 2026
- U.S. Paints & Coatings Market Size to Reach USD 50.23 Billion by 2034
- Paints and Coatings Market Size to Worth USD 282.45 Bn by 2034 – Precedence Research
- Industrial Coatings Market Outlook 2025-2032 | Demand Rising in A
- What the EU’s PFAS restriction means for coatings and paints
- PFAS Regulation in the UK and European Union: November 2025 Overview – Fieldfisher
- EU PFAS Restriction Proposal Update: Expanding The Impact – Ohana Public Affairs
- The evolving European PFAS Restriction Proposal: where we stand in 2025 – Ricardo
- Revision of EU PFAS restriction proposal – New approach or continuity?
- Detailed Fact Sheet | EPA
- EPA VOC Guidelines For Coatings
- Architectural Coatings: National Volatile Organic Compounds Emission Standards | US EPA
- Advanced Coatings 2026-2036: Market, Technologies, Players – IDTechEx
- Paints And Coatings Market Size, Growth, Share & 2030 Report – Mordor Intelligence
- Industrial Coatings Market Size to Hit USD 176.06 Bn by 2035 – Towards Chemical and Materials
- The Global Market for Advanced Anti-Corrosion Coatings 2026-2036
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