Legal Requirements on VOC emissions
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VOC in the international regulatory scenario
Several VOC regulations have been established in Europe within the last years. A harmonized approach as part of the Construction Product Regulation (EU) No 305/2011 is planned since several years, but could not yet be implemented. Some EU member states established national requirements while other EU member states are awaiting a common approach.
National VOC emission requirements in Europe are:
- Belgian VOC Regulation
- French VOC Label
- German ABG Regulation
- Italian CAM Regulation
- CE labelling - Construction Product Regulation (EU) No 305/2011
We offer testing according to these regulations and is EU Notified Body for VOC emission testing according to EN 16516 including accreditation and is accepted testing, certification and surveillance body.
Belgian VOC Regulation - Royal Decree C – 2014/24239
This decree is compulsory for flooring products, such as: floor coverings, levelling compounds for floorings, flooring adhesives, floor coatings, resin-based flooring compounds and systems, flooring tapes, which are sold on the Belgian market. The decree explicitly states it is forbidden to commercialize or make available any product not meeting the requirements.
The Belgian Decree includes requirements on VOC and CMR emissions. The limit values are applied to the total VOC and SVOC emissions, R-value and emissions of acetaldehyde, toluene and formaldehyde as well as to emission of CMR (carcinogenic, mutagenic and reprotoxic) substances of categories 1A and 1B.
The Belgian VOC Regulation is based on the European Construction Products Regulation (EU) No. 305/2011. Companies bringing construction products concerned on the Belgian market must be able to provide evidence that their products are compliant with the requirements stated in the Decree after a 28-days VOC emission testing in a ventilated chamber in accordance with EN 16516 / ISO 16000. The laboratory conducting the measurement must be accredited according to ISO 17025.
Following emission limit values apply:
|
Parameter |
Test after 28 days |
|
Limit Value |
|
|
TVOC (EN16516) |
≤ 1000 |
|
TSVOC |
≤ 100 |
|
R-value (dimensionless) |
≤ 1 |
|
Total carcinogens |
≤ 1 |
|
Toluene |
≤ 300 |
|
Formaldehyde |
≤ 100 |
|
Acetaldehyde |
≤ 200 |
The Belgian Decree is very explicit in describing the requirements of the FPC (Factory Production Control): it describes what needs to be done in order to prove product compliance.
French VOC Label (Décret n° 2011-321)
|
The French VOC Label is compulsory for construction and decoration products sold on the French market like floorings, wooden panels, levelling compounds for floorings and walls, wall coverings, insulation, acoustic ceiling panels, gypsum boards, adhesives, sealants, paints, floor coatings, resin-based flooring compounds and systems, tapes, technical textiles. Products must be labelled with an official label, showing their emission class (A+, A, B or C), resulting from 28-days VOC emission testing in a ventilated chamber according to ISO 16000. The manufacturer can self-declare the emission class based on emission testing according to ISO 16000 in combination with the European Reference Room according to EN 16516). An emission test is not necessarily required if other information allow assignment of the product to an emission class. |
|
Classification is based on following emission limit values:
|
|
CAS No. |
μg/m3 |
μg/m3 |
μg/m3 |
μg/m3 |
|
TVOC |
|
> 2000 |
< 2000 |
< 1500 |
< 1000 |
|
Formaldehyde |
50-00-0 |
> 120 |
< 120 |
< 60 |
< 10 |
|
Acetaldehyde |
75-07-0 |
> 400 |
< 400 |
< 300 |
< 200 |
|
Toluene |
108-88-3 |
> 600 |
< 600 |
< 450 |
< 300 |
|
Tetrachloroethylene |
127-18-4 |
> 500 |
< 500 |
< 350 |
< 250 |
|
Ethylbenzene |
100-41-4 |
> 1500 |
< 1500 |
< 1000 |
< 750 |
|
Xylene |
1330-20-7 |
> 400 |
< 400 |
< 300 |
< 200 |
|
Styrene |
100-42-5 |
> 500 |
< 500 |
< 350 |
< 250 |
|
2-Butoxyethanol |
111-76-2 |
> 2000 |
< 2000 |
< 1500 |
< 1000 |
|
1,2,4-Trimethylbenzene |
95-63-6 |
> 2000 |
< 2000 |
< 1500 |
< 1000 |
|
1,4-Dichlorobenzene |
106-46-7 |
> 120 |
< 120 |
< 90 |
< 60 |
Decisive for the classification is always the worst case emission value of the listed parameters. For example, if all components of a tested product except from one showed class A+, but the one particular component has an emission value belonging to class B, the product cannot be declared higher than B.
German ABG Regulation (MVV TB Annex 8)
The German ABG regulation is compulsory for buildings using certain construction products installed indoors like floor coverings, flooring underlays, flooring adhesives, floor coatings, reactive fire protective coatings, insulation based on phenolic foam and UF foam, plastic based wall and ceiling coverings, HPL and OSB panels as well as particle boards.
The ABG regulation includes requirements on VOC emissions with limit values of the total VOC emissions after 3 and 28 days, including assessment of carcinogenic VOC and a list of single VOC with LCI value (Lowest Concentration of Interest). Certain products need to show compliance with ammonia and nitrosamine emissions as well as content of PAH (Polycyclic Aromatic Hydrocarbons) and nitrosamines.
Testing requirements for product emissions are similar to the German AgBB scheme with VOC testing after 3 and 28 days, based on EN 16516 test method. Following limit values need to be fulfilled:
|
Parameter |
Limit value |
Limit value |
|
Carcinogens (Cat. 1A/1B) |
≤ 0.01 mg/m3 |
≤ 0.001 mg/m3 |
|
TVOCspez |
≤ 10 mg/m3 |
≤ 1.0 mg/m3 |
|
TSVOC |
|
≤ 0.1 mg/m3 |
|
TVOC without LCI value |
|
≤ 0.1 mg/m3 |
|
R-value |
|
≤ 1 |
|
Ammonia (criteria for smoked wooden flooring) |
|
≤ 0.1 mg/m3 |
|
Nitrosamines (criteria for rubber products releasing nitrosamines) |
|
≤ 0.0002 mg/m3 |
As deviation from the EN 16516 the ABG regulation defines a so called TVOCspez, which is the sum of all compounds with LCI values (including SVOC, but not VVOC) quantified with own response factor and VOC without LCI value including not identified compounds quantified as toluene equivalent. SVOC with LCI value will not be calculated into the TSVOC.
LCI values are defined in the German AgBB scheme from 2018, which is being updated frequently (usually on a biannually basis). LCI values are harmonized with European LCI values to a large extend.
Products with mandatory CE label that are within the scope of this regulation (like floor coverings, plastic based wall coverings, insulation based on phenolic foam and UF foam, HPL and OSB panels and particle boards) would require official verification documents (Gutachten) by a Technical Assessment Body (see above). For textile floor coverings, notified testing laboratories can be used, e.g. a Eurofins company.
Products with identical or similar recipes and constructions can be grouped into homogeneous product groups. Worst case product of each group is selected and tested. Compliance with the requirements shall be tested within a surveillance procedure on an annual basis including inspection of the production facilities, especially the Factory Production Control. We can provide both testing, inspection and creation of official verification documents (Gutachten).
Products without CE label that are within the scope of this regulation (like flooring adhesives, flooring underlays, floor coatings) need to have a technical approval issued by German DIBt. This technical approval (Ü-mark) will be valid as proof of compliance with the ABG requirements. The Ü-mark includes initial testing and a DIBt approval. Validity of the Ü-mark is five years without frequent testing or surveillance of the production facilities.
Italian CAM Regulation
The Italian CAM Edilizia was published in G.U. Serie Generale n. 259 in 2017 with an update from June 2022 and is also known as Green Public Procurement (GPP). VOC emission requirements are included in chapter 2.3.5.5.
This regulation is compulsory for products used in Italian public buildings or used in private buildings, which receive government funding. Approval of products is part of the tendering or funding procedure. In detail this regulation concerns construction, decoration and furnishing products, such as: paints and coatings, textile floor and wall coverings, laminated flooring, wooden flooring, other flooring (not ceramic tiles), adhesives and sealants, wall panels (e.g. plasterboards). There is no official label connected to the requirements, which can be used on tested construction products.
According to the CAM chapter 2.3.5.5 requirement, manufacturers must be able to provide evidence that their products are compliant with the requirements stated in the Decree after a 28-days VOC emission testing in a ventilated chamber in accordance with EN 16516 / ISO 16000. The laboratory conducting the measurement must be accredited according to ISO 17025. The CAM regulation is officially mentioning Eurofins Indoor Air Comfort Gold as compliance path.
Following emission limit values apply:
|
Parameter |
Product Emission Limit value after 28 days, μg/m3 |
|
Benzene |
< 1 |
|
Trichloroethylene |
< 1 |
|
DEHP |
< 1 |
|
DBP |
< 1 |
|
TVOC |
< 1500 |
|
Formaldehyde |
< 60 |
|
Acetaldehyde |
< 300 |
|
Toluene |
< 450 |
|
Tetrachloroethylene |
< 350 |
|
Xylene |
< 300 |
|
1,2,4-Trimtehylbenzene |
< 1500 |
|
1,4-Dichlorobenzene |
< 90 |
|
Ethylbenzene |
< 1000 |
|
2-Butoxyethanol |
< 1500 |
|
Styrene |
< 350 |
CE labelling - Construction Product Regulation (EU) No 305/2011
For the time being the Construction Product Regulation (EU) No 305/2011 does not contain requirements on VOC emission testing, only on release of formaldehyde determined by EN 717-1 and classification with the formaldehyde class E1 or E2
But the aim is to include VOC emission in the regulation, which would become part of the CE label and Declaration of Performance for construction products. First steps are already taken. In 2017 the horizontal test method EN 16516 was published, which defines testing scenarios and analytical methods. The EU LCI Working Group is defining LCI values (Lowest Concentration of Interest) for a list of VOC, which will be used for assessing single compounds.
Next step, which is being intensively discussed, is to establish a class system for VOC, CMR substances, LCI compliance and formaldehyde, which can be used for classifying construction products on the Declaration of Performance. Several proposals have been made, but there is no consensus yet.
Final step would be that single product standards are adding VOC testing to their requirements and then manufacturers can declare emission properties of their products as part of the CE label.
We are Notified Body for testing formaldehyde emissions according to EN 717-1, which is already required for certain floor coverings and suspended ceilings. And we are Notified Body for the harmonized standard EN 16516.
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