A central database for compliance declarations
Many end users are trying to set themselves apart from the competition with quality seals and labels. For paint manufacturers, the effort to comply with all the associated rules is becoming ever greater. Martina Kandler, Managing Director at Lott Lacke, explains how this could be improved.
What are compliance declarations?
Behind them are usually quality labels with which our customers and manufacturers of building products hope to gain advantages by distinguishing themselves from market competitors and emphasising special properties. Of course, there is also something like the EU REACH regulation, which is binding for all paint suppliers. When it comes to quality labels, however, the relevant data can usually no longer be found in the available technical and safety data sheets, but one has to “dig deeper”. This often involves stricter limit values and requirements than the general data from the data sheets provides. For paint manufacturers, this means that the necessary data must be determined along the entire value chain and requested from the respective suppliers.
What are the relevant labels that need to be recognised in this respect?
The most important ones that are requested include Greentag, Cradle to Cradle, IKEA IOS-MAT, Proposition List 65 and increasingly also Blue Angel, Swan Label (Nordic Ecolabelling) and Ecolabel. And then there are individual country-specific labels. Of course, we support the claim of wanting to inform the end user even better about ingredients and to sell added value as much as possible. But it ties up a lot of capacity, and every paint manufacturer basically does the same work twice and three times.
Why is the workload for compliance declarations substantial?
If, for example, we receive an enquiry for one of our coatings that contains 20 raw materials, we have to ask up to 20 different raw material suppliers for the respective label-relevant data. Some raw material suppliers want to be paid for this additional effort, others want a promise that we will buy the raw material in the end. After receiving the data, you have to document it properly, so you need databases to be able to create your own declarations of compliance. Of course, the effort is not just for one coating, but for many different formulations.
How long does this process take?
It can take several months. And this leads directly to the next problem. Nowadays, data sheets sometimes change monthly or at very short intervals. How up-to-date is my data actually at the moment when I have all the data together and submit my own declaration of conformity?
What kind of data are we talking about?
There are, for example, quality labels that demand that no more tin be contained in the coating or that only certain quantities be used. Such quantities of tin cannot necessarily be identified from common data sheets, so we cannot reach our goal without individual queries for each raw material used.
How could the situation be improved?
There are various ideas that would have to be thought through in detail. If, for example, in one month 25 different paint manufacturers query 25 identical raw materials from the same 25 raw material suppliers, it would be a win-win situation for everyone involved if, as a supplier, you could enter the most common requests for compliance declarations centrally in a higher-level database and, as a paint manufacturer, you could query the most common requests centrally in a higher-level database. Raw material manufacturer x, for example, publishes compliance declarations for his products A-F in a central database for the most common quality seals 1, 2 and 3 with the respective publication date. The 25 paint suppliers receive access data and can view and use the information relevant to them there. Of course, intellectual property would have to be protected. Access to the database should not allow any conclusions to about who has queried which raw materials.
A central database would also have the great advantage that manufacturers of products could inform end consumers more quickly about which products are compliant.
Are there already any specific cooperations?
Not so far. I have already contacted the German Association of the Chemical Industry (Verband der Chemischen Industrie e.V.) and they are interested. But it stands or falls somewhat with the way such a central database is implemented. Who will take the first step? We as paint manufacturers? Or would it not be better placed with the raw material manufacturers? If we were to join forces with other paint manufacturers and set up a database at paint manufacturer level, for example, we would soon find ourselves in a situation where it would be possible to draw conclusions about the formulations of other market players if the group were too small. So, it has to be so anonymous that nothing can be traced back and yet so open that the desired synergy effects can occur.
And this would also have great advantages for the raw material producers. Because they would not have to answer the same questions several times, but only once. I hope that a few companies will respond to this interview who are interested in improving the conventional situation.
Have you ever made the decision not to serve certain seals because the effort would be too high?
Not at all. But we do communicate very openly with our customers about the amount of work that is involved in each coating formulation.
How many resources does this tie up in your company?
We can now employ a separate department to retrieve, compile and evaluate the data and issue our own compliance declarations. In addition, various regulations are revised every few years, requiring updates and possibly bringing with them new limit values. So it’s always in motion – and the number of queries is constantly increasing.
Contact: martina.kandler@lott-lacke.de
