EU Ecolabel update: Testing implications and how to prepare for recertification

Which products are covered and when do the new requirements apply?

The revised criteria apply to three main product categories: decorative paints and varnishes, high-performance coatings, and water-based aerosol paints. This broader scope acknowledges the diversity of coating technologies on the market and ensures that environmental requirements are consistently applied across different applications. 

From a regulatory perspective, the EU Ecolabel continues to function as a Type I eco-label, meaning that compliance must be demonstrated and verified by an independent third party. This ensures credibility in the market and reinforces its value for both manufacturers and end users looking for reliable sustainability indicators.

Importantly, the new criteria introduce a transition period of 18 months for products already certified under the previous scheme. This creates a limited but strategic window for manufacturers to adapt their formulations, testing strategies and documentation before full alignment with the new requirements becomes mandatory.

Key changes vs previous version

Compared to the 2014 framework, the 2025 update introduces a more structured and technically robust approach to compliance. One of the most relevant changes is the reorganisation of the criteria, particularly the consolidation and clarification of performance requirements under Criterion 2 (efficiency in use).
In parallel, the treatment of volatile compounds has been refined. Requirements related to VOCs and SVOCs are now clearly divided between content (Criterion 3) and emissions (Criterion 5), providing greater clarity and aligning the scheme with indoor air quality considerations. 

Another important evolution is the stronger emphasis on evidence-based verification. The updated regulation places greater weight on laboratory testing reports, supplier declarations and structured documentation. While some simplifications have been introduced – such as the possibility to assess product families based on worst-case scenarios – the overall approach requires a more strategic and data-driven preparation. 

Criterion 2 in detail: efficiency in use

Criterion 2 remains the technical core of the EU Ecolabel scheme and is where laboratory testing plays the most critical role. It defines how efficiently a paint or coating performs during use, ensuring that environmental benefits are not achieved at the expense of durability or functionality.

The criterion is divided into three annexes, each corresponding to a product category. For decorative paints and varnishes (Annex I), manufacturers must assess a wide range of performance properties, including spreading rate, wet scrub resistance, adhesion, water resistance and resistance to environmental conditions such as weathering or biological growth. 

What makes this particularly relevant is that the required tests depend not only on the product type but also on the claims made by the manufacturer. For example, if a product is marketed as resistant to wet scrubbing or suitable for exterior use, these properties must be demonstrated through laboratory testing following recognised standards (such as ISO methods). This direct link between marketing claims and technical validation significantly increases the importance of robust testing strategies.

For high-performance coatings (Annex II), the focus shifts towards more demanding industrial requirements such as abrasion resistance, corrosion protection and ecotoxicity. These additional parameters reflect the higher functional expectations of these products and often require more advanced testing capabilities. 

In the case of water-based aerosol paints (Annex III), efficiency in use includes specific aspects such as spray efficiency, which must reach defined thresholds. This illustrates how the regulation adapts performance criteria to the application method, ensuring consistency between environmental impact and practical use.

VOCs and SVOCs (Criteria 3 and 5)

Beyond performance, chemical composition and emissions remain central components of the EU Ecolabel.

Criterion 3 addresses the content of VOCs and SVOCs in the formulation. VOCs are defined as organic compounds with a boiling point below or equal to 250 °C, while SVOCs cover compounds with higher boiling ranges. These definitions are aligned with existing European legislation, ensuring consistency across regulatory frameworks. 

Criterion 5, on the other hand, focuses on VOC emissions, particularly for indoor applications. It requires emission testing under controlled conditions, typically using environmental chambers, to verify that products do not release harmful levels of volatile substances over time. The possibility to conclude testing earlier than 28 days if compliance is demonstrated adds some flexibility, but the technical complexity remains high. 
Together, these two criteria reinforce the importance of both formulation control and real-world environmental performance, making VOC and SVOC testing a key pillar of compliance.

Implications for manufacturers

The updated criteria introduce a more demanding but also more coherent framework for manufacturers. Companies must now approach EU Ecolabel certification as a multidisciplinary process, involving formulation, performance testing and regulatory documentation.

One of the main challenges lies in balancing environmental requirements with functional performance. Reducing VOC content, for example, must not compromise key properties such as adhesion, durability or resistance to environmental stress. This creates a need for iterative development and testing cycles.

At the same time, the stronger connection between declared properties and testing means that marketing and technical teams must work more closely together. Claims can no longer be generic; they must be supported by verifiable data. This ultimately leads to more transparent and credible products in the market.

The importance of testing

Within this new framework, testing becomes a central element of the certification process rather than a final validation step. Laboratory testing is required not only to demonstrate compliance but also to guide product development and optimisation.

Criterion 2 alone encompasses a wide range of physical and mechanical tests, while Criteria 3 and 5 introduce advanced chemical analyses and emission measurements. The reliability and traceability of these tests are critical, as competent bodies give preference to results issued by qualified laboratories to carry out this type of testing.

This context highlights the role of specialised partners such as Applus+ Laboratories, which can support manufacturers throughout the entire process—from defining the testing strategy to performing performance and VOC/SVOC analyses and generating compliant documentation.

Timeline towards 2027

The transition towards the new EU Ecolabel criteria is already underway. Following the publication of the decision in December 2025, manufacturers benefit from an 18-month transition period to update their certifications.

This means that 2026 and early 2027 will be critical years for recertification. During this time, companies must assess gaps between their current products and the new requirements, plan and execute the necessary testing, and prepare the documentation needed for submission.

Although the criteria will remain valid until 2032, the immediate challenge is to ensure a smooth transition without disruption to market access or product positioning.

Key takeaways from the EU Ecolabel update 2025

The 2025 update of the EU Ecolabel for paints and varnishes represents a significant step forward in aligning environmental performance with technical excellence. By reinforcing performance requirements under Criterion 2 and strengthening VOC and SVOC controls, the new framework raises the bar for both sustainability and product quality.

For manufacturers, early preparation and a strong testing strategy are essential to navigate this transition successfully. In this context, Applus+ Laboratories provides the technical expertise and testing capabilities needed to support compliance and accelerate the path toward recertification.