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:

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:

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:

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:

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.

LEED (Leadership in Energy and Environmental Design) is a voluntary green building certification program originated in the United States of America and meanwhile used worldwide. LEED began in 1993, but has evolved since 1998 to more accurately represent and incorporate emerging green building technologies. The pilot version was LEED New Construction (NC) v1.0.

LEED is developed by the non-profit organization U.S. Green Building Council (USGBC) and granted by the Green Building Certification Institute (GBCI) as well as other national Green Building organisations.

The certification institute arranges third-party verification of a project's compliance with the LEED requirements. The certification process for design teams consists of:

• Design application, under the purview of the architect and the engineer and documented in the official construction drawings;
• Construction application, under the purview of the building contractor and documented during the construction and commissioning of the building.

Current version is LEED v4, but the new version LEED v4.1 is published as a Beta Version and can already be used. On the other hand, US Green Building Council still can make changes.

Major parameters and highlights within LEED v4.1 are:

• Integrative Process
• Location and Transportation
• Sustainable Sites
• Water Efficiency
• Energy and Atmosphere
• Materials and Resources
• Indoor Environmental Quality

As part of the Indoor Environmental Quality section, LEED v4.1 defines requirements for Low-Emitting Materials. The intent is to reduce concentrations of chemical contaminants that can damage air quality and the environment, and to protect the health, productivity, and comfort of installers and building occupants.

Emission criteria are defined by product type like:

• Paints and Coatings
• Adhesives and Sealants
• Flooring
• Wall panels
• Ceilings
• Insulation
• Composite Wood
• Furniture

Construction products, paints and coatings should be tested for VOC emissions according to the California Department of Public Health (CDPH) Standard Method v1.2–2017 and shall comply with the target CREL VOCs and their maximum allowable concentrations. Three TVOC ranges are defined as 0.5 mg/m3 or less, between 0.5 and 5 mg/m3, or 5 mg/m3 or more. This type of test would be valid proof for LEED projects around the globe including USA.

LEED v4.1 is defining an Alternative Compliance Pathway (ACP) for LEED projects outside the USA. According to this ACP, products should be in compliance to testing standard EN 16516, the German AgBB Scheme thresholds and shall meet a formaldehyde limit of 10 micrograms per cubic meter after 28 days. Indoor Air Comfort Gold is mentioned as Alternative Compliance Pathway.

Additionally, liquid applied products like paints, coatings, adhesives and sealants shall comply with VOC content criteria. Testing and evaluation shall be done according to CARB or SCAQMD rules by using gravimetric test methods. Paints and coatings for LEED projects in Europe may instead meet European Decopaint Directive as Alternative Compliance Pathway.

Products like composite wood and furniture require different type of testing:

Composite Wood shall be in compliance with formaldehyde emission criteria like for example CARB, TSCA or ULEF. Composite wood products for projects in Europe may instead show compliance with emissions class E1 as tested per EN 717-1 or EN 16516.

Furniture shall be tested and evaluated in accordance with ANSI/BIFMA.

Eurofins companies offer testing according to the requirements of LEED.

Products which are Indoor Air Comfort Gold certified, automatically fulfil the VOC emission related requirements according to the Alternative Compliance Path for projects outside the USA.

BREEAM is a voluntary assessment label of the sustainability performance of individual buildings, communities and infrastructure projects originated in the United Kingdom. BREEAM is issued by BRE (Building Research Establishment).

BRE is a centre of building science in the United Kingdom, owned by a charitable organisation the BRE Trust. It is a former UK government national laboratory and provides research, advice, training, testing, certification and standards for both public and private sector organisations in the UK and abroad.

BREEAM is an international scheme that provides independent third-party certification of the assessment of the sustainability performance of individual buildings, communities and infrastructure projects. Assessment and certification can take place at a number of stages in the built environment life cycle, from design and construction through to operation and refurbishment.

Other local BREEAM organisation are established in the USA, The Netherlands. Norway, Spain, Sweden, Germany, Austria, Switzerland, and China.

In case of BREEAM, third-party certification involves the checking – by impartial experts – of the assessment of a building or project by a qualified and licensed BREEAM Assessor to ensure that it meets the quality and performance standards of the scheme. At the heart of this process are certification bodies – organisations with government approval (through national accreditation bodies) to certifiy products, systems and services.

The main output from a certified BREEAM assessment is the rating. A certified rating reflects the performance achieved by a project and its stakeholders, as measured against the standard and its benchmarks. The rating enables comparability between projects and provides reassurance to customers and users, in turn underpinning the quality and value of the asset. The BREEAM ratings range from “Acceptable” (In-Use scheme only), “Pass”, “Good”, “Very Good”, “Excellent” to “Outstanding”. This rating is reflected in a series of stars on the BREEAM certificate.

BREEAM measures sustainable value in a series of categories, ranging from energy to ecology. Each of these categories addresses the most influential factors, including low impact design and carbon emissions reduction; design durability and resilience; adaption to climate change; and ecological value and biodiversity protection.

Within the Health and Wellbeing category, credits are awarded for specifying materials that minimize emissions from construction products, e.g. formaldehyde or volatile organic compounds (VOCs). These criteria involve meeting emission level performance requirements in accordance with compliant performance and testing standards. There are general level criteria and exemplary level criteria with stricter limit values, grating more BREEAM credits. This is defined in Section “Hea 02 Indoor air quality”.

Emission criteria are defined by product type like:

• Interior paints and coatings
• Wood-based products (including wood flooring)
• Flooring materials (including floor levelling compounds and resin flooring)
• Ceiling, wall, and acoustic and thermal insulation materials
• Interior adhesives and sealants (including flooring adhesives)

Additionally, interior paints and coatings shall comply with VOC content criteria.

BREEAM published a list of recognised schemes for emissions from construction products depending on product type and level criteria.

Eurofins companies offer testing according to the requirements of BREEAM International. Products which are Indoor Air Comfort Gold certified, automatically fulfil the VOC emission related requirements of the general level and exemplary level criteria of BREEAM for all product types.

The EMICODE® label certifies flooring installation products, adhesives and further construction products like for example sealants, joining products, wall panels as well as lacquers, finishes and oils for parquet, for mineral floorings and for resilient floorings.

The label is administrated by the German association GEV (Gemeinschaft Emissionskontrollierte Verlegewerkstoffe, roughly translated as Association of low emitting installation products). Manufacturers using the EMICODE® label are members of GEV and have the possibility to participate in the technical advisory council, which is defining the EMICODE® test method and classification criteria. There are requirements on VOC and SVOC emissions. There are further requirements on use of solvents and oximes and on toxicity of the product as well as classification according to CMR and SVHC of used substances.

The manufacturer of the product is responsible for grouping and selecting the representative worst case product of the group. This representative product should be tested according to the GEV test method by a listed laboratory. As result of a 28-days VOC emission testing in a ventilated chamber, the product can be classified in the classes EC2, EC1 and EC1Plus. The classification is based on following emission limit values:

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 EC1Plus, but one particular parameter has an emission value belonging to class EC1, the product will be classified as EC1.

With the test report, the manufacturer can apply for the EMICODE® certificate directly at the GEV association. Manufacturers have to be member of GEV for using the EMICODE® label. Certificates will be valid for 5 years.

GEV has a range of quality assurances for the EMICODE® label, including cooperation with an expert group of laboratories for improving the GEV test method and organization of round robin tests. Annual spot tests of certified products are organized for checking compliance with the claimed EMICODE® class.

The EMICODE® label has a broad international acceptance, especially for certification systems for sustainable buildings like LEED, BREEAM or DGNB.

The M1 label from Finland certifies low-emission products like building and decorative materials, fixtures (like kitchen cupboards, worktops, doors), furniture like tables, chairs, office chairs, shelves and drawers.

The label is issued by The Finish Building Information Foundation RTS (Rakennustietosäätiö RTS sr), which is Finland’s leading information service for the building and construction sector. Its mission is to foster and promote good architect and engineering practices in the building sector. The Foundation is a private institution with representatives from 54 Finnish organisations related to construction sector.

The M1 label includes requirements on VOC, formaldehyde and ammonia emission according to EN 16516 and odour testing according to ISO 16000-28 (acceptance).

Below table shows the single limit values.

First step of the M1 certification is the decision whether a single product or a product group shall be certified. Products that have very similar physical and chemical properties and application, can be considered as a product group. Classifying products as a group must be first agreed on with the technical working group of RTS. RTS takes the suggestions from the manufacturer in consideration when forming the groups. Representative worst case products are selected for testing in an approved testing laboratory before submitting the application.

After receiving the test result from the testing laboratory, manufacturers can apply for M1-classification and will receive the M1 certificate afterwards. The certificate and the right to use the M1-label is valid for three years. If the composition and method of manufacturing the product has not changed, the classification can be continued with a continuation application for another three years without testing. After 6 (3 + 3) years the product must be tested again and a renewal application would be necessary.

Blue Angel (Blauer Engel) is a German certification for products and services that have environmentally friendly aspects. Provider of the label is the German Federal Ministry of the Environment, Nature Conservation and Nuclear Safety and the label itself is administrated by the institute RAL. The specifications are defined by a jury consisting of representatives of EPAs, consumer organizations, industry, retailers, universities, media and governmental institutes.

Blue Angel defines criteria for more than 100 different product types covering a broad range of consumer products, consumables, construction products and decorative products. Among these, some products groups need to be in compliance with criteria on VOC content or emission, like for example paints and varnishes, putties, wooden panels, adhesives and other flooring installation products, sealants, floor coverings, insulation materials, mattresses and upholstered furniture.

Criteria are based on environmental and health aspects concerning the way of manufacturing, use of the products and content of harmful substances (both to health and to the environment). Some criteria contain specific requirements on VOC and SVOC emissions. Depending on product type, there are different requirements defined.

Blue Angel defines specifications for more than 100 different product types. Each specification has its own unique number and includes requirements, which are specific for the respective product type. Among these requirements are different legal regulations and other restrictions of certain chemical substances or raw materials. In many cases, manufacturer can declare that these chemicals or raw materials are not used. In other cases, tests from independent laboratories are required.

If a VOC emission test is required for a specific product type, usually a test after 3 and 28 days using a test chamber according to EN 16516 with evaluation in the style of the AgBB scheme is included. Loading factors of the test chamber and limit values, for example for the TVOC, are varying for different product types. Blue Angel only accepts tests reports from accepted laboratories for these emission tests.

Manufacturer can apply for the Blue Angel label directly at the RAL institute using tests reports of accepted laboratories and declarations of compliance. Templates for these declarations are available on the homepage of the Blue Angel together with respective specifications and an overview over accepted laboratories for testing.

Certificates and the right to use the label is defined in a certification contract. Validity of the contract expires on a fixed date defined in the respective product specific Blue Angel requirements. Contract can be prolonged afterwards, unless the it is cancelled, which is usually the case, when Blue Angel specifications change.

Danish Indoor Climate Labelling (DICL) is a labelling scheme that documents the emission of chemical compounds from building materials, furniture and fixtures to the indoor air. DICL was founded by the Danish housing minister and is continuously being operated by Danish Technological Institute (DTI).

The Danish Indoor Climate Label includes requirements on Emission testing for VOC, SVOC, carcinogenic compounds and LCI compounds according to EN 16516 and odour testing according to ISO 16000-28 (acceptance). Below table shows three classes for TVOC and formaldehyde criteria.

The odour test is not necessarily performed after 28 days, but every ten days during the testing period until a level with an acceptance of > 0.1 is reached. The result [in days] is the so called Indoor Relevant Time Value. Maximum Indoor Relevant Time Value is depending on product type and can be up to 60 or 100 days. Release of particles is limited as well for certain product types.

First step of the certification would be the decision whether a single product or a product group shall be certified. Products that have very similar physical and chemical properties and application, can be considered as a product group. Representative worst case products will be selected for testing in an approved testing laboratory before admitting the application.

After receiving the test result from the testing laboratory manufacturers can apply for DICL-classification and will receive the labelling license afterwards. The labelling license needs to be renewed each year and the emission test needs to be renewed after 5 years.