VOC in Paint: Definitions, Limits and How Additives Count

VOC in paint is counted by two different rules: the EU counts organic compounds boiling at or below 250 °C (482 °F), and the US counts photochemically reactive carbon compounds minus an exempt list. The two rules also divide by different volumes. In the EU, a decorative paint keeps its water in the liter; in the US, water and exempt compounds leave the liter before the VOC mass is divided by it.

One can of paint therefore carries two VOC numbers, and one molecule can be a VOC in the EU and exempt under the US federal rule. A worked example paint with 2 wt % VOC reads 20 g/L (0.17 lb/gal) with its water and 39 g/L (0.33 lb/gal) less water. Solvents count toward that figure, and so do the paint additives a formulator doses, such as coalescents, glycols and neutralizers.

Below follow three definitions, five content bases, category limits in five jurisdictions, the status of 19 additives and solvents, a five-step check and the dated changes.

How we check: regulations and classifications are read at the body that issues them, standards at the standards body, and every additive level names its basis and its source; the full method is in methodology and fact-checking.

What Is VOC in Paint? Three Definitions, Three Results#

Three definitions decide what counts as VOC in paint: Directive 2004/42/EC draws a 250 °C boiling-point line, 40 CFR 51.100(s) uses photochemical reactivity with an exempt list, and the EU Ecolabel adds semi-volatile organic compounds (SVOC). The SVOC band runs above 250 °C and below 370 °C (698 °F). The table below compares the three definitions by instrument, criterion, exclusions and date.

EU Definition: Initial Boiling Point at or Below 250 °C#

Directive 2004/42/EC Art. 2(5) defines a VOC as any organic compound with an initial boiling point at or below 250 °C (482 °F) at 101.3 kPa (760 mm Hg), so a molecule boiling at 251 °C does not count. An organic compound, under Art. 2(4), contains carbon and one or more of hydrogen, oxygen, sulfur, phosphorus, silicon, nitrogen or a halogen, carbon oxides and inorganic carbonates and bicarbonates excluded. Ammonia contains no carbon, so it is no organic compound and no VOC under the Directive.

VOC content under Art. 2(6) is the mass of VOC in g/L of the product in its ready-to-use condition, and VOCs that react chemically during drying to form part of the coating are excluded. The Directive covers coatings applied to buildings, their trim and fittings and associated structures (Annex I), aerosols excluded. Road-marking and marine antifouling paints are not Annex I subcategories, and plant-applied industrial paints fall under the installation rules of Art. 3(2).

US Definition: Photochemical Reactivity and the Exempt List#

Under 40 CFR 51.100(s), a VOC is any compound of carbon, excluding CO, CO2, carbonic acid, metallic carbides or carbonates and ammonium carbonate, that participates in atmospheric photochemical reactions, and compounds listed as negligibly reactive do not count. The paint-relevant exempt compounds in the eCFR text of 2026-10-30 are acetone, methyl acetate, methyl formate, PCBTF, propylene carbonate, dimethyl carbonate, 2-amino-2-methyl-1-propanol (AMP, 79 FR 17037, effective 2014-06-25), t-butyl acetate (fully, 81 FR 9339, effective 2016-04-25), completely methylated siloxanes and HFO-1336mzz(E) (88 FR 8226, effective 2023-04-10). No glycol, glycol ether, TMPD-MIB or TXIB is on that list.

Exempt status is jurisdiction-specific: dimethyl carbonate and t-butyl acetate outside industrial maintenance coatings count as VOC under SCAQMD Rule 102 and Rule 1113 (b)(78), and the CARB 2019 Suggested Control Measure (SCM) exempts only acetone, ethane, PCBTF, perchloroethylene, methyl acetate, listed fluorocarbons and methylated siloxanes (4.66). Each of the US VOC rules for paint therefore keeps its own exempt compounds. The federal list and each district's list are set out on US VOC rules for paint.

SVOC and LVP-VOC: Two Terms Paint Formulators Meet#

SVOC is the EU Ecolabel term for an organic compound boiling above 250 °C and below 370 °C at 101.3 kPa (Decision (EU) 2025/2607, Table 5 footnote 8), and it applies only to paints seeking the label. TMPD-MIB at 254 °C (489 °F) and TXIB at 281 °C (538 °F) fall in that band: neither counts under the Directive, both count against the Ecolabel SVOC caps.

LVP-VOC is a California consumer-products term, never an exemption for architectural coatings. Under 17 CCR 94508(a)(84), a low-vapor-pressure VOC has a vapor pressure below 0.1 mm Hg (13.3 Pa) at 20 °C (68 °F) by CARB Method 310, more than 12 carbons when vapor pressure and boiling point are unknown, or a boiling point above 216 °C (420.8 °F).

How VOC Content in Paint Is Expressed: With or Without Water#

VOC content in paint is a mass of VOC per liter, but the liter differs: the EU divides by the ready-to-use paint with its water, while US and Canadian rules divide by the paint less water and exempt compounds. The federal AIM rule reads the coating thinned to the manufacturer's maximum recommendation, colorant added to tint bases excluded (40 CFR 59.406(a)(1)). The table below sets the five bases side by side.

The US formula for VOC regulatory is (Ws - Ww - Wec)/(Vm - Vw - Vec), and VOC actual, the material VOC used for low-solids categories, is (Ws - Ww - Wec)/Vm. As a worked example from an SCAQMD working-group presentation on Rule 1113, take a paint of density 0.99 kg/L with 50 wt % water, 48 wt % solids, 2 wt % VOC and no exempt compounds. One liter holds 19.8 g of VOC and 0.495 L of water, so VOC regulatory is 19.8 g / 0.505 L, rounded to 39 g/L (0.33 lb/gal), and VOC actual is 19.8 g / 1 L, rounded to 20 g/L (0.17 lb/gal).

Content is not emission: the EU Ecolabel sets a separate indoor emission criterion of at most 3,000 µg/m³ total VOC at 3 days and 300 µg/m³ at 28 days, an R value of at most 1.0 and formaldehyde at most 10 µg/m³ (criterion 5).

The reference test differs as well: EPA Method 24 combines ASTM D2369 for volatile matter, D3792 or D4017 for water, D1475 for density and D4457 for exempt solvents (40 CFR 60 Appendix A-7). To compute both values for a formula, with and without water, use the paint VOC content calculator.

VOC Limits for Paint by Jurisdiction#

Five instruments set category VOC limits for paint in the markets covered here: Directive 2004/42/EC, Decision (EU) 2025/2607, 40 CFR 59 subpart D, SCAQMD Rule 1113 and SOR/2009-264, plus the CARB 2019 SCM as a model rule. The standard limit for VOCs is therefore one value per category, jurisdiction and basis, never one number for all paint. The table below lists each instrument with its categories, basis and start date.

EU Decopaint Phase II Limits by Subcategory#

Since 2010-01-01, Annex II A of Directive 2004/42/EC caps 12 decorative subcategories, from interior walls and ceilings to decorative effect coatings, in g/L of the ready-to-use paint. The Phase I limits applied from 2007-01-01 and no longer govern any paint. The table below gives the Phase II limits for waterborne (WB) and solventborne (SB) paint, with lb/gal calculated at 1 lb/gal = 119.8264 g/L.

A paint may be placed on the EU market only within the limit of its subcategory, and components that must be added to make it ready for use count toward the figure (Art. 3(1)). The label states the subcategory, its limit in g/L and the maximum VOC content of the ready-to-use product (Art. 4). Water is never subtracted for decorative paints, so every glycol and glycol ether boiling at or below 250 °C counts against a waterborne limit as low as 30 g/L (0.25 lb/gal).

EU Ecolabel VOC and SVOC Caps#

Decision (EU) 2025/2607 caps VOC and SVOC separately for nine category rows, measured on the ready-to-use product including recommended colorants and thinners. The Decision covers product groups 044, 056 and 057, is valid until 2032-12-31 and repeals Decision 2014/312/EU. The table below lists both caps; where two SVOC values appear, the first applies to indoor white paint and the second to indoor tinted and outdoor paint.

A coalescent that escapes the Directive still fills the Ecolabel budget: Texanol, at 254 °C, adds nothing to the Ecolabel VOC cap but counts in full against the SVOC cap of the same paint.

US Federal, South Coast and California Model-Rule Limits#

A US flat paint may carry 250 g/L (2.1 lb/gal) under the federal AIM rule but 50 g/L (0.42 lb/gal) under SCAQMD Rule 1113 and the CARB 2019 model rule, all less water and exempt compounds. The AIM rule excludes containers of 1 liter or less, aerosols, exports and coatings for ships, boats, aircraft and railcars. Flat means gloss below 15 at 85° or below 5 at 60° (ASTM D523). The table below compares six categories across the three US rules and Canada; federal lb/gal values are printed in Table 1, the others are calculated at 1 lb/gal = 119.8264 g/L.

All values are g/L (lb/gal) less water and exempt or excluded compounds. The federal 250 and 380 g/L are the flat and nonflat limits of Table 1, never a definition of "low-VOC" paint. Under the CARB 2019 SCM, a multicomponent coating is measured as mixed, and SCAQMD Rule 1113 adds a 50 g/L limit for colorant added at the point of sale.

Canada: SOR/2009-264 Concentration Limits#

Canada caps architectural coatings under SOR/2009-264 (registered 2009-09-09) at 100 g/L for flat, 150 g/L for non-flat and 250 g/L for high-gloss coatings (gloss of 70 or more at 60°), less water and excluded compounds. Excluded compounds are those of the VOC item of CEPA 1999 Schedule 1 (item 60 in the current consolidation, cited as item 65 in the Regulations) plus t-butyl acetate. That item excludes acetone, PCBTF, methyl acetate, methyl formate (z.22), t-butyl acetate (z.23), propylene carbonate (z.25) and dimethyl carbonate (z.26).

How Paint Additives Count Toward VOC#

A paint additive counts toward VOC by its boiling point in the EU and by the exempt list in the US, so the 13 additives below fall into four groups. Eight count under every rule, three escape the EU count only, AMP is federally exempt only, and ammonia counts nowhere. The table below gives each additive's boiling point at 101.3 kPa and its status under three instruments.

Glycol is the largest VOC contributor in a latex paint, at typically 2 to 3 times the coalescent amount, according to Mitchell (PCI, 2005). A switch of coalescent alone therefore leaves most of the VOC of a glycol-bearing latex paint in place.

Coalescents and Glycols Across the 250 °C Line#

TMPD-MIB (254 °C) and TXIB (281 °C) boil above the EU line and are no VOCs under Directive 2004/42/EC, while DPnB, PPh, butyl diglycol and both glycols boil below it and count. How the coalescing agents for latex paint differ in volatility and efficiency is compared on the family page.

The two esters still count elsewhere: both are SVOCs under Decision (EU) 2025/2607 and neither is exempt under 40 CFR 51.100(s), so every gram adds to a US AIM figure. No glycol ether is federally exempt either.

Neutralizers and Exempt Solvents: Same Molecule, Different Status#

AMP is exempt from the US federal VOC definition since 2014-06-25 (79 FR 17037) but is a VOC in the EU because it boils at 165 °C (329 °F). The table below follows six exempt solvents and AMP through five rule sets.

Every US-exempt solvent boils below 250 °C and is a VOC in the EU, so a solvent swap that lowers a US figure leaves the EU figure unchanged. Propylene carbonate shows the split within one country: exempt federally and in the South Coast, it counts as VOC under the CARB model rule. The pH role and levels of each amine are covered on neutralizing agents for waterborne paint.

MEKO, Silanes and Volatiles Released During Cure#

Methyl ethyl ketoxime (MEKO) boils at 152.5 °C (306.5 °F), so the anti-skinning agent of an alkyd counts as VOC in the EU, and it is not on the US exempt list.

Silane adhesion promoters add VOC twice. APTES boils at 217 to 220 °C (422.6 to 428 °F), below the EU line, and on full hydrolysis releases 0.624 g of ethanol per gram (3 mol alcohol per mol silane); GPTMS releases 0.407 g of methanol per gram. The CARB 2019 SCM counts VOCs generated during cure, such as ethanol from silanes (4.68), and hydrolysis alcohol is never exempt under 40 CFR 51.100(s).

Low-VOC and Zero-VOC Paint: What the Claims Mean#

A low-VOC or zero-VOC claim on paint is only as precise as the definition, basis and jurisdiction behind it, because one can holds different numbers in the EU and the US. No instrument covered on this page defines "low-VOC" or "zero-VOC" paint, and the federal AIM limits are category caps, not claim thresholds.

Producers use their own criteria. BYK defines "VOC-free" for its additives as below 1,500 ppm, a producer criterion that is not a regulatory definition. A BASF guide formulation of 2015 describes a zero-VOC semigloss acrylic at a pigment volume concentration of 22.9 % and 100 KU with VOC below 5 g/L, dosing a defoamer at 0.50 % on total formula in the grind.

Three checks make a claim comparable: definition, basis and jurisdiction. A paint coalesced with TMPD-MIB can read zero against the Directive yet carry SVOC under the Ecolabel and VOC in the US, and a paint thinned with propylene carbonate can read zero federally yet count it as VOC in the EU.

What Changes in the Additive Package of a Low-VOC Paint#

Removing glycols and volatile coalescents changes four parts of the additive package, listed below.

• Coalescent choice: a coalescent boiling above 250 °C adds nothing to the Decopaint figure, so low-VOC and zero-VOC coalescents replace volatile ones.
• Foam control: zero-VOC paints need more surfactant, so paint defoamers that worked before may no longer suffice (same 2015 source), and the resulting paint foaming is diagnosed on the defect page.
• Freeze-thaw stability: the glycols that served freeze-thaw stability leave, so freeze-thaw stabilizers for latex paint take their role.
• Open time: patent CN102652163A names reduced open time or wet-edge time as a major challenge for low or zero VOC paints, which open-time extenders address.

Each change is rechecked against the reference method of the target market, with EPA Method 24 governing in the US.

Checking a Paint Against VOC Rules: Five Steps#

A paint is checked against VOC rules in five steps: assign its category, pick each market's basis, list every volatile ingredient with its status, calculate the content, and confirm it by the reference test. The five steps are listed below.

1. Assign the category in each market, for example an interior matte in emulsion (latex) paint formulation is Decopaint subcategory (a) in the EU and a flat coating under Table 1 of 40 CFR 59 subpart D.
2. Pick the basis: g/L ready to use with water in the EU, g/L less water and exempt or excluded compounds in the US and Canada.
3. List every volatile ingredient, including components added to make the paint ready for use, with its status from the two additive tables above.
4. Calculate both values with the VOC content calculator.
5. Confirm by VOC content testing of paint: in the EU by the methods of Annex III of the Directive, in the US by Method 24, whose result governs over formulation data (40 CFR 59.406(b)).

This page sets out the rules, not legal advice for one product. A question about one paint goes through the form below, and its data are handled as described in the privacy policy.

Dates and Pending Changes in Paint VOC Rules#

The paint VOC rules in force today date from 1977 to 2025: SCAQMD Rule 1113 was adopted on 1977-09-02, Decopaint Phase II applies since 2010-01-01, and Decision (EU) 2025/2607 was adopted on 2025-12-17. The table below lists 15 dated steps, adopted or in force.

One change is pending and kept apart from the rules above: a proposed amendment to SCAQMD Rule 1113 (PAR 1113) is in the working-group stage and has not been adopted, so none of its proposals applies today.

How VOC Rules Connect to Other Rules for Paint#

VOC rules limit how much volatile matter a paint carries, while other rules for paint govern which additives may be used at all and how the label reads. Restrictions and labeling rules are grouped with VOC on paint additive regulations.

MEKO shows the overlap: it is an EU VOC at 152.5 °C and, separately, restricted under REACH Annex XVII entry 28 for supply to the general public at 0.1 % or more since 2022-03-01.

VOC in Paint FAQs#

The four questions below cover the meaning of VOC, zero-VOC claims, waterborne paint and ammonia.

What does VOC mean for paint?#

VOC stands for volatile organic compound: in the EU an organic compound boiling at or below 250 °C at 101.3 kPa, in the US a photochemically reactive carbon compound not on the exempt list.

Is a zero-VOC paint free of all VOCs?#

Not necessarily: the claim depends on basis and jurisdiction, and a paint with Texanol can read zero under the Directive while carrying SVOC under the Ecolabel. A propylene carbonate solvent reads zero federally but counts in the EU.

Does water-based paint contain VOCs?#

Yes, when it holds glycols or glycol ethers boiling at or below 250 °C, such as propylene glycol at 187.6 °C or DPnB at 230 °C. Glycol is the largest VOC contributor in a latex paint (Mitchell, PCI, 2005), and the EU counts it with the water left in the liter.

Is ammonia a VOC in paint?#

No: ammonia contains no carbon, so it is not an organic compound under Directive 2004/42/EC Art. 2(4) and falls outside 40 CFR 51.100(s). Its role as a neutralizer is covered on ammonia in paint.