Nordic Swan derogation for TMP in paints will expire on 31 May 2027: implications for titanium dioxide-based paints

The derogation allowing the use of trimethylolpropane (TMP) in paints and varnishes certified under the Nordic Swan Ecolabel is expected to expire on 31 May 2027. From that date, paints containing TMP-treated TiO₂ will no longer be eligible for the label. This decision diverges from the EU Ecolabel, which under the revised criteria for paints and varnishes has extended the use of TMP under defined conditions until 31 December 2032. As a voluntary certification, the Nordic Swan Ecolabel sets eligibility criteria for carrying the label; it does not restrict the manufacture, sale or use of the products concerned. 

What should paint manufacturers and formulators do? 

Manufacturers should note that, from June 2027, eligibility rules for paints containing TMP-treated TiO₂ grades will differ between the Nordic Swan Ecolabel and EU Ecolabel. To support compliance and certification strategies, companies should verify the surface treatment of TiO₂ grades used in formulations, engage with suppliers to confirm whether TMP is present, and assess alternative grades where necessary. 

What is the Nordic Swan Ecolabel? 

The Nordic Swan Ecolabel is the official voluntary sustainability certification of the Nordic countries, Sweden, Norway, Finland, Denmark and Iceland. Established in 1989, it certifies that a product or service meets strict environmental, health and quality requirements across its entire life cycle. 

Like the EU Ecolabel, it is based on life-cycle assessment, evaluating products from raw material sourcing and manufacturing throughout the use, recycling and disposal. Requirements include limits on chemicals, resource efficiency and reduced greenhouse gas emissions. Criteria are revised every three to five years, so certified companies must continuously improve to retain the label.  

What is TMP and why is it used on titanium dioxide? 

Trimethylolpropane (TMP)¹, also known as propylidynetrimethanol, is an organic substance used to surface-treat pigmentary TiO₂. The treatment improves the flow and dispersion of the pigment, supporting consistent performance in paints, coatings, adhesives and inks. 

What is the regulatory status of TMP? 

TMP remains self-classified as a category 2 suspected human reproductive toxicant. More information can be found here. However, a new harmonised classification and labelling (CLH) intention for trimethylolpropane (TMP)* has been notified under the EU Classification, Labelling and Packaging (CLP) Regulation, with Norway acting as the submitting authority. More information here.  

¹ EC number 201-074-9; CAS number 77-99-6.