Which coatings used by industrial painting enterprises can be exempted from "key pollutant discharging units in the atmospheric environment"?

The Measures for the Management of Key Lists of Environmental Supervision (hereinafter referred to as the Measures), which were deliberated and adopted by the Ministry of Ecology and Environment, came into force
on January 1, 2023.

The Measures clarify the identification of key pollutant discharge in the water environment and atmospheric environment in turn, and point out that enterprises and undertakings that produce, process, use or discharge chemical substances listed in the list of new pollutants under key control shall be included in the key pollutant discharge, and enterprises and undertakings that implement the key management of pollutant discharge permits stipulated in the catalogue of classified management of pollution discharge permits shall be listed as key pollutant
discharges.

Enterprises above designated size in the industrial painting industry are clearly listed in the list of "key pollutant discharge in the atmospheric environment" by the Measures (Article 5 (5) of the Measures), except for the use of four types of low volatile organic compound content coatings that comply with national regulations, such as water-based, solvent-free, radiation curing and powder
.

Further interpretation of this exemption clause, what standards should be followed for coatings with low volatile organic compound content used in the industrial coating industry to enjoy the exemption clause?

At present, the standard judgment of low volatile organic compounds for coating products is mainly based on GB/T 38597-2020 "Technical Requirements for Low Volatile Organic Compound Content Coating Products", the drafting of this standard includes, the Planning Institute of the Ministry of Ecology and Environment, China Coatings Industry Association, China Petroleum and Chemical Industry Federation, CNOOC Changzhou Coatings and Offshore Engineering Research Institute Co.
, Ltd.

For waterborne coatings for industrial coatings, the standard uses the limit values of VOCs such as vehicle coatings (original factory paint, refinish paint, rail transit vehicle coating), industrial protective coating, marine coating, floor coating, toy coating, road and traffic sign coating as the standard
for judging waterborne coatings.
The detailed judgment values of each product are shown in the table
below.

The VOC limit for solvent-free coatings in the standard is less than or equal to 60g/L
.

The limit values for VOCs in radiation-curing coatings in the standard are as follows
.

Waterborne, solvent-free and radiation-curable coatings that meet the above VOC limits can apply for removal
from the environmental regulatory focus list.