South Africa Regulates Lead in Paint and Coating Materials

SafeGuardSHardgoodsSeptember 23, 2024

SG 144/24

South Africa has issued legislation to regulate lead in paint and coating materials. The provisions will be implemented in phases, starting May 17, 2025.

In May 2024, South Africa’s Minister of Health published the Regulations Relating to Lead in Paint or Coating Materials, 2024 (the Regulations) in the Government Gazette to revise the nation’s Hazardous Substances Act, 1973 (Act No. 15 of 1973).

The new law contains several important provisions: It:

Sets a limit value for lead content in paints and similar coating materials
Mandates a declaration of compliance (DoC) certificate for the first production batch or lot of paint or similar coating materials, and in the event of a material change (Annexure A)
Directs the use of a non-exhaustive list of international sampling procedures, quality assurance principles and analytical methods (Annexure B)
Details labeling requirements, including the statement ‘Complies with the South African legal lead limit of 90 ppm or less’ and the globally harmonized system of classification and labeling for chemicals

Highlights of the regulations are summarized in Table 1.

Substance	Scope	Requirement	Effective date
Lead	Paints Coating materials	≤ 90 mg/kg (0.009% or 90 ppm) for weight of the total non-volatile content of the paint or weight of the dried paint film)¹^, ²	May 17, 2025
Lead	Paints Coating materials	Labeling according to section 6 of the regulations	May 17, 2026

Table 1

¹Requires lead content standard compliance declaration certificate for the first production batch or lot of paint or similar coating material of all manufactured and imported products and in the event of a material change (Annexure A)

²Must use internationally recognized sampling procedures, quality assurance principles and (ISO or ASTM international) analytical methods, including but not limited to ISO 1513, ISO 1514, ASTM E1645-16, ASTM E1979-17, ISO 6503, ASTM D3335-85a (2014), ASTM E1613-12, ASTM F28530-10 and US CPSC Method CPSC-CH-E1003-09.1

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