Friendly Guide to Lead in Paint Regulations 2025
Under the Hazardous Substances Act regulations published by South Africa's Department of Health, manufacturers cannot label paint as "lead free." Instead, they must include this specific statement on the packaging:
"Conforms with the South African legal lead limit of 90 ppm or less."
- Requirement Date: This labeling requirement went into effect on May 17, 2026.
- Mandatory Limit: Since May 17, 2025, it has been illegal to manufacture, import, or sell any paint or coating containing more than 90 mg/kg (90 ppm) of lead in the dried film.
HAZARDOUS SUBSTANCES ACT 15 OF 1973: REGULATIONS RELATING TO LEAD IN PAINT OR COATING MATERIALS
Notice Title: Hazardous Substances Act 15 of 1973 (“HSA”): Regulations relating to lead in Paint or Coating Materials
Government Notice: GN 4832 in GG 50665 on 17 May 2024
Commencing date: 17 May 2025 and 17 May 2026
The Minister of Health, in terms of section 29(1) of the HSA, published the Regulations relating to lead in paint or coating material for implementation.
These Regulations apply to the manufacture, sale, distribution, import, and export of all paints or similar coating materials.
The total lead concentration applicable to paints or similar coating materials must not be more than 0.009 percent (90 ppm) or 90mg/kg total lead (calculated as lead metal), based on the weight of the total non-volatile content of the paint or weight of the dried paint film.
The Regulations shall come into effect 1 (one) year after the date of publication (i.e. 17 May 2025), with the exception of regulations 6(1) (a), (b), (c), (d), (e), (/) and (2), which shall come into effect 2 (two) years after the date of publication (i.e. 17 May 2026).
Lead in Paint: Your 2025 Compliance Guide
South Africa’s paint and coatings industry has entered a new era. Since 17 May 2025, it has been illegal to manufacture, import, or sell any paint containing more than 90 mg/kg (90 ppm) of lead in the dried film or non-volatile content.
As a manufacturer, and distributor, we fully comply with this regulation. However, for many players in the market—dealers, distributors, contractors, and specifiers—the regulation also introduces new responsibilities. From 17 May 2026, every container sold in South Africa must carry the specified wording:
“Conforms with the South African legal lead limit of 90 ppm or less.”
Our role is to help you understand what this entails in practice, what should already be in place, and what the next milestone requires.
What should have been done already
By May 2025, all paints and coatings available in the market should have met the 90 ppm limit. This means:
– Dealers and distributors should be checking that stock on shelves complies and is supported by a Declaration of Compliance (DoC).
– Contractors and specifiers should be requesting DoCs as part of project submissions and only accepting compliant products on site.
If these steps have not yet been implemented in your business or projects, now is the time to catch up.
What’s coming next: 2026 labelling
The next important milestone involves labelling. From May 2026, every paint container must display the required compliance statement: “Conforms with the South African legal lead limit of 90 ppm or less.”
This is especially relevant for dealers, retailers, and project managers, who need to ensure that stock moving through the supply chain bears the correct packaging and wording.
It’s not enough for the paint itself to comply—your packaging and documentation must also visibly demonstrate this.
Why this matters to every role in the value chain
Manufacturers like ourselves, have already adopted the necessary changes. The focus now is on the rest of the supply chain:
– Dealers and distributors: Verify DoCs, plan to phase out old labels, and prepare to check packaging from May 2026.
– Specifiers and contractors: Update tender requirements to demand compliant labels and confirm packaging upon delivery.
– Project managers and facilities: Ensure compliant coatings are specified, supplied, and approved with the correct documentation.
Other areas of compliance to consider
The label transition also offers a good opportunity to align with other compliance frameworks:
– VOC evidence: Many Green Star projects now require low-VOC documentation in line with GBCSA IEQ-13.
– Packaging responsibility: Paint packaging falls under Section 18 Extended Producer Responsibility (EPR) regulations, which mandate producers to join a PRO and report on recovery and recycling.
How Polymer Coatings Group can assist:
Our commitment extends beyond manufacturing compliant products. We aim to support our partners—dealers, distributors, contractors, and specifiers—through this transition. Our technical team can provide the updated SDSs, documentation, and compliance packs needed for tenders, audits, and site approvals.
You can be confident that your product choices comply with regulations and project requirements.
Final word
The 90 ppm lead limit is already law, and from May 2026, all containers must clearly state compliance. If your business has not yet adjusted processes or stock controls, the time to act is now.
Polymer Coatings Group is here to guide you through the final steps—ensuring you have the right products, documentation, and support to stay compliant with confidence.
References
– Government Gazette 50665, Notice 4832 – Regulations Relating to Lead in Paint or Coating Materials, 2024
– SGS Technical Summary – South Africa regulates lead in paint and coating materials
– GBCSA IEQ-13 – VOC requirements for interior coatings
– Section 18 EPR regulations – packaging obligations
