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Chemical Control Order for Lead and Lead Compounds (CCO, 2013-24)

Foundational Legislation: Toxics Substances and Hazardous and Nuclear Waste Control Act, 1990. Clarifications: Clarification on the Prohibited use of Lead and Lead Compounds; Clarification on the Prohibition of Paints with Lead and Lead Compounds Used for Children Toys and Related Products.

In order to tackle the problem of lead paints in the Philippines, the Chemical Control Order for Lead and Lead Compounds (CCO) was issued. With the CCO the Philippines became the first Southeast Asian country to successfully implement legislation towards lead-safe paint. While globally only a few countries have enacted comprehensive bans on the use of lead additives in all paints, the Philippines demonstrate that it is entirely possible to restrict the use of lead in all paints, including in “industrial” paints, which generally have lead concentrations that are up to 10 times greater. Already from 2013 to 2017, the CCO caused a radical decrease in the number of paints containing high levels of lead (by about 40 percent). By 2020, the local paint and coating industry, with strong encouragement from the government and civil society, had beaten the phase-out deadline for lead paints as stipulated by the CCO, with a total of 1,395 paint products certified through the new Lead Safe Paint® Certification programme. This policy serves as an excellent roadmap with clear definitions, phase-out plans, and decisive instruments with special attention to children. It also combines a collaborative top-down and bottom-up strategy with successful implementation through the promotion of many awareness-raising activities. This policy truly stands out, as great number of stakeholders were actively involved prior, during, and after the implementation of the policy, and the cooperative involvement of the paint industry further solidified its success. However, current studies have revealed a certain lack of enforcement in the area of imported lead paints. Although the government immediately placed an advisory against imported lead paints, there remains the need for a better monitoring system and long-term solution.

Our “Best Policies” are those that meet the Future Just Lawmaking Principles and recognise the interconnected challenges we face today. The goal of principled policy work is to ensure that important universal standards of sustainability and equity, human rights and freedoms, and respect for the environment are taken into account. It also helps to increase policy coherence between different sectors.  

Sustainable use of natural resources

• Decreased import and increased prohibition of lead-based raw materials ensures the protection of the Earth’s scarce resources.
• Requires a reformulation.

   Equity and poverty eradication

• Prohibits occupational and chronic lead exposure, especially for children.
• Encourages respect through the generations by allowing amendments, modifications, and supplementations by stakeholders.
• Empowers consumer rights by allowing the demand for lead-safe paints and public access to information.

   Precautionary approach

• Protects future generations through the phase-out of lead in paint.
• Studies are showing the increase of lead-safe paints in the market.
• Aims for reducing lead in paint to below 90ppm, which is internationally promoted by the UN Model Law.

   Public participation, access to information and justice

• Collaborative consultations with stakeholders from various backgrounds in five consultation meetings.
• Provides a robust section about the access to information, education and awareness-raising activities for the population.
• The DENR provides detailed rules on handling complaints.

    Good governance and human security

• The EMB is assigned with monitoring overall compliance; it is actively supported by the civil societies, which conduct monitoring activities independently.
• Provides for rather low penalties for non-compliance; no penalties have been issued to date.
• The code of conduct is promulgated by the DENR.
• Measures on imported paints are lacking compliance and continue to remain an issue.

   Integration and interrelationship

• Integration into various other national policies.
• Enhances and strengthens cooperation among various stakeholders.
• Provides for synergies with other governmental agencies.
• The decrease of lead exposure protects children and pregnant women as the most vulnerable groups as well as occupationally exposed workers, the overall population and the environment.

   Common but differentiated responsibilities

• The policy document provides for internal and external capacity building.
• Minimal costs are paid by the industry.
• Adoption of the 90 ppm limit by small and medium-sized enterprises in the Philippines shows the present level of chemical expertise in the country.

Since 2007, civil societies and the paint industry were advocating for a lead paint standard to tackle the hazardous impacts of lead on health and the environment. In the early 2000s, the largest Philippine paint company became alarmed about the discussion on lead in paint then taking place in developed countries and, due to its extensive market share, saw itself as especially responsible regarding the urgent need to switch to lead-safe paints, which are defined as paint with lead levels below 90 ppm. Studies have shown that lead exposure costs the Philippines more than USD 15 billion (approximately PHP 700 billion) annually. Additionally, the concern about the effect of lead exposure on children, with its potential intellectual and developmental health risks, was further taken into consideration. In 2011, civil society groups and the paint industry collaboratively petitioned the government through the Environmental Management Bureau to establish a regulation that would target the problem of lead in paint by limiting or prohibiting its use. After the Department of Environment and Natural Resources (DENR) published a draft version in 2011, civil society (Eco Waste Coalition) replied in form of a position paper. In their view, the draft was not going far enough. This was the beginning of a participatory process to develop the policy with support of the paint industry. During the whole development process, there were consultations with stakeholders from civil society including IPEN, the paint industry, representatives from schools and communities, experts from the education and the health sector, and local and national governments. Moreover, waste handlers, sanitation officers, former police officers, indigenous people, and people with disabilities were all involved. After these consultations, the DENR adopted the CCO in 2013 and started to implement it in the same year.

The objectives of the CCO are: 1) to increase the awareness of the toxicity of lead exposure and to provide safer alternatives to protect the lives of the population and the environment; 2) to develop a framework for implementation of a prevention programme; 3) to set guidelines to help identify lead exposure; and 4) to meet the regulations within the limits set out by the policy.

The CCO includes specific phase-out plans and applicant requirements. There are established timeframes for the phasing out of lead and lead compounds in paint: for decorative, architectural, and household paints until end of 2016; and for industrial paints until the end of 2019. The phase-out plans apply to domestic as well as imported products. The early phase-out of lead paint specifically for household and decorative paints shows the prioritized goal of protecting families and children in their homes. For applicant requirements, the applicants are obliged to reduce the lead concentration in paint to the maximum limit of 90 ppm. Applicants also have to submit a registration form and management plan, and they must label their products in order to responsibly inform consumers. Various activities have been undertaken to support the change to establish lower lead paint concentrations. The government set up workshops for paint manufacturers, and the paint industry was very keen to participate and supportively accomplish policy objectives. In 2013, one of the leading NGOs in the movement (the Eco Waste Coalition of the Philippines) joined UNEP’s Global Alliance to Eliminate Lead Paint, with  the Government of the Philippines subsequently joining in 2015. Importantly, one of the country’s major paint industry companies, Pacific Paint (Boysen) Philippines, Inc., became an industry representative member of the Alliance Advisory Council in 2015, demonstrating the great willingness of the paint industry towards achieving lead-safe paints. This significant and consistent cooperation among stakeholders is one of “the key[s] to the success” of the policy implementation. To support the bottom-up effect, the government is continuously informing the public about the harmful impacts from lead exposure and supporting the transparency of information by providing public access to all of the records of the DENR online, except information regarding trade secrets. The EMB, together with various NGOs, academia, industry groups, and agencies also partake in increasing public awareness about lead exposure. For example, civil society groups designed a booklet outlining the impacts of lead exposure on children, the paint industry has organized awareness-raising campaigns, and various stakeholders jointly set up the annual ‘International Lead Poisoning Prevention Week’ each October. Moreover, these ambitions for spreading awareness have consequently been integrated into the school curriculum to help teach children about the health implications of lead exposure. The EMB Regional Offices serve as the main regulatory bodies, responsible for conducting tests on lead paint both during the manufacturing processes and on products readily available on the market. These Offices are supported with additional tests by civil society, as well as by the independent, third-party voluntary certification body Lead Safe Paint® implemented by IPEN in collaboration with PAPM and the Eco Waste Coalition. Impressively, only two years after the implementation of the policy, two Philippine paint companies were the first in the world to receive a lead-safe certification from the newly established certification body. In the case of non-compliance, penalties are issued by the government in the form of a fee to be paid. However, the penalty fee is low and until today there have been no penalties issued. Additionally, the DENR provides detailed rules for handling any incoming feedback and complaints. Complementary directives further reinforced the required use of lead-safe paints in line with the CCO. The Department of Interior and Local Government issued a Memorandum Circular 2018-26 on the “Mandatory Use of Lead-Safe Paints by Local Government Units (LGUs)” that enjoins provincial governors and mayors to adopt a “Lead-Safe Paint Procurement Policy”; the Department of Education issued Order No. 4, Series of 2017 on the “Mandatory Use of Lead-Safe Paints in Schools”; and the Department of Social Work and Development’s Memorandum of 2017 requires the use of lead safe paints as a mandatory requirement in facilities catering to disadvantaged and vulnerable sectors. As next steps, civil society pointed out that more needs to be done concerning non-compliant paints and consumer products, particularly school supplies, toys and childcare articles, that are imported. They also noted that, nationally, local governments, real estate developers, home builders and other major paint consumers need to adopt a lead safe paint procurement policy to ensure that only compliant paints are purchased and used. In addition, the national government needs to draw up guidelines on lead paint abatement to minimize lead dust pollution, especially during renovation activities at home, school and other places.

Due to the lack of baseline studies on the population health impacts from lead exposure, it is difficult to reach evidence-based conclusions on the impact of CCO. However, there are studies regarding the lead concentrations in paint. In 2013, before the implementation of the policy, studies showed that 61 percent of paint in the Philippines had a lead concentration over 90 ppm.  After the implementation of the policy, the numbers began to decrease and, in 2017, fell to a significantly reduced 23 percent. With regards to paint categorized as having dangerously high lead concentrations (defined as a lead concentration over 10,000 ppm), a similar result was found, showing a decrease from 45 percent in 2015 to 12 percent in 2017. The same study of 2017 stated that the majority of the 104 samples of lead paints studied had sufficient labelling information, whilst for 29 samples such information was insufficient. Between 2019 and 2020, another study was conducted to analyse imported spray paints. It revealed that 42 percent of the samples were exceeding a lead concentration level of 90 ppm, while 29 of the 87 spray paints exceeded the dangerously high lead concentration threshold. As a result, the Food and Drug Administration of the Philippines issued an advisory in 2020 to highlight and notify the public against these hazardous paints; the advisory warns against the purchase and use of the 37 spray paints found to have lead concentration levels over 90 ppm. This demonstrates the immediate and responsible reaction by the government to continuously raise awareness with ongoing and upcoming information. However, the compliance of imported paint still remains to be a challenge. Overall, by 2017, the CCO had already achieved significant results as it had led to the reduction of lead in paint by almost 40 percent. The Order had also been integrated into other national and local policies from different governmental departments. Furthermore, the policy was received very positively by the public and was highlighted as a “milestone” in public health and as a “historic transition” for the safer future for the people of the Philippines. In October 2020, at the 8^th International Lead Poisoning Prevention Week, it was announced that the local paint and coating industry had beaten the phase-out deadline for lead paints as stipulated in the CCO. Indeed, a total of 1,395 paint products manufactured by three Philippine paint companies were certified through the Lead Safe Paint® Certification programme. One these companies, Pacific Paint (Boysen) Philippines, was in 2019 the largest paint and coating producer in the Philippines by a wide margin, with nearly 60 percent of the domestic market share (based on volume) and in 2017 it ranked as the 51^st largest paint company in the world.

For a number of aspects, the CCO serves as a model example for UNEP’s Model Law and Guidance for Regulating Lead in Paint. The significant cooperative efforts of multi-stakeholder consultations and involvement in policy formulation and implementation have inspired and continue to inspire the UN Model Law in its ongoing efforts. In 2017, Philippine representatives from civil society and the paint industry were invited to Malaysia to share their knowledge on the implications, strategies and challenges of lead-safe paint legislation. The event was organized by the Malaysian Paint Manufacturer’s Association and supported its initiative to limit the use of lead in paint by 2020.

1. Attina, T.M. & Trasande, L. (2013). Economic Costs of Childhood Lead Exposure in Low- and Middle-Income Countries. Environmental Health Perspectives, Vol.121 (9): pp. 1097-1102. https://ehp.niehs.nih.gov/doi/10.1289/ehp.1206424.
2. Chavez, C. (2020). Transition to full non-lead production of PH paint, coating industry hailed. Manila Bulletin. https://mb.com.ph/2020/01/05/transition-to-full-non-lead-production-of-ph-paint-coating-industry-hailed/.
3. Chemical Control Order for Lead and Lead Compounds (CCO, 2013-24), https://chemical.emb.gov.ph/wp-content/uploads/2017/03/DAO-2013-24-CCO-Lead.pdf
4. Coatings World. The Paints and Coatings Industry in the Philippines. https://www.coatingsworld.com/issues/2019-09-01/view_india_asia_pacific_reports/the-paints-and-coatings-industry-in-the-philippines/
5. Department of Natural Resources, PAPM and Ecowaste Coalition. PPT: Boysen Lead Paint Elimination Experience. https://wedocs.unep.org/bitstream/handle/20.500.11822/21998/8_UN%20Preparatory%20Workshop%20-%20Boysen.pdf?sequence=8&isAllowed=y;
6. Ecowaste Coalition (2020). Philippines beats 2020 Phase-Out Deadline for Lead-Containing Paints. PIA (25 October 2020). https://pia.gov.ph/news/articles/1056968
7. Food and Drug Administration (2020). FDA Advisory No. 2020-1585. https://www.fda.gov.ph/fda-advisory-no-2020-1585-public-health-warning-against-the-purchase-and-use-of-spray-paints-containing-significant-levels-of-toxic-heavy-metal-lead-pb/.
8. Homefinder (2017). Malaysia: Towards Lead-Free Paint by Year 2020. http://homefinder.com.my/property/news/malaysia-towards-lead-free-paint-by-year-2020/.
9. Interview with Geminn Louis C. Apostol on 10 October 2020.
10. Interview with Manny Calonzo on 30 September 2020.
11. Interview with Vergel Dyoco on 31 July 2020.
12. IPEN (2013). National Report. Lead In New Enamel Household Paints In The Philippines. https://ipen.org/sites/default/files/documents/Philippine%20Paint%20Report%202013%20(FINAL).pdf
13. IPEN (2016). Two Philippine Companies Receive First Lead Safe Paint® Certifications. https://ipen.org/news/two-philippine-companies-receive-first-lead-safe-paint%C2%AE-certifications.
14. IPEN (2017). Philippines Marks Phase-Out of Lead-Containing Paints. https://ipen.org/news/philippines-marks-phase-out-lead-containing-paints.
15. IPEN (2018). Industry Leader Reveals Secrets of PH Success in Phasing Out Lead Paints. https://ipen.org/news/paint-industry-leader-reveals-secrets-ph-success-phasing-out-lead-paints.
16. IPEN (2020). In Philippines 15 Brands Pass Lead Safe Paint® https://ipen.org/news/philippines-15-brands-pass-lead-safe-paint%C2%AE-certification. EcoWaste Coalition (2020). Philippine beats 2020 Phase-Out Deadline for Lead-Containing Paints. Republic of the Philippines: Philippine Information Agency. https://pia.gov.ph/news/articles/1056968.
17. IPEN and EcoWaste (2020). National Report. Lead In Spray Paints For Consumer Use In The Philippines. https://ipen.org/sites/default/files/documents/ipen-lead-spray-paint-philippines_v1_2-webhq.pdf
18. IPEN and EcoWaste Coalition (2013). National Report: Lead in New Enamel Household Paints in the Philippines. http://ipen.org/sites/default/files/documents/Philippine%20Paint%20Report%202013%20%28FINAL%29.pdf.
19. IPEN and EcoWaste Coalition (2015). National Report: Lead in New Enamel Household Paints in the Philippines – the 2015 Report. https://ipen.org/sites/default/files/documents/National%20Report%20Lead%20in%20New%20Enamel%20Household%20Paints%20in%20the%20Philippines.pdf.
20. IPEN, EcoWaste Coalition and Swedish Society for National Conservation (2017). National Report: Lead in Solvent-Based Paints for Home Use in the Philippines. http://www.ecowastecoalition.org/wp-content/uploads/2019/03/ipen-philippines-lead-report-final.pdf.
21. IPEN, EcoWaste Coalition and Swedish Society for National Conservation (2017). National Report: Lead in Solvent-Based Paints for Home Use in the Philippines. http://www.ecowastecoalition.org/wp-content/uploads/2019/03/ipen-philippines-lead-report-final.pdf.
22. Lead Safe Paint®. https://www.leadsafepaint.org/.
23. Perry Gottesfeld (2015). Time to ban lead in industrial paints and coatings. In: Frontiers in Public Health, 18 May 2015. Available at https://www.frontiersin.org/articles/10.3389/fpubh.2015.00144/full
24. Republic of the Philippines (1990). Toxic Substances and Hazardous and Nuclear Wastes Control Act of 1990; Republic Act No. 6969. http://extwprlegs1.fao.org/docs/pdf/phi45262.pdf.
25. Republic of the Philippines. The DENR (2015). Clarifications on the Prohibited Uses of Lead and Lead Compounds under DAO 2013-24, “Chemical Control Order (CCO) For Lead and Lead Compounds”. Memorandum Circular No. 005; Series of 2015. http://chemical.emb.gov.ph/wp-content/uploads/2017/03/EMB-MC-2015-005-Clarification-CCO-of-Lead.jpg.
26. Republic of the Philippines. The DENR (2016). Clarification on the Prohibition of Paints with Lead and Lead Compounds Used for Children’s Toys and Related Products. Memorandum Circular No. 010; Series of 2016. http://chemical.emb.gov.ph/wp-content/uploads/2017/03/MC-2016-010.pdf
27. Republic of the Philippines. The DENR (2019). Feedback and Complaints mechanism. https://www.denr.gov.ph/images/transparency_seal/2019_Citizen_Charter/2019_Citizen_Charter_2nd_Edition/Feedback_and_Complaints.pdf.
28. The DENR/EMB, Philippine Association of Paint Manufacturers, EcoWaste Coalition and IPEN (2015). Philippines Moves to Phase Out Lead Paint. US EPA. https://www.epa.gov/sites/production/files/2015-11/documents/philippines_case_study_presentation.pdf.
29. The policies in which the CCO has been further integrated into can be found under the section “Methods and modalities” of this report.
30. UNEP (2018). Model Law and Guidance for Regulating Lead Paint:
31. Global Alliance to Eliminate Lead Paint. https://www.unenvironment.org/fr/node/8128.
32. Lead Paint Alliance – Partners. https://www.unenvironment.org/explore-topics/chemicals-waste/what-we-do/emerging-issues/global-alliance-eliminate-lead-paint-1.
33. WHO (2020). Campaigns: WHO International Lead Poisoning Prevention Week 2020. https://www.who.int/campaigns/international-lead-poisoning-prevention-week/2020.