Recently, Dalian City issued the “Implementation Plan for the Substitution of Volatile Organic Compound–Based Raw and Auxiliary Materials,” setting forth clear requirements:

• Before May 15th , included in the list of key enterprises under regulatory oversight
• By the end of May , establish and improve a ledger for VOCs-related raw and auxiliary materials.
• By the end of June , complete the self-inspection report on the substitution of low-VOC raw and auxiliary materials.

Time is tight, and the task is heavy.

For downstream industries such as steel structures, construction machinery, and automotive components, this is not an ordinary environmental‑protection notice—it is a major test that will shape the future of their businesses.

Five Hurdles for Downstream Enterprises

The first hurdle: the policies are hard to understand.

“What is low-VOCs paint? What are the standards? How can I tell whether the paint I’m using now meets the requirements?”

Policy documents are replete with technical jargon, leaving business owners thoroughly confused. Standards such as GB/T 38597-2020 and GB 38507-2020—these code numbers mean little to most people; what the specific indicators entail, how they are tested, and how compliance is determined all remain unclear.

The second hurdle: There’s not enough time.

“We’re required to submit a list by May 15, establish an accounting ledger by the end of May, and file a self‑inspection report by the end of June. Right now, we’re still using solvent‑based coatings—how are we supposed to make the switch in just two months?”

The policy timeline has been set, but corporate transformation requires time: selecting the right solution, conducting tests, performing debugging, providing training—each step takes time. What if there’s not enough time? The only option is to submit the application first and address any issues in the follow-up phase.

The third hurdle: problems arise after the change.

“We previously tried water-based paint, but it suffered from sagging, bubbling, and poor adhesion, leading to a decline in product quality and customer complaints—so we ended up switching back.”

This is the most pressing concern. The application process for waterborne coatings differs from that of traditional solvent-based coatings; meticulous control of temperature and humidity, proper spray equipment, and optimal drying conditions are all critical. If these factors are not managed correctly, it can not only compromise product quality but also result in lost customers.

The fourth hurdle: not knowing whom to turn to.

“There are far too many companies on the market claiming to be manufacturers of water-based coatings—I’m not sure which one is trustworthy. After buying one and testing it, I found that the VOCs levels exceeded the limit, so I wasted my money and ended up delaying things.”

The market is flooded with water-based paint brands, and their quality varies widely. Many companies lack the testing capabilities to assess product quality and are unsure how to vet compliant suppliers, leaving them wary of potential pitfalls.

The fifth hurdle: you still have to write a report.

“How do we set up the ledger? How do we draft the self‑inspection report? How is the substitution ratio calculated? We don’t have a dedicated person to handle this.”

The policy requires companies to maintain records of raw and auxiliary materials, calculate substitution ratios, and prepare self‑inspection reports. For small and medium-sized enterprises, these tasks represent additional workloads, leaving them unsure where to begin.

Behind the pain points lies an opportunity for transformation.

Although policy pressure is significant, viewed from another angle, this also presents an opportunity for the industry to undergo a major reshuffle.

Enterprises that are the first to complete the replacement will gain three major advantages:

1. Operate in compliance, with no worries about the future. Environmental inspections are here—no need to live in constant fear.
2. Reduce governance costs. The policy explicitly stipulates that, where all emissions have been fully substituted and meet the required standards, the construction of end-of-pipe treatment facilities may be waived.
3. Enhance the corporate credit rating. Achieving an environmental performance rating of B or higher allows for reduced production restrictions during periods of severe air pollution.

The question is: Who can help you complete this transformation quickly and reliably?

Holy Hong: Understanding policies, and even better at coatings.

As a company dedicated to industrial coatings for thirty years, we not only offer low-VOC products that meet national standards, but also provide end-to-end services—from product selection to regulatory compliance.

• I can’t understand the policy. We offer free policy‑interpretation services to help businesses understand regulatory requirements and identify clear compliance pathways.
• Due to time constraints We offer a well-established portfolio of waterborne industrial coatings, with ample inventory to ensure rapid delivery. We also provide technical guidance on application processes to shorten the commissioning and adjustment period.
• It’s problematic after the replacement. Our waterborne coating products have been rigorously tested over many years and boast numerous successful applications in steel structures, construction machinery, automotive components, and other sectors. Our technical team provides on-site support to ensure superior application quality.
• For those who don’t know who to turn to. We are a reputable industrial coatings manufacturer, and all our products come with third-party test reports. Our VOC content complies with the GB/T 38597-2020 standard.
• Still need to write a report. We assist companies in establishing ledgers for raw and auxiliary materials, provide guidance on calculating substitution ratios, and offer self-assessment report templates, making compliance efforts smoother and more efficient.

We’re not selling paint—we’re helping you pass.

This shift to VOC‑free alternatives is no longer a matter of choice for downstream coating manufacturers—it is an imperative.

Well answered—your company will upgrade; poorly answered—you may be out of the game.

Holy Hong Coatings is willing to stand by your side as you face this "major test":

• Product Compliance , verifiable with documentation
• Technologically mature , with documented precedents
• Excellent service , someone can be found

Act Now

With the deadline for self-inspection reports at the end of June fast approaching, time is running out.

If you are a company in the steel structure, construction machinery, or automotive components industries and are struggling with VOC substitution, please contact us.

We can do more than you think.