Person pouring white paint into a paint tray with a roller.

Approved EO 4 Specification: Paint

Covered Products

Latex paints and primers for both interior and exterior applications. Recycled content paints are not covered by this specification.



Paint can impact air quality and affect the health of building occupants and painters due to volatile organic compound (VOC) emissions and the presence of hazardous air pollutants. The twentieth century saw the development of water and latex based paints as well as reductions in the levels of VOCs and reductions or removal of hazardous air pollutants in response to increases in regulation and the environmental and health impacts. The emergence of recycled content paints has continued to push the industry in a more sustainable direction. New York State plans to use its purchasing power to support this progress and foster further advancement of sustainable paints by creating a separate recycled content paint specification in the future. This specification does not cover non-architectural paints. Click here for the green purchasing specification for pavement marking paint.



Latex paint: A water-based paint with a synthetic binder such as acrylic, vinyl acrylic, or other such polymers.

Recycled content paint: Paint that contains a minimum of 50% by volume post-consumer paint and a maximum of 50% by volume secondary industrial materials or virgin materials.

Volatile Organic Compounds (VOC): Human-made or naturally occurring organic chemical compounds that easily enter the air as gases from some solids or liquids and are used and produced in the manufacture of paints, adhesives, some building materials, petroleum products, pharmaceuticals, and refrigerants. VOCs are present in nearly all interior environments. Reduction of the introduction of VOCs in interior environments is part of maintaining good indoor air quality.

Strong third-party certifications: Third-party certifications for latex paints and primers that restrict chemicals of concern (COC), limit VOC content and emissions, and require products to meet performance standards. Products meeting this standard qualify as Executive Order 4 (EO 4) Compliant Plus.

Acceptable third-party certifications: Third-party certifications for latex paints and primers that restrict chemicals of concern, limit either VOC content or emissions, and require products to meet performance standards or commensurate attributes.

EO 4 Compliant Plus: This is a designation that is preferred for procurement over products that comply with the baseline requirements in this specification. 

Recycled content: Minimum of 50% post-consumer recycled content.


Standard Setting and Certifying Programs

Master Painters Institute is a non-profit, third-party standard setting and certification organization focused on quality assurance in the paint and coating industry. They have three separate multi-attribute eco-standards that cover all types of paints and coatings.

Green Wise is a third-party certification for paints and coatings administered by the Coatings Research Group Incorporated (CRGI), a non-profit association of paint and coating manufacturers. CRGI maintains an ISO 17025 certified laboratory to ensure compliance with the two certifications they oversee.

Cradle to Cradle is a multi-attribute eco-label that evaluates a wide range of products across five categories of human and environmental health. The standard includes material health, material reutilization, renewable energy and carbon management, and water stewardship. For more information visit the Cradle to Cradle Products Innovation Institute website.

Green Seal is a non-profit, independent, third-party standard setting and certification organization that follows the Guiding Principles and Procedures for Type I Environmental Labeling adopted by the International Organization for Standardization (ISO 14024). Green Seal has developed environmental standards and certifies products for more than 40 major product categories.

UL EcoLogo is an independent, third-party standard setting and certification program that follows the Guiding Principles and Procedures for Type I Environmental Labeling adopted by the International Organization for Standardization (ISO 14024). Since its establishment in 1988, EcoLogo has been recognized or referenced in hundreds of specifications and standards. It has standards for cleaning products, sanitary paper, trash bags, adhesives and more. UL EcoLogo certified products are listed on the UL SPOT database at  

South Coast Air Quality Management District (SCAQMD) is the air pollution control agency for all of Orange County and the urban portions of Los Angeles, Riverside and San Bernardino counties, the smoggiest region of the U.S. Standards set by this pollution control agency are cited in LEED rating systems as well as regulation related to air quality in buildings. Information regarding SCAQMD can be found at

SCS Indoor Advantage Gold is a third-party certification for emissions limits to ensure compliance with the State of California’s Department of Public Health “Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions from Indoor Sources Using Environmental Chambers, Version 1.1 (2010)” (California Section 01350).

UL GREENGUARD Gold is a single-attribute certification for low-emitting products such as flooring, adhesives, paints, furniture, building construction products, insulation and many other. UL GREENGUARD Gold products are listed on the UL SPOT database at

USDA Certified Biobased is a third-party certification of the biobased content in a product and its packaging administered by the U.S. Department of Agriculture. The content is quantified using ASTM International D6866.



Where such products are cost competitive and meet form, function and utility requirements, affected entities shall to the maximum extent practicable procure latex paints and primers that have at least one of the following multi-attribute third-party certifications. The procurement of latex paints is encouraged over oil paints. In addition, the procurement of recycled content latex paints is encouraged over virgin latex paints for exterior use.

  • Master Painters Institute (MPI) Extreme Green;
  • MPI:
    • Green Performance Standard 2;
    • Green Performance Standard 1;
  • Green Seal: GS-11 Paints, Coatings, Stains, and Sealers;
  • Cradle to Cradle (Silver or higher); and
  • UL EcoLogo: UL 2768 Architectural Surface Coatings

Third-party Certification

Restrict COCs

VOC content limit

VOC emission limit

Performance standards

MPI X-Green















Green Seal-11





Cradle to Cradle





UL EcoLogo 2768






All latex paints and primers shall meet the following standards:

  • Shall not exceed the VOC content limits established by 6 NYCRR § 205.3.
  • Shall not contain mercury, methylene chloride or perchloroethylene.

Procurement of products with the following environmental attributes is encouraged.

  • SCS Indoor Advantage Gold certification, solely focused on VOC emissions
  • UL GREENGUARD Gold certification, solely focused on VOC emissions
  • USDA Biobased certification, solely focused on amount of renewable content
  • Compliance with the South Coast Air Quality Management District (SCAQMD) limit on VOCs of 50 grams/liter. This attribute only applies to paints other than interior flats. 
  • A Health Product Declaration (HPD), solely focused on potential chemicals of concern, has been published by the manufacturer
  • Recycled content


Take-Back/ Recycling

Affected entities are encouraged to:

  • Keep and appropriately maintain an appropriate amount of excess paint for future projects and recycle any excess paint whenever possible. 
  • Include a take-back agreement from the manufacturer in the procurement of paint.
  • Work with the vendor during the purchasing process to only purchase the amount of paint necessary for the project and to look at available donation and recycling options for excess paint, regardless of manufacturer.
  • Work with contractors who offer programs that include take-back and the proper environmental disposal of materials (including materials manufacturers and sold by others).

State Agencies are reminded to follow State Finance Law § 167 regarding surplus property redistribution before utilizing take-back, recycling or other options for the disposition of any paint that is still in useable condition. This standard requires donation of usable materials to other state agencies prior to declaration of materials as surplus or waste.

Affected entities should provide details regarding existing materials for take-back, including location of materials (i.e. whether materials are located in a basement; up one flight of stairs; fourth floor location with elevator access; or whether agency will move to dock) and any other pertinent information that will assist the contractor in determining disposal costs.

If materials are being transferred for disposition, a record of each disposition shall be retained by the affected entity. Documentation shall be provided to the affected entity demonstrating that these products have been disposed of in an environmentally sound manner in compliance with applicable local, state and federal laws. The contractor or disposing party shall provide assurance to the affected entity that all exports of used materials collected for reuse, recycling or disposal will be in compliance with the laws of the importing country.



Packaging shall comply with Environmental Conservation Law section 37-0205. Packaging shall not contain inks, dyes, pigments, adhesives, stabilizers, or any other additives to which any lead, cadmium, mercury or hexavalent chromium is intentionally added or contain incidental concentrations of lead, cadmium, mercury or hexavalent chromium which together are greater than 100 parts per million by weight (0.01%).

New York State encourages affected entities to adopt the following:

  • The use of bulk packaging.
  • The use of reusable packaging.
  • The use of innovative packaging that reduces the weight of packaging, reduces packaging waste, or utilizes packaging that is a component of the product.
  • That all packaging remain the property of the supplier and not become the property of the affected state entity under any circumstance or condition. The vendor shall certify that the packaging material will be reused, recycled, or composted, and managed in compliance with applicable local, state, and federal laws.
  • Packaging that maximizes recycled content and/or meets or exceeds the minimum post-consumer content level for packaging in the U.S. Environmental Protection Agency Comprehensive Procurement Guidelines.
  • Packaging that is recyclable or compostable.