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Sourcing Lead Paint

This page explains the process you need to follow in England if you want to either use - or supply lead paint for use  - on Grade I or II* listed buildings, scheduled monuments or works of art or use paints with high volatile organic compounds (solvents).  

Historic England is responsible for approving the supply and use of lead paint in England.

The marketing and use restrictions of lead paints are set out in the REACH Enforcement Regulations, Schedule 5 (and specifically UK Statutory Instrument No.2852).  REACH, is the acronym for the Registration, Evaluation, Authorisation and Restriction of Chemical substances.  

It restricts the use of hazardous substances and promotes the safe handling of all chemical materials.  It is an offence to contravene paragraph 5(b) or 6 of Part 1 of Schedule 5, or cause or allow another person to do so.  

A person/supplier who supplies or uses lead paint is subject to the following restrictions and obligations.

Permitted use of lead paint

In England a supplier can, with the approval of Historic England, supply lead paint to be used in the maintenance or restoration of:

  • Historic buildings that are listed either Grade I or Grade II*
  • Scheduled monuments
  • Fine or decorative works of art

Suppliers wanting to import and/or sell lead paint must comply with REACH regulations.

Lead paint purchased in the UK

  1. If you want to use lead paint for qualifying structures or artworks in England you must complete and send a declaration form to the supplier of the paint.
  2. The supplier must then send a copy of the declaration with their own notification form to Historic England for approval.  The required contents of the declaration and notification forms and the contact details of Historic England are set out below. The supplier must not supply the paint less than three weeks after submitting the declaration and notification forms to Historic England.
  3. Upon receiving the declaration form from the supplier, Historic England will assess the eligibility of the sale of paint.  If we are not satisfied with the content of a relevant declaration or notification, we will respond in writing to the applicant within two weeks of receipt, with the reasons for our decision.

Lead paint purchased outside the UK

  1. If you have obtained lead paint outside the UK and want to use it in England you must complete and send a declaration form to Historic England. You must not use the paint less than three weeks after submitting the declaration.
  2. Upon receiving the declaration form, Historic England will assess the eligibility of the proposed use. If we are not satisfied with the content of a relevant declaration, we will respond in writing to the applicant within two weeks of receipt, with the reasons for our decision.

Historic England contact details for lead paint declarations and notifications

Lead Paint Applications
Building Conservation & Research
Historic England
1 Waterhouse Square
138 – 142 Holborn
London EC1N 2ST

Email: conservation@HistoricEngland.org.uk

Contents of a relevant declaration

  • The name, address and telephone number of the intended user of the paint.
  • The quantity, trade name and manufacturer of the paint intended to be used.
  • In the case of a listed building, the name, address and owner of the building and, where appropriate, its listing category.
  • In the case of a scheduled monument, the name, location and owner (if known) of the monument.
  • In the case of a listed building or scheduled monument, details of the parts of the building or monument where the paint is to be applied.
  • In the case of a work of art, its name, date, author, location, the name and address of the owner and details of how the paint is intended to be used.
  • The date the declaration is made and the signature and name of the person making it.

Contents of a notification

  • The name, address and telephone number of the intended supplier of the paint.
  • A statement that the intended supplier agrees to supply to the intended user paint of the quantity and type stated in the relevant declaration.
  • The date the notification is made and the signature and name of the person making it.

Paints with high volatile organic compounds (solvents)

Organic solvents in paints or volatile organic compounds (VOCs) react in sunny conditions with nitrogen oxides to form ozone which is harmful to health and vegetation.

Paints affected include:

  • Oil gloss paints
  • Flat oil and eggshell oil paints, and
  • Many oil-based varnishes  

Their use is restricted (European Legislation Directive 2004/42/CE and Paints, Varnishes and Vehicle Refinishing Products Regulations (Amendment) (England) 2009 SI 3145).

However, the legislation does permit the use of decorative paints, varnishes with a higher VOC content for the maintenance of historic buildings that are either Grade I, Grade II* or a scheduled monument.

A Code of Practice governs the sale of non-compliant paint to customers for use on historic buildings or vintage vehicles. The supplier requires the customer to complete a declaration of intent and proof of historic building status. The declaration form can be obtained from the paint supplier.

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