Consumer Products and Retail E-ssentials

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Germany GS-MARK

November, 2014

 

In August 2014, the German AfPS (Committee for Product Safety) has determined the new requirements for PAHs evaluation and testing for the GS Mark Certification. It aims to align with the upcoming REACH Annex XVII PAHs requirements in consumer products. Comparing with existing ZEK 01.4-08, major changes are limits and categories. Please refer to the below summary and Table A for limits.

The new PAHs requirements are mandatory for GS-Certification from 1st July 2015 and the document ZEK 01.4-08 will be invalid from 30th June 2015. All products applying for GS certification will be affected such as electrical and electronic equipment, toys, mechanical products etc. In order to ensure a smooth transition to the new requirements, current projects should already be evaluated according to the new requirements. Please refer to corresponding dates in Table B.

Significant changes of new PAHs requirements:

  •  Update the limit of PAHs:
    • Specify individual limits of 10 PAHs
      • Benzo[e]pyrene; Benzo[a]anthracene; Benzo[b]fluoranthene; Benzo[j]fluoranthene; Benzo[k]fluoranthene; Chrysene; Dibenzo[a,h]anthracene; Benzo[g,h,i]perylene; lndeno[1‚2,3-cd]pyrene; Naphthalene
    • Add the limit for the sum of 7 PAHs
      • Acenaphthylene,  Acenaphthene, Fluorene, Phenanthrene, Pyrene, Anthracene, Fluoranthene
    • Sharply decrease the limit of benzo[a]pyrene and the sum of 18 PAHs for categories 2 and 3.
  • Amend the scope of categories 2 and 3:
    • Category 2 newly includes materials with repeated short term skin contact.
    • Categories 2 and 3 are divided into two groups: toys according to EU Directive 2009/48/EC and all other products according to ProdSG (Germany Product Safety Act)

Table A: New limits and categories of PAHs

 AfPS Decision on PAHs for GS-Mark Certification, 4 August 2014
 Substance name C A S No. Limit (mg/kg) 
 Category 1 Category 2  Category 3  
Materials, that are intended to be taken in the mouth or materials in toys with proper and long-term skin contact (longer than 30s) Materials, not covered in Cat.1, with foreseeable contact to skin longer than 30s (long-term skin contact) or repeated short-term skin contact* Materials, that do not fall in Cat. 1 or 2, with foreseeable contact to skin up to 30s (short-term skin contact)
Toys in 2009/48/EC Other products in ProdSG

Toys in 2009/48/EC

Other products in ProdSG

Benzo[a]pyrene (BaP) 50-32-8

< 0.2 

< 0.2

< 0.5

< 0.5

< 1

Benzo[e]pyrene (BeP) 192-97-2

< 0.2

< 0.2

< 0.5

< 0.5

< 1 

Benzo[a]anthracene (BaA)

56-55-3

< 0.2

< 0.2

< 0.5

< 0.5

< 1

Benzo[b]fluoranthene (BbFA) 205-99-2

< 0.2

< 0.2

< 0.5

< 0.5

< 1

Benzo[j]fluoranthene (BjFA)

205-82-3

< 0.2

< 0.2

< 0.5

< 0.5

< 1 

Benzo[k]fluoranthene (BkFA)

207-08-9

< 0.2

< 0.2

< 0.5

< 0.5

< 1

Chrysene (CHR)

218-01-9

< 0.2

< 0.2

< 0.5

< 0.5

< 1

Dibenzo[a,h]anthracene (DBAhA)

53-70-3

< 0.2

< 0.2

< 0.5

< 0.5

< 1

Benzo[g,h,i]perylene

191-24-2

< 0.2

< 0.2

< 0.5

< 0.5

< 1

Indeno[1,2,3-cd]pyrene

191-39-5

< 0.2

< 0.2

< 0.5

< 0.5

< 1

Acenaphthylene

208-96-8

Sum: < 1

Sum: < 5 

Sum: < 10 

Sum: < 20 

Sum: < 50 

Acenaphthene

83-32-9

Fluorene

86-73-7

Phenanthrene

85-01-8

Pyrene

129-00-0

Anthracene

120-12-7

Fluoranthene

206-44-0

Naphthalene

91-20-3 < 1

< 2

 

< 10

 

Sum of 18 PAH above

 

< 1 

< 5 

< 10 

< 20 

< 50 

 * =Definition of “short-term= repetitive contact with the human skin“ from  REACH Annex XVII Entry 50 Amendment (Commission Regulation (EU) No. 1272/2013)

Table B. Transition measures for the new PAH requirements

 GS Mark Certificate When to comply with the new PAHs requirements?
Issuance of new GS Mark certificate from 1st July 2015 onwards (note for exceptions below) Before the issuance of the GS Mark certificate

GS Mark certificate issued before 1st July 2015

Existing GS Mark certificates are still valid. The new PAHs requirements should be considered during the next factory inspection (within 1 or 2 years depends on the regular control period of the certificate)

Re-issuance of existing GS Mark certificate - Exceptions

A. For non-technical changes, such as the change of company name, relocation of license holder, immediate consideration of new PAH requirement is not a must. However, this should be addressed during the next factory inspection.

B. For the new issuance of secondary certificates and its related main-certificate, new PAH requirements must be complied before the next factory inspection, but not later than 28th December 2015.

 

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