Germany – New PAHs Requirement for Products with German GS Mark

Vol. 804 | December 22, 2014

In August 2014, the German Committee for Technical Equipment and Consumer Products (AtAV) published a requirement on polycyclic aromatic hydrocarbons (PAHs) limits in products that are subject to the GS Certification, which will become effective on July 1, 2015.

Products that are subject to GS Certification and are covered under the scope of this requirement include:

• Electrical and electronic products 
• Toys 
• Food packaging materials 
• Plastic products 
• Rubber products 
• Machinery 

Compared to the previous standard, the new standard includes significant changes and added restrictions, including:

1. The products of Category 2 and Category 3 are divided into two parts respectively according to Toy Directive 2009/48/EC, and all the parts are defined new limit values; 
2. The old standard only defined limit value of sum of 18 PAHs and limit value of benzo(a)pyrene. The new standard adds new limit values of 10 PAHs such as benzo(e)pyrene, benzo(a)anthracene, benzo(b)fluoranthene, naphthalene, etc. The new standard defines the limit value of sum of 7 PAHs (acenaphthylene, acenaphthene, fluorene, phenanthrene, pyrene, anthracene, fluoranthene); 
3. The new standard defines lower limit values of benzo(a)pyrene in Category 2 and Category 3; 
4. The new standard defines lower limit values of sum of 18 PAHs. 

 

Table: Limits for PAHs in the New Standard (mg/kg)

Parameter	Category 1	Category 2			Category 3
	Materials intended to be put in the mouth, or materials of toys with intended  to long-term skin contact(longer than 30 seconds)	Materials not covered by Category 1, with foreseeable skin contact for longer than 30 seconds (long-term skin contact) or repeated short-term skin contact			Materials not covered by category 1 or 2 with foreseeable skin contact up to 30 second(short term skin contact)
		Toys in the scope of 2009/48/EC		Other products in the scope	Toys in the scope of 2009/84/EC		Other products in the scope
BENZO(a)PYRENE	< 0.2	< 0.2		< 0.5	< 0.5		< 1
BENZO(e)PYRENE	< 0.2	< 0.2		< 0.5	< 0.5		< 1
BENZO(a)ANTHRACENE	< 0.2	< 0.2		< 0.5	< 0.5		< 1
BENZO(b)FLUORANTHENE	< 0.2	< 0.2		< 0.5	< 0.5		< 1
BENZO(j)FLUORANTHENE	< 0.2	< 0.2		< 0.5	< 0.5		< 1
BENZO(k)FLUORANTHENE	< 0.2	< 0.2		< 0.5	< 0.5		< 1
CHRYSENE	< 0.2	< 0.2		< 0.5	< 0.5		< 1
DIBENZO(a,h)ANTHRACENE	< 0.2	< 0.2		< 0.5	< 0.5		< 1
BENZO(g,h,i)PERYLENE	< 0.2	< 0.2		< 0.5	< 0.5		< 1
INDENO(l,2,3-cd)PYRENE	< 0.2	< 0.2		< 0.5	< 0.5		< 1
ACENAPHTHYLENE, ACENAPHTHENE, FLUORENE, PHENANTHRENE, PYRENE, ANTHRACENE,  FLUORANTHENE	<1 Sum	<5 Sum		<10 Sum	<20 Sum		<50 Sum
NAPHTHALENE	< 1	< 2			< 10
Sum of 18 PAH	< 1	< 5	< 10		< 20	< 50

 

Impact on Manufacturers and Exporters

With less than one year before the new requirement comes into effect, it is important for manufacturers and traders to be proactive and take the appropriate steps to prepare for compliance. In addition to testing the related finished products, it is also necessary to conduct inspection on the whole production line and the supplier.

 

Contacts:

Should you have any questions about PAH restrictions for products bearing the GS Certification Mark, please do not hesitate to contact:

Mr. Isaac Lam
isaac.lam@intertek.com

or

Ms Kathy Lee
kathy.lee@intertek.com

 

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