September 17, 2019
Our UL experts - Elisa Gavazza and Judith Haber — answer some questions about restricted CMR substances in toys and chemical management solutions for toy industry supply chains.
Q: Will there be any amendment to Annex XVII of REACH, entry 52, in Europe?
A: Thank you for the question, the reply is no, as we have mentioned there has been an amendment in entry 51, but entry 52 will not change. So basically the three phthalates covered by the entry 52 (DINP, DIDP, DNOP) will still be subject to the same requirement that is they shall not be used as substances or in mixtures, in concentrations greater than 0,1 % by weight of the plasticized material, in toys and childcare articles which can be placed in the mouth by children.
Q: The US state law say intentionally added substances must be below the PQL. What does PQL mean? And how do they define intentionally added as a contaminant?
A: Those are both good questions. PQL or practical quantification limit is the lowest level at which the results can be reported confidently. Intentionally added chemical means a chemical in a product that serves an intended function in the product component. Contaminant means trace amounts of chemicals that are incidental to manufacturing and serve no intended function in the product or component.
Q: If my product meets federal regulations for a chemical listed on CA Proposition 65, do I still need to provide a warning?
A: Excellent question. It depends. Proposition 65 warning requirements are independent of federal regulations. The warning requirements are based on exposure levels rather than the quantity of the chemical it contains. For example, a product might be in compliance with a federal requirements for lead in substrate because it contains less than the required limit of 100 mg/kg, but not in compliance with Proposition 65 because it lacks a warning that consumers who use the product will be exposed to more than 0.5 micrograms of lead per day.
Contact us to receive more information about restricted CMR substances in toys and chemical management solutions or to know more about how UL can support your business.