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The German BfR is proposing to strengthen the existing PAH limits to 0.2 mg/kg for Category 2 consumer products covered by the GS Mark.

SAFEGUARDS | Consumer Products NO. 122/19

Bread toaster

On August 9, 2019, the German Federal Institute for Risk Assessment (Bundesinstitut für Risikobewertung, BfR) announced the presence of polycyclic aromatic hydrocarbons (PAHs) in consumer products should be ‘as low as possible’. Measurement data from testing institutes on many products with low levels of PAH revealed that it is technically feasible to reduce the PAH content to less than 0.2 milligrams per kilogram in all common rubber materials, elastomers and plastics.

PAHs are a family of more than 100 substances and some of these are classified as carcinogenic. According to the announcement, handles and contact surfaces of tools, toys and electrical appliances may contain PAHs as these are often made of rubber, elastomers or plastics.

Since December 2015, the European Union (EU) has restricted each of the eight PAHs to no more than 1 mg/kg in articles for the general public, such as sports and household appliances, tools, clothing or bracelets, under normal or reasonably foreseeable conditions of use, if their rubber or plastic components that come into direct as well as prolonged or short-term repetitive contact with the human skin or the oral cavity. This limit is strengthened to 0.5 mg/kg for toys and childcare articles. These requirements are governed by Entry 50 to Annex XVII of REACH in Regulation (EU) No 1272/2013, amending Regulation (EC) No 1907/2006.

The Geprüfte Sicherheit Mark (GS Mark) stands for "Tested Safety" and is a German voluntary certification mark for product safety. The GS Mark divides products into different categories depending on the contact, grip and operating surface:

  • Category 1 includes products intended to be placed in the mouth or toy materials with intended prolonged contact with the skin (longer than 30 seconds)
  • Category 2 includes products that are not in Category 1, but with foreseeable long-term skin or frequent short-term skin contact
  • Category 3 includes products not falling under Categories 1 and 2, but with foreseeable short-term skin contact

The existing GS Mark has established a limit of 0.2 mg/kg only for (carcinogenic) PAHs in Category 1 products and toys. In light of the aforementioned studies and to strengthen consumer protection, the BfR is recommending to implement this value of 0.2 mg/kg for Category 2 products under the GS Mark certification program.

The GS Mark is regulated in chapter 5 of the German Product Safety Law (ProdSG). It may only be used on ready-to-use products such as tools, toys, furniture or textiles. Manufacturers can apply for the GS Mark for their products. This application can be made to a GS-body recognized by the Zentralstelle der Länder für Sicherheitstechnik (ZLS).

SGS is committed to providing information about development in regulations for consumer products as complimentary services. Through a global network of laboratories, SGS provides a wide range of services including physical/mechanical testing, analytical testing and consultancy work for technical and non-technical parameters applicable to a comprehensive range of consumer products. Please do not hesitate to contact us for further information.

For enquiries, please contact:

Dr. Udo Krischke
Global Technical Manager, RSTS
t: +49 6128 744 235

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