Germany’s Product Safety Committee has published the April 2020 version of AfPS GS 2019:01 PAK under the voluntary GS-Mark. This latest edition clarifies the scope of Category 1 materials.
In May 2019, the German Product Safety Committee (Ausschuss für Produktsicherheit, AfPS) issued AfPS GS 2019:01 PAK on a new set of specifications for polycyclic aromatic hydrocarbons (PAHs) under the voluntary Geprüfte Sicherheit Mark (GS-Mark, ‘Tested Safety’ Mark). This document on the testing, evaluation and specifications on PAHs replaces AfPS GS 2014:01 PAK and will become mandatory for issuing the GS-Mark from July 1, 2020. The GS mark can only be awarded to ready-to-use products (e.g. machines, hand tools, toys, electrical appliances, lights, household appliances or furniture) as outlined in Chapter 5 of the German Product Safety law (ProdSG).
On April 10, 2020, the AfPS issued the latest version of AfPS GS 2019:01 PAK. This latest edition, in German and English, clarifies the scope of materials falling under Category 1, which applies to:
- Materials intended to be placed in the mouth, or
- Materials coming into long-term contact with the skin (more than 30 seconds) during intended use:
- In toys falling under the scope of Directive 2009/48/EC (Toy Safety Directive, TSD), or
- For use by children up to three years of age
The other provisions in AfPS GS 2019:01 PAK of April 2020 are essentially similar to those in the May 2019 AfPS GS 2019:01 PAK document.
In Germany, PAHs are still a critical group of substances in consumer products. These have an impact on the meaningful test scope of consumer goods where GS-Mark certification is not desirable. According to §30 of the German Food and Feed Code ((Lebensmittel-, Bedarfsgegenstände- und Futtermittelgesetzbuch, LFGB) on general product safety and recommendations from the German Federal Institute for Risk Assessment (Bundesinstitut für Risikobewertung, BfR) to reduce the amount of PAHs in consumer products as much as possible, it is advisable to continue testing according to the list of PAHs in AfPS GS 2014:01 PAK after its sunset date of June 30, 2020
Highlights of the PAH requirements in AfPS GS 2019:01 PAK of April 10, 2020 for GS-Mark certification are summarized in Table 1.
| German Product Safety Commission (AfPS) Testing and Assessment of Polycyclic Aromatic Hydrocarbons (PAHs) in the Award of GS Marks – Specification Pursuant to Article 21(1) No. 3 of the Product Safety Act (ProdSG) AfPS GS 2019:01 PAK, April 10, 2020 | |||||
|---|---|---|---|---|---|
| Category 1 | Category 2 | Category 3 | |||
Materials intended to be placed in the mouth,
(mg/kg) | Materials not covered by Category 1, coming into long-term contact (> 30 seconds) or short-term repetitive contact*** with skin during intended or foreseeable use | Materials not covered by Category 1 or 2, coming into short-term contact (≤ 30 seconds) with skin during intended or foreseeable use | |||
2a (mg/g) | 2b (mg/kg) | 3a (mg/kg) | 3b (mg/kg) | ||
| 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[1,2,3-cd]pyrene | < 0.2 | < 0.2 | < 0.5 | < 0.5 | < 1 |
| Anthracene, fluoranthene, phenanthrene, pyrene | < 1 (sum) | < 5 (sum) | < 10 (sum) | < 20 (sum) | < 50 (sum) |
| Naphthalene | < 1 | < 2 | < 10 | ||
| Sum of 15 PAHs | < 1 | < 5 | < 10 | < 20 | < 50 |
| *’Child’ is legally defined as a person under 14 years of age **Use by children includes both active and passive direct contact by children ***Definition of ’short-term repetitive contact’ has the same meaning as amended entry 50 to Annex XVII of REACH (Regulation (EC) 1272/2013) **** According to Article 2(28) to Chapter 1 of the Product Safety Act (ProdSG), ‘foreseeable use’ means the use of a product in a manner that is not intended by the person who places it on the market, but is reasonably foreseeable Effective date: July 1, 2020 for issuing of GS-Mark | |||||
Table 1.
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