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No progress on reducing the maximum PAH levels for the GS certification mark inline with prevailing technical standards

06/2022, 16.02.2022

The BfR once again recommends minimising PAH levels in consumer products as much as technically feasible

The Federal Institute for Risk Assessment (BfR) is involved in the development of the criteria for awarding the national GS ("Geprüfte Sicherheit" = tested safety) certification mark. For several years now, the institute has been working to ensure that the existing maximum levels for carcinogenic polycyclic aromatic hydrocarbons (PAHs) are reduced to a level that is feasible according to prevailing technological standards. The consumer exposure to PAHs should continue to be reduced, since no harmless dose can be derived for this carcinogenic mixture of substances. The BfR is now reiterating what it emphasised back in 2019 that it is now technically possible to minimise the PAH content to below 0.2 milligrams per kilogram in all common rubber materials, elastomers and plastics. This was shown more than two years ago via measurement data from various testing institutes for many products with comparatively low levels. "From a scientific standpoint, it is incomprehensible that when awarding the GS mark, this value does not yet apply to all products that make long-term or repeated contact with the skin," says BfR President Professor Andreas Hensel. Hensel emphasised that, "People can only be adequately protected, if the PAH content in consumer products is kept as low as possible."

Handles and contact surfaces of tools, toys and electronic devices are often made of rubber, elastomers or plastics. These may contain polycyclic aromatic hydrocarbons (PAHs). These are mixtures of more than one hundred individual components, which may also contain carcinogenic substances. A limit of 1 milligram per kilogram (mg/kg) of the eight PAHs classified as carcinogenic applies for all consumer products, such as sports and household appliances, tools, clothing or bracelets marketed in the EU. This value refers to the plastic and rubber parts with prolonged or repeated short-term body contact. For toys and articles for toddlers or infants, the value is 0.5 mg/kg. The threshold values have applied throughout Europe since 27/12/2015. They have been inserted to Regulation (EC) No 1907/2006 through Regulation (EU) No 1272/2013, Annex XVII.

The GS mark is a national certification mark for product safety and ensures "tested safety". From the point of view of the BfR, it should be based on the technically feasible maximum levels for the protection of consumers. This corresponds to a maximum level of 0.2 mg/kg of PAHs in the plastic and rubber parts of the product.

The GS mark divides products into different categories depending on the contact, grip and operating surface:

• Category 1 includes products intended to be put into the mouth or materials in toys with long-term skin contact (longer than 30 seconds).
• Category 2 includes products that are not in Category 1, but have predictable long-term skin contact or repeated short-term skin contact.
• Products with predictable short-term skin contact, which do not fall into the first two categories, are classified as Category 3.

The award criteria for the GS mark have so far established a maximum level of 0.2 mg/kg only for Category 1 products and toys.

Therefore, it is the opinion of the BfR that a stricter GS value should also apply to products for which prolonged contact with skin is foreseeable, e.g. bicycle handles or watch straps, before the GS mark is awarded. The BfR is therefore strongly committed to implementing the value of 0.2 mg/kg for Category 2 products in order to further minimise health risks and improve consumer protection. Analyses show that a value of 0.2 mg/kg is technically feasible for all Category 2 products. A reduction of the PAH content below 0.2 mg/kg is generally technically feasible in all common rubber materials, elastomers and plastics. Measurement data from various testing institutes have repeatedly shown this using many products with comparatively low levels.

The GS mark indicates that the health and safety of the user are not endangered provided the marked product is used as intended or in an unintended but foreseeable manner (e.g. misuse). Above all, this is guaranteed when the PAH content is as low as technically feasible.

The GS mark is awarded in compliance with the Product Safety Act (ProdSG) and is overseen by the Committee for Product Safety (AfPS), which advises the federal government on product safety issues. The GS mark 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 any GS-body recognised by the Central Office of the Federal States for Safety Technology (Zentralstelle der Länder für Sicherheitstechnik, ZLS). The GS mark is voluntary.

About the BfR

The German Federal Institute for Risk Assessment (BfR) is a scientifically independent institution within the portfolio of the Federal Ministry of Food and Agriculture (BMEL) in Germany. The BfR advises the Federal Government and the States ('Laender') on questions of food, chemical and product safety. The BfR conducts its own research on topics that are closely linked to its assessment tasks.

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