From 1st April 2008, the testing for Polycyclic Aromatic Hydrocarbons (PAH) became mandatory in voluntary German GS Mark certification according to the document ZEK 01-08. These PAHs are based on the list published by the United States Environmental Protection Agency (US EPA) and all 16 substances are classified as carcinogenic. ZEK 01-08 was replaced by ZEK 01.2-08 in December of 2008 as new evaluation requirement in GS product certification.
On 29 November 2011, the German authority ZLS (Zentralstelle der Länder für Sicherheitstechnik) published the new testing method ZEK 01.4-08 (i), which added two new PAHs to the GS Mark requirements and thus extended the list of PAHs to 18. The new PAHs are:
1. Benzo[e]pyrene (CAS No. 192-97-2)
2. Benzo[j]fluoranthene (CAS No. 205-82-3)
The new requirements on these 18 PAHs and new document ZEK 01.4-08 (i) will be effective from 1 July 2012 and they are mandatory for all new GS Mark certificates. After July 1st 2012 ZEK 01.2-08 will be repealed. The concentration limits of the individual as well as the sum of PAHs remain the same with ZEK 01.2-08. (Refer to Table A).
In order to ensure a smooth transition to the new requirements, current holders of the TÜV SÜD GS Mark are advised to take note of this effective date and update their test plans without delay. Table B summarises the corresponding actions for GS Mark certificate holders.
TABLE A: Limits for PAH content for material of (grip) surfaces, which are to be categorized on account of the results of the risk analysis.
| Parameter | Category 1 | Category 2 | Category 3 |
| Materials intended to be put in the mouth or materials of toys for children aged < 36 months with intended skin contact2) | Materials not covered by category 1, with foreseeable skin contact for longer than 30 seconds (long-term skin contact) | Materials not covered by category 1 or 2 with foreseeable skin contact up to 30 seconds (short term skin contact) | |
| Benzo[a]pyrene (mg/kg) | Not detectable (< 0.2) 1) | 1 | 20 |
| Sum 183) PAH (mg/kg) | Not detectable (< 0.2) 1) | 10 | 200 |
1) If the limits of category 1 are surpassed but the limits of category 2 still met, the confirmation of the suitability of contact with foodstuff or the oral mucosa can be verified by an additional specific migration test of the PAH components according to EN 1186ff. and § 64 LFBG 80.30-1. The results of the migration test shall be evaluated according to law criteria for foodstuff.
2) According to the regulations of the EK2.
3) Extended list of substances of AtAV based on EPA according to ZEK 04-11.
TABLE B: Actions for GS Mark Certificate Holders.
| GS Mark CertificateGS | Compliance with 18 PAHs Requirements |
|
For existing GS Mark certificate
|
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That will expire before 1 July 2012.
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No. Only the current 16 PAHs need to be evaluated.
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That will expire on or after 1 July 2012, without reissuance request.
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Yes. The 18 PAHs need to be evaluated as part of the factory surveillance latest to 30 June 2013.
|
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That will expire on or after 1 July 2012,
with reissuance request (except for any of 3 cases below) |
Yes. 18 PAHs need to be evaluated before the reissuance of GS certificate.
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Immediate compliance of the 18 PAHs is not necessary, but the 18 PAHs need to be evaluated before next factory surveillance, latest to 30 June 2013.
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For issuance of new GS Mark certificate on or after 1 July 2012
|
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All new GS certificates
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Yes. 18 PAHs need to be evaluated before the issuance of new GS certificate.
|
