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non-final version. Committee members may request permission to reproduce, quote from, and/or circulate this document to persons or
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TG Submission
NSF 426 TG 6 – Substances of Concern
TG 6 status summary: The TG recommends, or is still developing, 4 prerequisite criteria and 10 optional
criteria as outlined below. The TG has provided 2 options for criterion 6.1.3 for JC consideration. Of the
14 criteria below, 6 are still under development/consideration by TG 6.
Major changes in the recommended criteria, compared to the November draft, are:
 Addition of criteria on full substances inventory and alternatives assessment.
 Deletion of the non-mercury containing light sources criterion.
Points
Criterion Number and Title
Status*
Reference
(optional
document
criteria
only)
Prerequisite Criteria
N/A
TG
Recommendation
N/A
TG
Recommendation
N/A
Options for JC
Consideration
6.1.4 Reduction of Bromine and Chlorine
N/A
Still Under
Content of Plastic Parts > 25 Grams
Development
Optional Criteria
6.2.1 Further Reduction of Lead
Still Under
Development
6.2.2 Further Reduction of Bromine and
Still Under
Chlorine Content
Development
6.2.3 Reduction of Substances on the
TG
European Union REACH Regulation
Recommendation
Candidate List of Substances of Very High
Concern
6.3.1 Disclosure of Declarable Substances
TG
Recommendation
6.3.2 Requesting Full Substance inventory
TG
Recommendation
6.3.3 Receiving Chemical Inventory
Still Under
Development
6.3.4 Greener Chemicals and Processes
Still Under
Information
Development
6.3.5 Alternatives Assessment
TG
Recommendation
6.3.6 Making Results of Alternatives
TG
Assessment Publicly Available
Recommendation
Cables??
Still Under
Development
6.1.1 Compliance with European Union
RoHS Directive
6.1.2 Compliance with European Union
Battery Directive
6.1.3 Inventory of Declarable Substances
© 2014 NSF International and Green Electronics Council
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None
None
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This document is part of the NSF International standard development process. This document is subject to change and may be a draft and/or
non-final version. Committee members may request permission to reproduce, quote from, and/or circulate this document to persons or
entities outside of their organization after first receiving written permission from NSF International and Green Electronics Council. Send
written requests to NSF International that include notice of to whom and for what purpose this document is to be shared.
6
Substances of Concern
6.1 Prerequisites
6.1.1 Compliance with European Union RoHS Directive (TG Recommendation)
The product shall meet the substance restriction requirements of the European Union RoHS Directive.
using the version which is in force at the time the product is declared to conform to this standard. All
exemptions to the substances restrictions as defined by the Directive are applicable.
6.1.2 Compliance with European Union Battery Directive (TG Recommendation)
Batteries in the product shall meet the substance restriction requirements of the European Battery
Directive, using the version which is in force at the time the product is declared to conform to this
standard.
“Not Applicable” may be declared on the Product Registry by manufacturer if the product does not
contain batteries.
6.1.3 Non-Mercury Containing Light Sources
Products shall not contain light sources with intentionally added mercury.
“Not Applicable” may be declared on the Product Registry by manufacturer if the product does not
contain light sources.
6.1.3 Inventory of Declarable Substances (Options for JC Consideration)
Option #1
Manufacturer shall document the presence of IEC 62474 declarable substance groups and declarable
substances in the product at or above the reporting threshold amounts stated in the IEC 62474
standard, using the version of IEC 62474 which is current at the time the product is declared to conform
to this standard. The inventory shall include all declarable substance groups and declarable substances
designated criteria 1, 2 and 3 of IEC 62474.
During verification, the documentation shall contain the CAS number for each declarable substance (not
including declarable substance groups).
Option #2
Manufacturer shall document the presence of IEC 62474 declarable substance groups and declarable
substances in the product at or above the reporting threshold amounts stated in the IEC 62474
standard, using the version of IEC 62474 which is current at the time the product is declared to conform
to this standard. The inventory shall include all declarable substance groups and declarable substances
designated criteria 1 and 2 of IEC 62474.
During verification, the documentation shall contain the CAS number for each declarable substance (not
including declarable substance groups).
Note to JC: Criteria 1, 2 and 3 in IEC 62474 are the basis for inclusion of the substance. Criteria 1
(currently regulated) and 2 (being assessed for regulation with no specific effective date) are mandatory
© 2014 NSF International and Green Electronics Council
This document is part of the NSF International standard development process. This document is subject to change and may be a draft and/or
non-final version. Committee members may request permission to reproduce, quote from, and/or circulate this document to persons or
entities outside of their organization after first receiving written permission from NSF International and Green Electronics Council. Send
written requests to NSF International that include notice of to whom and for what purpose this document is to be shared.
declaration. Criterion 3 (for information only – recognized industry wide common market requirement) is
optional declaration.
6.1.4 Reduction of Bromine and Chlorine Content of Plastic Parts > 25 Grams (Still Under
Development)
Plastic parts exceeding 25 g shall contain a maximum of 1000 ppm chlorine and a maximum of 1000
ppm bromine. Parts which exceed 25% postconsumer recycled content may contain a maximum of
3000 ppm chlorine and a maximum of 3000 ppm bromine.
“Not Applicable” may be declared on the Product Registry by manufacturer if the product does not
contain plastic parts > 25 g.
6.2 Further Reduction of Substances of Concern (Optional)
6.2.1 Further Reduction of Lead (Still Under Development)
The product shall not contain lead in excess of __ (50?) ppm by weight in homogeneous materials as
defined by European RoHS Directive.
6.2.2 Further Reduction of Bromine and Chlorine Content (Still Under Development)
The product shall meet the bromine and chlorine restrictions of IEC 61249-2-21 with a maximum of 900
ppm chlorine and a maximum of 900 ppm bromine and a combined maximum of 1500 ppm for:
Table 6.2
Plastic Parts
Printed circuit boards only
All plastic materials in the product
Points
1
2
This assessment shall be performed consistent with one of the following frameworks: (TG will revisit
and refine this list in the fall)

Interstate Chemicals Clearinghouse Alternatives Assessment Guide, Hybrid or Sequential
Frameworks (www.newmoa.org/prevention/ic2/IC2_AA_Guide-Version_1.pdf)

California Safer Products regulations–CA Code of Regulations Title 22, Division 4.5, Chapter 55
Article 5, Sections 69505.5-69505.7 (dtsc.ca.gov/LawsRegsPolicies/Regs/upload/SCP-Final-RegsText-10-01-2013.pdf) (NEED TO CONFIRM REFERENCING ONCE GUIDANCE IS PUBLISHED)

iNEMI Alternative Materials Assessment Project. (NEED TO CONFIRM REFERENCING ONCE
PUBLISHED)

Report of the National Academies of Science project “Design and Evaluation of Safer Chemical
Substitutions – A Framework to Inform Government and Industry Decisions” (expected August
2014 – need to confirm referencing once published)
An alternative assessment performed on a substance application from a prior-shipped product is
considered sufficient if the application is relevant to the product to which this standard is being applied,
and if the evaluation reflects recent science on substance hazards.
© 2014 NSF International and Green Electronics Council
This document is part of the NSF International standard development process. This document is subject to change and may be a draft and/or
non-final version. Committee members may request permission to reproduce, quote from, and/or circulate this document to persons or
entities outside of their organization after first receiving written permission from NSF International and Green Electronics Council. Send
written requests to NSF International that include notice of to whom and for what purpose this document is to be shared.
Manufacturer shall demonstrate conformance by providing documentation supporting its decision and
the alternatives assessment outcomes with the following:

Methodology used

Date of completion of the assessment; the assessment shall have been completed within XX
years of the date the product is declaration to conform to this criterion

Substances evaluated

Alternative substance used in the product or the technology change made to eliminate the
requirement for the function performed by the substance while still meeting the technical
specifications of the product
In the case of an assessment done as part of a partnership or industry consortium, the other
participating parties shall be named.
6.3 Supply Chain Management of Substances of Concern (Optional)
6.2.3 Reduction of Substances on 6.3.1 Compliance with the European Union REACH Regulation
Candidate List of Substances of Very High Concern Directive (TG Recommendation)
The product shall not contain substances on the Candidate List of Substances of Very High Concern
(SVHC) above 0.1% by weight per Article 33 paragraph 1 of the REACH Regulation and interpreted
according to the European Chemicals Agency “Guidance on requirements for substances in articles.” All
SVHCs with a Date of inclusion >=1 year before the product is declared to conform to this criterion are
subject to this requirement. following lists above the threshold for authorization specified in the
European REACH Directive, using a version which is in force within the XX (two?) years prior to the
product claiming conformance to this criterion:

Substances of Very High Concern (SVHC) Candidate List

Substances Subject to Authorization (Annex X1V)
Manufacturer shall document that a supply chain management system, which may include supplier
management and grading procedures, material declaration and disclosure, as well as includes analytical
testing, is used to ensure that the product does not contain these substances.
Candidate List of Substances of Very High Concern: http://echa.europa.eu/web/guest/candidate-listtable.
6.3 Supply Chain Management of Substances of Concern (Optional)
6.3.2 Inventory 6.3.1 Disclosure of Declarable Substances (TG Recommendation)
Manufacturer shall make publicly available on their website, and provide a link with the product
specification, the reports generated to demonstrate conformance to criterion 6.1.3. The reports shall
contain the CAS number for each declarable substance (not including declarable substance groups).
document the presence of IEC 62474 declarable substances in the product, using the version of IEC
62474 which is current at the time the product is declared to conform to this standard.
© 2014 NSF International and Green Electronics Council
This document is part of the NSF International standard development process. This document is subject to change and may be a draft and/or
non-final version. Committee members may request permission to reproduce, quote from, and/or circulate this document to persons or
entities outside of their organization after first receiving written permission from NSF International and Green Electronics Council. Send
written requests to NSF International that include notice of to whom and for what purpose this document is to be shared.
6.3.2 Requesting Full Substance Inventory (TG Recommendation)
The manufacturer shall require all suppliers to provide a complete list of all the substances and their CAS
numbers in each item supplied to the manufacturer.
“Require” means either the manufacturer has requested this information in writing from the supplier
directly, or has modified the contract between the manufacturer and the supplier to require the supplier
to provide this information.
6.3.3 Receiving Chemical Inventory (Still Under Development)
The manufacturer shall demonstrate that it is receiving a complete list of all the chemicals/materials in
the products/components supplied to the manufacturer, down to the part level, from its suppliers. This
requirement allows for a 5% by weight, per part, of the chemicals and materials to not be reported if
they are confidential business information.
Table 6.x
Receiving chemical inventory from:
POINTS
30% to 49% of [need to define*]
50% to 74%
75% to 95%
96 to 100% of its suppliers
* Need to define the numerator of this percent. Possible options:
 Percent of spend
 Number of line items on the bill of materials(need to address multiple suppliers)
 Number of suppliers
 Percent of product mass
 Percent of…?
The manufacturer has a system for validating reports or other chemical/material ingredient declarations
from its suppliers. Validation process may include:
 Reviewing/auditing the forms submitted by suppliers
 Require suppliers to test parts in approved labs and provide results
 Randomly test parts, components, or products to ensure compliance
 Use a third party to verify supplier information
6.3.4 Greener Chemicals and Processes Information (Still Under Development)
6.3.5 Alternatives Assessment (TG Recommendation)
Option #1: Manufacturer shall document that it or a supplier or a recognized scientific expert has
performed an alternatives assessment on at least one substance of concern included in the product.
The substance shall be listed in the “Declarable Substances List” (Table A) of IEC 62474, Material
Declaration for Products of and for the Electro-technical Industry or listed as a carcinogen, reproductive
toxicant, persistent, bioaccumulative, and toxic (PBT) substance, or endocrine disruptor in the lists in
Annex XX of this standard.
Option #2: Manufacturer shall document that it or a supplier or a recognized scientific expert has
performed an alternatives assessment on at least one substance of concern included in the product.
© 2014 NSF International and Green Electronics Council
This document is part of the NSF International standard development process. This document is subject to change and may be a draft and/or
non-final version. Committee members may request permission to reproduce, quote from, and/or circulate this document to persons or
entities outside of their organization after first receiving written permission from NSF International and Green Electronics Council. Send
written requests to NSF International that include notice of to whom and for what purpose this document is to be shared.
The substance shall be listed in the “Declarable Substances List” (Table A) of IEC 62474, Material
Declaration for Products of and for the Electro-technical Industry.
This assessment shall be performed consistent with one of the following frameworks: (TG will revisit
and refine this list in the fall)

Interstate Chemicals Clearinghouse Alternatives Assessment Guide, Hybrid or Sequential
Frameworks (www.newmoa.org/prevention/ic2/IC2_AA_Guide-Version_1.pdf)

California Safer Products regulations–CA Code of Regulations Title 22, Division 4.5, Chapter 55
Article 5, Sections 69505.5-69505.7 (dtsc.ca.gov/LawsRegsPolicies/Regs/upload/SCP-Final-RegsText-10-01-2013.pdf) (NEED TO CONFIRM REFERENCING ONCE GUIDANCE IS PUBLISHED)

iNEMI Alternative Materials Assessment Project. (NEED TO CONFIRM REFERENCING ONCE
PUBLISHED)

Report of the National Academies of Science project “Design and Evaluation of Safer Chemical
Substitutions – A Framework to Inform Government and Industry Decisions” (expected August
2014 – need to confirm referencing once published)
Manufacturer shall indicate which of the three outcomes their alternative assessment resulted in:
1) A safer alternative was identified and used as the substitute for the original substance,
2) The original substance is determined to be safer than the evaluated potential alternative, or
3) The need for the function provided by the substance was eliminated.
An alternative assessment performed on a substance application from a prior-shipped product is
considered sufficient if the application is relevant to the product to which this standard is being applied,
and if the evaluation reflects recent science on substance hazards.
Manufacturer shall demonstrate conformance by providing documentation supporting its decision and
the alternatives assessment outcomes with the following:

Methodology used

Date of completion of the assessment; the assessment shall have been completed within XX
years of the date the product is declaration to conform to this criterion

Substances evaluated

Alternative substance used in the product or the technology change made to eliminate the
requirement for the function performed by the substance while still meeting the technical
specifications of the product
In the case of an assessment done as part of a partnership or industry consortium, the other
participating parties shall be named.
6.3.6 Making Results of Alternatives Assessment Publicly Available (TG Recommendation)
The manufacturer shall publicly disclose the documentation required for conformance with criterion
6.3.5 and provide a list of criteria and weighting used in the alternatives assessment by either:
© 2014 NSF International and Green Electronics Council
This document is part of the NSF International standard development process. This document is subject to change and may be a draft and/or
non-final version. Committee members may request permission to reproduce, quote from, and/or circulate this document to persons or
entities outside of their organization after first receiving written permission from NSF International and Green Electronics Council. Send
written requests to NSF International that include notice of to whom and for what purpose this document is to be shared.

Posting on a publically accessible database such as the Substitution Support Portal (SUBSPORT),
the IC2 Database, or (need to confirm public accessibility of tools)

Making the documentation readily accessible on the manufacturer’s website.
The manufacturer shall declare the location and the URL of the public disclosure.
Point value:
Annex XX - Lists of Carcinogens, Reproductive Toxicants, and Persistent, Bioaccumulative, and Toxic
(PBT) Substances
Carcinogens
Listed by the International Agency for Research on Cancer as:
Group 1: carcinogenic to humans
Group 2A: probably carcinogenic to humans
Listed by the National Toxicology Program as:
Known human carcinogen
Reasonably anticipated human carcinogen
Meet the criteria under the Globally Harmonized System of Classification and Labeling (GHS) for the
Carcinogenicity hazard class (codes H350, H351).
Reproductive Toxicants
Listed under the State of California Safe Drinking Water and Toxic Enforcement Act (Prop 65) for
reproductive or developmental toxicity.
Meet the criteria under the Globally Harmonized System of Classification and Labeling (GHS) for the
Reproductive Toxicity hazard class (codes H360, H361, H362).
PBT Substances
Stockholm Convention Persistent Organic Pollutants
U.S. – Canada Binational Toxics
Toxics Release Inventory (TRI) PBT chemicals
RCRA Waste Minimization Priority Chemicals
Endocrine Disruptors
The Endocrine Disruptor Exchange (TEDX) list (http://endocrinedisruption.org/endocrinedisruption/tedx-list-of-potential-endocrine-disruptors/overview)
© 2014 NSF International and Green Electronics Council