Draft for Review
United Nations Environment Programme
The Chemicals in Products programme
Guidance for Stakeholders in Exchanging Chemicals in
Products Information (v5)
June, 2015
Chemical in Products Programme
Table of Contents
Introduction .................................................................................................................................... 3
Guidance on Identifying Chemicals for Information Exchange and the Relevant Information for
these Chemicals .............................................................................................................................. 4
Guidance for Programme Participants in the Supply Chain ......................................................... 12
Guidance for Programme Participants Outside the Supply Chain ............................................... 14
Overview of CiP information systems and exchange ................................................................... 17
Introduction
This Chemicals in Products programme “Guidance for Stakeholder in Exchanging Chemicals in
Products Information” (programme Guidance) is intended to provide guidance to those who are
designing a CiP information system or seeking to participate in an existing system. The
programme Guidance supports the CiP programme Document. It provides direction for those
stakeholders who require assistance in their CiP information exchange, by describing steps
commonly taken in scoping, designing and building a CiP information exchange systems.
The programme Guidance is a companion document to the Chemicals in Products programme
Document. The Guidance is designed with the recognition that many stakeholders are building,
or are already operating, CiP information exchange systems, whose aims align with the CiP
programme Objectives.
This document provides guidance on the activities associated to:
 identifying the chemicals and chemicals information to include in the CiP information
exchange system; and
 steps to prepare both internally within the stakeholder’s organization and with external
stakeholders for the information exchange, so that the CiP programme Objectives can be
achieved.
This document includes descriptions of existing systems, which provide useful examples to
stakeholders seeking to define key parameters which typically need to be considered at an early
stage, i.e., before designing or choosing a system.
It is important to reiterate the overall CiP programme Objectives upon which this Guidance is
designed.
CiP programme Information Objectives
1. Within SUPPLY CHAINS, KNOW AND EXCHANGE information on chemicals in products,
associated hazards and sound management practices.
2. DISCLOSE information of relevance to stakeholders outside the supply chain to enable
informed decision-making and actions about chemicals in products.
3. ENSURE that information is accurate, current and accessible.
3
Guidance on Identifying Chemicals for Information Exchange and the
Relevant Information for these Chemicals
To take actions towards meeting the programme Objectives, stakeholders must first determine
which chemicals1, and what associated information, to target for information exchange. These
decisions depend on numerous factors, including the product sector, the objectives of the
information exchange and the stakeholders generating and receiving the information. Making
such decisions should, in general, involve involve two steps:
1) determining which chemicals are to be included in the information exchange; and
2) determining for those chemicals the information to be exchanged.
The following section describes these two steps and provides examples from current practices.
1. Determining and selecting the chemicals to be included in the information
exchange
Selecting chemicals based on potential for significant adverse impacts on human
health or the environment and/or which are regulated2 by governments in countries
where a product is manufactured, sold, used or disposed.
One of the most fundamental parameters in any CiP information exchange system are the
chemicals it covers. As described in the CiP programme Document, the rationale for choosing
any particular set of chemicals depends on many factors3.
Selection based on existing regulation
The CiP programme recommends that stakeholders identify, at a minimum, regulated
chemicals2 contained in the products in question. To identify regulated chemicals, a CiP
programme participant would need to review the chemical regulations in those countries in
which it operates to ensure the products and information on the chemicals included are
compliant with national legislation and regulation.
The approach of using regulations to determine which chemicals to include in a CiP information
system is common. The wide use of systems based on Restricted Substance Lists (RSLs) is the
1
The chemicals can be identified by a Chemical Abstract Service (CAS) number or through a similar
internationally recognized chemical identification system.
2
Throughout the CiP programme chemicals referred to as “regulated” signifies those chemicals where a
prohibition, restriction, threshold limit, required authorization or similar limitation is applied through
existing legislation.
3
As an example, two brands in the same product sector but with significantly different end uses for their
CiP information may scope widely different sets of chemicals. These two hypothetical stakeholders can
both be completely aligned with the CiP programme Objectives, provided they build or use CiP
information exchange systems that deliver the information needed for their end uses (i.e., for their sound
chemicals management decisions and actions).
4
result of companies and other stakeholders targeting chemicals based on the laws in countries
in which they operate.
Beyond regulated substances: a pre-emptive approach
Stakeholders applying the “regulated chemical” scoping criteria above would generally also
benefit from including those chemicals which are projected to be regulated. This is a proactive
approach, frequently taken by companies and other stakeholders in their CiP information
exchange activities, and involves adding projected-to-be-regulated chemicals to the chemicals
listed in their regulatory-based systems (i.e., in their RSLs). This approach has clear advantages
as companies and others may seek to avoid chemicals before they are legislatively restricted and
assess the impacts of potential or pending restrictions.
In the majority of systems based on RSLs this pre-emptive approach is used.
Selecting chemicals based on hazard characteristics
While many chemicals of concern4 (CoC) are addressed by regulation, the absence of, or
conflicting regulations between countries create challenges selecting chemicals for inclusion in a
CiP information system. Numerous chemicals may be restricted in some jurisdictions and either
not regulated or regulated differently in others. It may be the case that legislation is not yet in
place to effectively address chemicals in products issues. In response to this challenge
stakeholders may use the SAICM criteria5 to identify the chemicals that they choose to include
in their information exchange systems/activities. These SAICM criteria, based on hazard and
targeting risk reduction, provide an internationally-accepted basis for selection of chemicals
under the CiP programme.
Similar to the approach of using the SAICM criteria, CiP Programme participants may wish to
select the chemicals they include in the programme based on what is considered a hazardous
substance, as determined by the criteria of the Globally Harmonized System of Classification
and Labelling of Chemicals (GHS). This can be accomplished by screening chemicals against the
health and environmental endpoints identified in the GHS and determining which chemicals
classified as hazardous under the GHS are present in their products; if these chemicals are
present in the manufactured article above a threshold value, then these chemicals could be
covered by the CiP programme6.
Information on chemicals and their properties is supplied under the GHS from chemical
suppliers in a large number of jurisdictions. This is an increasing trend, with more and more
countries implementing the GHS. This approach presents an opportunity to use GHS chemical
4
“Chemicals of concern” were defined during the scoping phase of the CiP project (2009) as “chemicals
which, due to their inherent hazardous properties, present a known or reasonably suspected risk to
human health and/or the environment”.
5
SAICM Overarching Policy Strategy, Paragraph 14
6
GHS safety data sheets could be used in the supply chain for hazardous chemicals remaining in the
product or product component. Companies could use third parties to collect, store and process the
information in these safety data sheets, similarly as for chemicals targeted through.
5
information in CiP information exchange. Opportunities for coordination between GHS and the
CiP programme should be further investigated.
In summary, there are numerous ways to select chemicals for information exchange based on
their regulated status or hazardous characteristics. Stakeholders should refer to the examples
and information given below (Tables 1, 5 and 6) and consider the characteristics for the product
and product sector in selecting their chemicals for inclusion.
Information references for selecting chemicals
Companies and other stakeholders that apply the regulated chemicals or pre-emptive
approaches described above when scoping chemicals may refer to the listing in Table 2 of
various chemical lists. The lists noted generally include chemicals based on a legislative
restriction and/or a health or environmental hazard. These lists are not exhaustive and
stakeholders should undertake an appropriate review to have an accurate and current list of the
chemicals which are regulated (or projected to be) for the particular product or sector.
Knowing what's in a product: a significant step towards significant benefits
Many current CiP information exchange systems are used to exchange information about which
chemicals are not in products. Other systems are used to present information on what
chemicals are in products. The CiP programme recognizes the value of these two approaches
and encourages stakeholders to adopt a system which best meets their requirements, goals and
resource possibilities.
There are clear and inherent advantages which come from knowing which chemicals are present
in products. Chemicals “intentionally added to the product” are typically included in such
systems7. There are also significant resources typically associated with implementing systems to
transmit this level of information. A recent UNEP publication highlights this cost/benefit from
experience in building and using such a system in the electronics sector8.
--------------Table 1 below gives examples of and summarizes systems developed and applied in the product
sectors represented on the CiP Project Steering Group (the Overview of CiP systems section
below gives further examples).
The subsequent caption box (reproduced from the CiP programme Document) recalls the
significant benefits which have been realized by numerous industry and product sectors through
use of the various types of CiP information systems.
7
Intentionally added chemicals below a pre-determined concentration usually do not need to be reported
under existing systems, unless they are regulated chemicals or exhibit hazardous characteristics.
8
The report “The Business Case for Knowing Chemicals in Products and Supply Chains” addresses this
topic in depth (see URL:
http://www.unep.org/chemicalsandwaste/UNEPsWork/ChemicalsinProductsproject/tabid/56141/Default
.aspx ).
6
Table 1: CiP information systems – selected summaries
Sector and system(s)
Automotive:
International Material
Data System (IMDS)
Electronics:
1) International
Electrotechnical
Commission (IEC)
Database 62474
Mechanism/Body for
sector coordination
Coordination between:
1) Sponsors Group
(members company
management), and
2) Steering Committee
(member company
experts)
1) IEC Technical
Committee No 111
2) Institute for Printed
Circuits (IPC) 1752A
Materials Declaration
Management Standard
Results
IMDS has become a global standard used by
almost all of the global automotive OEMs. In
IMDS, all compliance-relevant materials used
for automobile manufacturing are collected,
maintained, analysed and archived by
following the CBI principles. Using the IMDS,
it is possible to meet the obligations placed
on automobile manufacturers, and thus on
their suppliers, by national and international
standards, laws and regulations.
1) IEC 62474 provides a harmonized CiP
information exchange system approach for
the sector, through requirements for
reporting of substances and materials,
standardizing protocols, and facilitating
transfer and processing of data.
2) IPC Committee 22) IPC-1752A is the materials declaration
18b Materials
standard for companies in the supply chain
Declaration Task Group to share information on materials in
products. The standard is supported by an
XML schema and a data model.
Textiles:
Work streams within
Historically there has been collaboration
The Chemicals
SAC, OIA and ZDHC
among major brands on RSLs (based on a
Management
manage the CiP
preemptive approach) resulting in
Framework of the
information elements
coordination of approaches and training
Outdoor Industry
under these initiatives materials for supply chains.
Association (OIA),
and coordinate
which is integrated
between themselves
Current efforts extend coordination to
into the Sustainable
and within the sector.
development of sector harmonized: 1) tools
Apparel Coalition (SAC)
for supplier facility audits, 2) schemas to
Higg index;
gather CiP information and 3) levels of
the data schema and
performance metrics for brands and supply
facility audit protocol
chain actors.
developed by the Zero
Discharge of
Hazardous Substances
Working Group (ZDHC)
7
Advantages cited by manufacturers / brands through use of existing CiP information systems

Major cost savings in the supply chain: the sector-wide approach leads to a broad
harmonization of individual customer (and supplier) requirements for CiP information. This
avoids a patchwork of systems and results in an efficient and cost-effective transfer of
information in the sector.

Legislators and NGOs become aware of the sector’s CiP information systems and management
processes and recognize that they are providing useful information exchange: this greatly
facilitates manufacturers in terms of inspections or compliance audits and also results in that the
sector or system users are not key targets for NGO campaigns.

When a chemical or substance is subject to a legislative restriction somewhere in the world,
the sector has the possibility to more easily start the necessary countermeasures in time.
These could include:
o Impact assessments: Check the related impact on the industry;
o Alternative Assessments: Having sufficient time for substitutions results in cost savings;
o Lobbying: Reliable and high quality input into stakeholder consultations, appreciated both by:
 Legislators: The sector can provide more accurate information to legislators, who can then
better decide on the most appropriate risk management measures; and
 Chemical industry: The sector can provide more accurate information to the industry (their
suppliers), who can then better they can defend their substances during their own lobbying
actions.

A high degree of system knowledge is achieved in the supply chain, which boosts supplier
compliance: suppliers understand their obligations under the system, and also that they will get
an immediate response from their customers if they produce non-compliant parts.
In cases of individual customer requests manufacturers are able to prove reliable answers.
2. Determining the Information to be Exchanged
After selecting the chemicals for information exchange in Step 1 above, stakeholders would next
determine what information to exchange on the selected chemicals.
The aim of the CiP programme Information Objectives is that reliable and relevant CiP
information is available throughout the life-cycle for stakeholder decisions and actions. More
specifically, for the individual Objectives in the Programme document:
Objective 1: the CiP programme calls for information exchange through supply chains on
hazardous chemicals present in products. The information exchange would be for chemicals
determined to be in scope (i.e., in Step one above - chemicals which are regulated, or assessed
as hazardous, or intentionally added to the product) and present above a pre-determined
threshold values. The information should include identification of the hazards the chemicals
8
present and associated safe handling instructions. This information should be supplied in
appropriate language for the recipients.
It is within the supply chain that products are made and the product chemistry can change.
Following the addition of new chemicals and tracking the presence of existing chemicals (e.g., in
sub-components) calls for a hazard-based approach.
CiP information exchange in supply chains are usually built on existing business relationships,
which allow for confidential information protection mechanisms.
Objective 2: the CiP programme calls for the information exchange needed to enable a
chemicals management decision and action by a stakeholder outside the supply chain. This may
be achieved by documenting that selected chemicals of concern are not in a product or by
acknowledging when they are present, along with appropriate precautions and use instructions.
There are cases where hazardous chemical content information would be appropriate, and
others where a risk-oriented communication is better suited. The information should at a
minimum enable the recipient to decide and act so as to minimize the risk of significant adverse
effects to health or the environment.
Outside supply chains, the range of possible decisions and actions by (and within) stakeholder
groups is highly varied, and so would be the corresponding enabling information. The
expectation within the CiP programme, is that those both requesting CiP information, and those
providing CiP information, would engage in a constructive dialogue, on information needs. The
aim of such dialogue would be to make available useful information for a product purchase or
other chemicals management decision or action9. As with Objective 1, this information should
be supplied in appropriate language for the recipients.
If disagreement exists as to what information is relevant to include, the final decision is, unless
otherwise required by law, to the information provider as to what information is provided. In
such cases the provider should be open and transparent in the rationale for their decision.
Determining “Relevant information”
The CiP Programme suggests a focused dialogue for stakeholders to define their information
needs and how to best meet those needs.
Paragraph 15(b) of the SAICM Overarching Policy Strategy states that CiP chemical information
be “….appropriate to the needs of all stakeholders”, where “appropriate types of information
include their effects on human health and the environment, their intrinsic properties, their
potential uses, their protective measures and regulation”. The ICCM3 Resolution on Chemicals
in Products targets the facilitation of access to “relevant information” and to take into
consideration “best practices and successful experiences”.
For the purposes of the CiP Programme, “relevant information” is defined broadly as “the
information that the recipient needs to take an informed purchase or chemicals-management
9
See also the CiP programme Document section on Confidential Business Information and Information
Security
9
decision or action”. For information to be relevant it must be pertinent (the recipient can use
the information to inform actions) and it must be in a usable format (i.e., it is accessible, clear
and understandable). Defining what is “relevant” then depends also on specifying what the
intent is for use of the information, which itself depends on the level of the recipients’ ambition
to act upon the CiP information10.
To design and put into operation a CiP information system, this broad definition of relevant
information must be refined. This requires characterizing the range of the recipients’ ambitions
(e.g., to purchase a product or to manage chemical risk or hazard), and the related actions. In
this regard, dialogue between the stakeholders exchanging the information would clearly be
useful and is highly recommended (as pointedly mentioned in Objective 2).
Thresholds for Reporting
Companies that participate in the CiP programme are encouraged to refer to chemical hazard
lists to screen for regulated chemicals and/or health and environmental hazards (see Table 2).
These lists sometimes include reporting thresholds for specific chemicals, which may be useful
to determine if particular chemicals would be in scope for the CiP information system being
used.
An alternate method is to base the reporting thresholds upon the GHS. Here the default
threshold for reporting is 0.1% (1,000ppm) for known or suspected carcinogens, mutagens, and
reproductive toxicants and 1% (10,000ppm) for other substances. There may be evidence that a
chemical or mixture is hazardous below the default threshold level. In these cases, the
threshold reporting level should be reduced accordingly.11
10
General examples include brand or manufacturer decisions about component selection, consumer
decisions about product purchase, use and handling and end-of-product-life decisions about waste
handling and recycling.
Scoping the relevant information raises numerous questions: which life cycle stage is targeted? who are
the stakeholders and what are their capacities and ambitions for chemicals management actions?
More specific examples could include:
For a consumer “relevant information” is at a minimum the chemical information needed for a product
user to make informed decisions and take action about the purchase and safe handling, use and disposal
of a product. A more ambitious consumer might be one who would act on information linking the
product’s chemicals to a broad range of possible impacts on health or the environment: these consumers
would have a need for information beyond the minimum.
For a brand or retailer the minimum relevant information will be that needed to ensure adequate control
of the chemicals in the products, in accordance with legal responsibilities. Companies with more
advanced corporate goals would require more information. Manufacturers and suppliers similarly would
target differing levels of information to meet corporate aims, as well as client requirements for chemicals
oversight or control.
11
GHS provides cut-off values/concentration limits for health and environmental endpoints of 1% for
acute toxicity, skin corrosion/irritation, serious eye damage/eye irritation, germ cell mutagenicity
category 2, specific target organ toxicity, and hazards to the aquatic environment, and 0.1% for
respiratory/skin sensitization, germ cell mutagenicity category 1, carcinogenicity, and reproductive
toxicity. United Nations, Globally Harmonized System of Classification and Labeling of Chemicals (GHS):
Fifth revised edition. New York and Geneva: United Nations, 2013. Table 1.5.1, p. 36: Cut-off
10
Table 2: Listing of Chemical Hazard Lists
Chemical Hazard Lists: Examples
Hazard Class
Acute toxicity
Asthma
Endocrine
Disruption
Cancer
List
- Extremely Hazardous Substances (EPCRA Section 302)
- Association of Occupational and Environmental Clinics (AOEC)
Asthmagen List
-E.U Community Strategy Endocrine Disruptors—Priority List
Sponsoring Agency
- US EPA
-AOEC
-Monographs on the Evaluation of Carcinogenic Risks to Humans
-International Agency for
Research on Cancer
-U.S. EPA
-U.S. National Toxicology
Program
-California EPA
-Integrated Risk Information System (IRIS)
-12th Report on Carcinogens
Reproductive and
Developmental
Toxicity
PBTs
POPs
Ozone Depletion
Priority
substance lists
based on various
endpoints
Other
information
sources
-Chemicals Known to Cause Cancer or Reproductive Toxicity—
Prop. 65
-Expert Panel Reports on Reproductive and Developmental
Toxicity
-Chemicals Known to Cause Cancer or Reproductive Toxicity—
Prop. 65
-National Waste Minimization Program Priority List of PBTs
-European Chemical Substances Information System—PBT List
- State of Washington Persistent Bioaccumulative Toxins
(Chapter 173-333)
-Stockholm Convention on Persistent Organic Pollutants
-Regulation (EC) No. 1005/2009—Substances that Deplete the
Ozone
-Ozone Depleting Substances—Class 1 & Class 2
-Global Warming Potential of Ozone Depletors and Substitutes
E.U. Substances of Very High Concern for Authorization
Chemicals of Concern Action Plans
European Commission Classification and Labelling Inventory –
CMRs
Global Portal to Information on Chemical Substances
Hazardous Substances Information System
CSI (Chemical Sampling Information)
-European Commission
-U.S. National Toxicology
Program
-California EPA
-U.S. EPA
-European Commission
-State of Washington
-UNEP
-European Commission
-U.S. EPA
-European Commission
-U.S. EPA
- European Commission
-OECD
Substances with EU Risk & Safety Phrases (European
Commission Directive 67-548-EEC)
-Australia
-U.S. OSHA
-European Commission
Canadian Environmental Protection Act (Schedule 1: List of Toxic
Substances)
Chemicals under the US Toxic Substances Control Act (TSCA)
-Health Canada and
Environment Canada
value/concentration limits for each health and environmental hazard class. , URL:
http://www.unece.org/trans/danger/publi/ghs/ghs_rev05/05files_e.html
11
Work Plan
Minamata Convention on Mercury
Chemical Substances Control Law (Class I Specified Chemical
Substances and Class II Specified Chemical Substances)
-U.S. EPA
-UNEP
-MHLW, METI and MOE,
Japan
Guidance for Programme Participants in the Supply Chain
Stakeholders in the supply chain will need to take certain basic steps to be able to meet the CiP
programme Objectives. After selecting chemicals for information exchange and the relevant
information to be exchanged, the next step is to communicate within a supply chain, typically
through existing business relationships, the need to establish information flow of the chemicals
in products. This involves engaging with supply chain partners to describe clearly:
 the rationale behind the request – why this information is needed;
 that the request for information is a priority, and why it is important;
 which chemicals information is foreseen or expected to be included in the exchange
(chemicals in scope and information on those chemicals);
 what the information will be used for, including which chemicals management decisions
and actions may be taken based on the information;
 the advantages that will or could be gained through such information exchange (business,
reputational, etc.);
 how the information will be transmitted (i.e., through an existing system or service or new
system yet to be established, etc.);
 the details around the protection of the parties interests (e.g., CBI); and
 the economic facets – how will the information exchange be financed.
These above elements will involve considerable dialogue between and among supply-chain
partners as they determine the details relevant to their circumstances. The CiP programme’s
Know, Disclose and Ensure Information Objectives provide a reference that can be useful in
guiding such dialogue.
This section of the guidance describes common activities, which those in a supply chain might
apply, in meeting the three CiP programme Information Objectives.
Table 3: Suggested activities for supply chain stakeholders to meet CiP programme
Objectives
CiP programme Objective
Within SUPPLY CHAINS, KNOW
AND EXCHANGE chemicals in
products, associated hazards
Suggested Activities


Establish a point of contact
Determine the desired scope of
chemicals to be covered by the CiP
12
Comments
and sound management
practices.




DISCLOSE information of
relevance to stakeholders
outside the supply chain to
enable informed decisionmaking about chemicals in
products.




information exchange system
Communicate with supply chain
partners to define the system
parameters and CiP information
details
Research systems and services
available within the sector
Conduct training for supply chain
partners and internal personnel
Create or use a system / service to
exchange information within the
supply chain
Establish a point of contact
Provide corporate statement on the
objectives of the CiP information
exchange, including objectives for
outside the supply chain
Communicate with partners outside
the supply chain to define the means
and details for the CiP information
exchange
Disclose information needed for
stakeholders outside the supply
chain to take sound chemicals
management decisions and actions
When determining what
information to exchange outside
the supply chain and how, to
consider is that the potential uses
for CiP information vary widely, as
do stakeholders’ desires and
capacities to access and act upon
the information. Particular
attention should be given to the
language and terms used in such
disclosures, especially in
circumstances where a technical
background may be absent or
limited and where language
barriers may inhibit effective
communication. The date that the
disclosed information was
produced would also be useful to
provide.

ENSURE that information is
accurate, current and
accessible.




Review (e.g., annually) the chemicals
in scope and update as needed
Establish a means to ensure the
quality and accuracy of information
exchanged (e.g., quality
management system, independent
certified laboratory verification).
Require suppliers to provide
independent (e.g., third-party)
verification, as needed
Review (e.g., annually) with CiP
information providers and recipients
for feedback on whether the
received or provided information is
sufficient and adjust as needed
13
Guidance for Programme Participants Outside the Supply Chain
Consumers, end-of-life actors, those in government agencies and non-governmental
organizations (including workers’ organizations) can participate in the CiP Programme, as well.
Section 5 of the CiP programme Document describes the roles of CiP stakeholders outside the
supply chain. This Section of the Guidance suggests actions that could be taken to achieve the
CiP programme Objectives.
Table 4: Suggested activities for stakeholders outside supply chains to achieve CiP
programme Objectives
Stakeholder group
Government agencies
The varying government roles of
regulator, customer, provider of
public information and initiator
and/or supporter of nonregulatory initiatives present a
wide range of opportunities and
responsibilities with respect to
CiP information.
Suggested Activities
Comments
1. Use CiP information systems
to both meet and anticipate
regulatory reporting
requirements, as well as
supporting more ambitious
initiatives.
1. Many CiP information initiatives that
exist today had their start in
response to regulation. An extensive
discussion of the important role
regulations have served in driving
this issue forward is found in other
CiP project documents12.
2. Use public procurement to
promote improved CiP
information exchange, sound
chemicals management and
green chemistry.
2. As customers, governments have
purchasing power which can
influence markets and drive change,
often to a significant degree. Public
procurement strategies can send
strong signals and stimulate
innovation and change in the private
12
see for example the CiP project Synthesis report, URL:
http://www.unep.org/chemicalsandwaste/UNEPsWork/ChemicalsinProductsproject/tabid/56141/Default
.aspx
14
sector.
3. Promote voluntary initiatives
and collaboration.
4. Drive awareness of CiP issues.
End of life (EOL) actors:
Recyclers/Disposers
The steps involved in a product’s
end of life may be highly complex.
End-of-life actors need
information for safe handling,
including which hazardous
chemicals are in a product and
where they are located, and how
to prevent exposures. They need
information on product
composition so that materials can
be properly sorted and
processed, including information
on the base material and
additives.
1. Monitor chemical issues and
information provided by
upstream actors, including
materials/chemicals location
in products and identification
methods.
2. Provide information to
producers about how their
information is being used and
areas for improvement,
including technical means
used in the EOL operations,
language issues and marking,
tagging, list or label options.
3. Government roles of policymaker,
regulator and customer allow
governments to convene relevant
stakeholders and to construct and
operate voluntary initiatives that will
achieve policy aims.
4. As a major provider of information,
governments can support all of the
above activities, both through
targeted communications to
particular stakeholders and through
information to the general public, as
well as through creation of CiP
information infrastructure.
In some sectors brands and OEMs are
taking action towards ensuring that
their products are properly managed at
end of life. At the same time, recyclers
and other end-of-life actors have
developed their own certification and
auditing systems to ensure that
materials are properly managed. Given
the need for information about
products as well as for manufacturers
to obtain information when recycling
(point 3) it is crucial that there be
communication between producers
and end-of-life actors.
3. Provide CiP information to
manufacturers incorporating
recycled materials back into
products.
Corporate customers / buyers
4. Provide information to
producers about problems
with product designs or
manufacturing and suggest
improvements.
1. Corporate buyers should
consider the CiP programme
Objectives in their procurement
decisions and take appropriate
15
1. As consumers of products,
corporations have significant
purchasing power and ability to
affect markets. They can drive
action.
Corporations in the CiP
programme could describe (e.g.,
through reporting) how these
decisions and actions lead to
achieving the CiP programme
Information Objectives.
Non-Governmental
Organizations (NGOs)
Actions and comments are for
NGOs representing the public
interest. Suggested actions for
NGOs representing private sector
interests are covered under
supply chain activities.
1. Identify the need for CiP
information and the chemicals
management decisions and
actions to which the
information could contribute.
2. Establish working
relationships with and between
the businesses and
organizations that can provide
the needed CiP information.
change by applying a corporate
strategy to their purchases of the
business materials, consumables and
infrastructure necessary to run their
businesses13.
Corporate CSR policy and
commitments can (and often do)
align with the CiP programme
Objectives.
1. This may include conducting
research and generating data on
chemicals in products.
2. When appropriate, establish
agreements as to conditions under
which the information is to be used
and/or disclosed.
3. Research and collaborate to
determine the most appropriate
format and means (systems) for
exchange of the needed CiP
information.
Individual Consumers
Consumers make up a very
heterogeneous stakeholder
group, including individuals and
corporate purchasers. This gives
rise to a multitude of potential
uses / needs and corresponding
sets of information to meet those
needs.
Examples of possible actions are
4. Publish CiP information (e.g.,
through publications or websites) based on data provided or
from research – see comment 1.
1. Activities for this consumer in
the CiP programme are to look
for and read warning labels and
to heed any safety instructions,
including for waste disposal.
Another action is to ask
questions, should there be any,
on the proper handling, use or
disposal with respect to the
chemicals contained in the
13
1. Consumers in this group assume that
a product for sale is safe, based on
the notion that either the
government or the product
manufacturer has the responsibility
to ensure this safety, to perform
oversight functions and to issue
appropriate warnings.
Corporate purchases (related to running a business) are described here and not corporate contracts
(which relate to the provision by the business of e.g., products or services).
16
given for two types of consumer:
1) Consumers not especially
motivated to search for CiP
information. This subset of
consumers is arguably the largest.
Defining characteristics include
that this consumer wants a safe
product.
2) Consumers who are motivated
to seek and act on CiP
information. These consumers are
aware of the potential for harm
that can arise from chemicals in
everyday products. They will look
for product labels and
certifications of (chemical) safety.
They make purchasing decisions
influenced by the CiP information
and knowledge they have
available.
Both examples above assume no
specialized chemicals knowledge,
and that a prime motivating factor
in purchasing decisions is value
(including elements of both
quality and price).
product.
2. Activities for these
consumers include, as is
practicable, to Know the
problematic chemicals related
to the products they purchase,
to investigate the product
labelling and CiP information
available, Ensure the
information meets their
standards as trustworthy and to
ask questions, should there be
any, on the proper handling,
use or disposal with respect to
the chemicals contained in the
product.
2. These consumers are aware of the
potential for harm that can arise
from chemicals in everyday products.
They will look for product labels and
certifications of (chemical) safety.
They make purchasing decisions
influenced by the CiP information
and knowledge they have available.
Another activity is to provide
feedback to the providers of the
information (e.g., is it clear and
adequate, or how it could be
improved).
Overview of CiP information exchange systems
This section gives an introduction to numerous CiP information exchange systems, related
initiatives and the lessons learned from these activities. The information contained herein is not
exhaustive, and periodic additions and updates on lessons learned and (especially) to the list of
existing systems will be needed to maintain a current list. In this respect the Guidance
represents an opportunity for the SAICM community to keep abreast of, connect with and add
value to this important yet complex policy issue.
CiP information exchange system and related initiatives
The CiP information exchange systems listed in Table 6 in most cases arose in response to an
identified sequence:
17
A chemical in
identified as
harmful and is
or will be
subject to legal
restrictions
Companies
using this
chemical take
steps to safely
manage, or use
a substitute, in
their products
Individual company
solution
Companies have a
similar issue with
the chemical and
come together to
build a sectorwide approach
A CiP information
exchange system
is established as
part of the efforts
to safely manage
the chemical
Sector based solution
The types of exchange systems in use and some of their general characteristics are:
Information disclosure within supply chains: The majority of methods currently in use in supply
chains include a targeted list of restricted chemicals (an RSL). The chemical list is established
based on the needs and objectives of the stakeholders (e.g., information for meeting or
anticipating regulatory compliance). These systems typically include requirements for reliable
CiP information exchange that are similar to the CiP programme (i.e., Objective 3). The most
common method for information exchange in the supply chain is electronically, either directly
between stakeholders, or via a third-party service provider (i.e., contracted third party).
Information disclosure to stakeholders outside the supply chain: Information made available to
stakeholders outside the supply chain is most often derived from information generated and
exchanged inside the supply chain. Examples include CiP information targeted to stakeholders,
e.g., retailers via product labelling or packaging, via markings on the product (e.g., precautions
or end of life instructions), or through in-store displays as part of brand marketing.
Related to both of the above, electronic systems in use within supply chains can feed
information targeted to stakeholders outside the supply chain as well. Examples include when
product traceability data or third-party certifications (i.e., the business-to-business verifications
related to product labels) are made available on a public web site.
Communication between stakeholders wholly outside of supply chains includes public
awareness campaigns in places such as public transit systems, government buildings, billboards,
TV or other electronic media. Information on chemical hazards, warning labels and safe handling
are other examples of general public awareness-raising. More targeted awareness campaigns on
product specific CiP issues are frequently carried out via web sites, email notifications, print
media and billboards.
CiP information combined with other information: CiP information can be combined with other
information as a part of a broader sustainability communication. Thus energy or water use,
recycled materials content, working conditions and labour rights and other issues are sometimes
included with CiP information and contribute to a message related to corporate social
responsibility. This avenue of communication represents an excellent opportunity for the SAICM
community to ‘connect’ the CiP issue into mainstream sustainability discussions.
Lessons learned from existing Information Exchange Systems
18
Stakeholders currently employing many of these systems would already be achieving certain
Information Objectives of the CiP programme. As a general presentation of lessons learned from
CiP information exchange systems analyzed through the CiP project (2009 – 2015) an indicative
listing is given in Table 5 of the pros and cons of various systems based on the scope of the
chemicals they target (regulated chemicals only, regulated chemicals plus those foreseen to be
regulated, etc.).
Table 5: Lessons from CiP information systems – pros and cons of systems vs.
chemicals in scope
Scope of the CiP information
covered
Pros and advantages
Cons and disadvantages
Restricted Substances List (RSL)
based on product chemicals
content actually restricted by
legislation
 Selection of chemicals in scope is
straightforward
 Product sector associations can
provide a list for their member
companies, greatly reducing individual
company research efforts needed to
determine the CiP information
system’s chemicals scope.
 Allows for a clear target – legally
compliant products – for both
individual companies and service
providers (e.g., 3rd party certifiers).
 The goal of ensuring a product is
legally compliant is more simple,
making this approach easier from a
business management and due
diligence perspective.
 Every time a new chemical is
added to the list the entire
supply chain must adjust – on a
short time scale – to include
the related CiP information in
the system
 When a chemical becomes
restricted, there is an
immediate need to investigate
for presence and potentially
urgent materials substitutions
or product design changes are
required
 Regular review of jurisdictions
is needed, which is time
consuming
Restricted Substances List (RSL)
based on product chemicals
content actually restricted by
legislation, or anticipated to be
restricted.
 Chemicals are in selected for
information exchange before they are
subject to regulatory restrictions,
allowing:
- material substitutions and design
changes in a planned manner; and
- to meet any regulatory reporting
requirements (e.g., for demonstrating
compliance) as soon as they come into
force.
 Brands and manufacturers are
following potential legislative
developments and can provide input
to the legislative process in a timely
manner.
 More chemicals must be
included in the information
exchange and the measures to
ensure compliance (e.g., testing
to check for presence or
concentration), leading to
higher costs to run the CiP
information system.
 In addition to a regular review
of jurisdictions and the costs
associated with this, companies
must also dedicate resources to
follow the developments and
(possibly) participate in the
debates on chemicals under
consideration for restriction.
19
Systems based on product
content declarations (within the
supply chain)
 Provides a comprehensive overview of
materials and chemicals in a product
 Allows for immediate verification of
compliance when new chemicals are
restricted
 Allows material substitutions and
design changes in a planned manner
when new chemical restrictions are
anticipated
 Minimizes incremental costs when
new chemicals come into regulatory
scope
 Enables moves to green chemistry
better than other system designs
 Leads to less pressure from regulatory
oversight bodies and NGOs
 Likely the most expensive type
of system to set up initially
 Materials which are used in
products often do not have a
human-health or
environmental hazard profile:
data gaps are an obstacle to
knowing potential impacts
A detailed comparison of existing CiP systems and the CiP programme Objectives needs to be
undertaken on a system by system basis. Such a read-across analysis would allow for recognition
within the SAICM community of those leading systems and the stakeholders using them. As part
of the CiP programme pilot in the textiles sector14, a preliminary version of such a list has been
developed and is contained in the Table 4 below. Table 4 also presents brief descriptions of
systems used in other sectors identified during the course of the CiP Project15.
Table 6: Examples of existing CiP information systems and related initiatives
The table below provides examples of existing systems and provides general indications of the
type of system and the main product sector(s) using the system. A cross referencing between
these existing systems and the CiP programme Objectives requires detailed comparison.
Owners or operators of these and similar systems are encouraged to participate in the CiP
programme and benchmark their system against the CiP programme Objectives.
System
Sector
Description / Characteristics
14
Project documents for the GEF-funded “Defining and Demonstrating Best Practices for Exchange of Information on
Chemicals in Textile Products” are available at URL: https://www.thegef.org/gef/project_detail?projID=5662
15
Mention of particular examples does not imply blanket endorsement of their suitability or quality: users may wish
to consider whether a particular example is structured in a way which meets their needs.
20
3E GPA™,
GreenWERCS™, iPoint,
Hewlett-Packard and
SciVera Lens™
BizNGO Guide to Safer
Chemicals
Multiple sectors
Any sector
International Material
Data System (IMDS)
Automotive
BASTA
Building materials
These are private firms providing confidential chemical
information tracking and assessment services.
The BizNGO Guide broadly covers a company’s chemical
management responsibilities and aligns well with the CiP
Programme. The progression of activities described under the
four levels in the BizNGO guide on Know and Disclose align with
the Objectives of the CiP Programme.
Data repository and communication system for use by
automobile manufacturers and throughout their supply chains.
IMDS has become a global standard used by almost all of the
global automotive OEMs. In IMDS, all compliance-relevant
materials used for automobile manufacturing are collected,
maintained, analysed and archived by following the CBI
principles. Using the IMDS, it is possible to meet the obligations
placed on automobile manufacturers, and thus on their suppliers,
by national and international standards, laws and regulations.
Note: the IMDS contains a provision for information suppliers to
report a certain percentage of the material or component content
as not specified. This allows to address CBI issues, as long as the
unnamed chemicals are not on an IMDS-specific list of substances
identified as hazardous (and thus not permitted to go
undeclared).
Third party assessment of building products for hazardous
substances. Includes database and common format.
Health Products
Declaration (HPD)
Building materials
A Health Product Declaration (HPD) is a report of the materials or
ingredients content of a building product and the associated
health effects. Defining the content of this report is the Health
Product Declaration Open Standard™.
Pharos
Building materials
Help commercial buyers evaluate product content and other
relevant data against health and environment benchmarks
Cleaning products
CleanGredients provides a Web-based database for cleaning
product formulators and suppliers to transfer chemical
information on their products. Enable transfer Information on
physical and chemical properties of ingredients to encourage
safer formulations.
Cleaning products
The US EPA’s DfE Partnership Program helps consumers,
businesses, and institutional buyers identify products that
perform well and are cost-effective, but are safer for human
health and the environment. This program promotes
sustainability by working with small businesses and consumers to
identify risks involved with chemicals used in products or
CleanGredients
Design for Environment
(DfE)
21
manufacturing processes.
Rapid Alert System for
dangerous non-food
products (RAPEX)
Consumer products
RAPEX is established as the EU rapid alert system that facilitates
the rapid exchange of information between Member States and
the Commission on measures taken to prevent or restrict the
marketing or use of products posing a serious risk to the health
and safety of consumers (with the exception of food,
pharmaceutical and medical devices). Chemical alerts make up a
significant portion of the alerts communicated over RAPEX.
Weekly alert bulletins are publically available.
JAMP offers a data format (XML schema), Tools, Management
Guidelines and global portal IT system for disclosure/transfer of
information on chemicals and chemicals in products through the
supply chain. across all sectors. The JAMP declarable substance
list is based on hazardous or highly concerned substances lists
from selected regulations and industrial lists.
Joint Article
Management
Promotion-consortium
(JAMP)
Any sector
Bomcheck
Electronics/medical
devices
Electronic system designed for use by OEMs & suppliers.
BOMCheck is designed to assist electronics component suppliers
and brands comply with regulations (e.g., EU REACH). It builds on
the Joint Industry Guide (JIG) and IPC 1752 standard.
Electronics
IPC-1752A is the materials declaration standard for companies in
the supply chain to share information on materials in products.
The standard is supported by an XML schema and a data model.
IPC 1752 Standard and
Joint Industry Guide
(JIG)
International
Electrotechnical
Commission (IEC)
Database Standard
6247416
Electrical and Electronic
products
The electrical and electronics industry and its supply chain use
material declarations to track and declare specific information
about the material composition of its products. To harmonize
requirements across the supply chain and to improve economic
efficiencies, IEC 62474 provides an International Standard for the
exchange of material composition data and provide requirements
for material declarations.
This International Standard benefits the electrotechnical industry
by establishing requirements for reporting of substances and
16
A project composed by the member of JAMP, VT 62474 (JPNC, former JGPSSI), JCIA (Japan Chemical Industry
Association), SME, etc. has been launched under the Working Group held by Japan’s METI (the Ministry of Economy,
Trade and Industry) in May 2013. The purpose is to review current standardization activities and create new scheme
for more efficient information convey across entire supply chain covering cross-industrial activities. IEC 62474 should
be essential as basis of the scheme. The scheme should be co-operated with BOMcheck, IPC-1752 and others in the
globally-connected supply chain.
22
materials, standardizing protocols, and facilitating transfer and
processing of data.
It provides data to downstream manufacturers that:
- allows them to assess products against substance restriction
compliance requirements;
- they can use in their environmentally conscious design process
and across all product life cycle phases.
Electronic Product
Environmental
Assessment Tool
(EPEAT®)
Electronic products
EPEAT® is an easy-to-use resource for purchasers, manufacturers,
resellers and others to identify environmentally preferable
electronic devices.
Consumer products
GoodGuide is a comprehensive resource for information about
the health, environmental and social performance of consumer
products and companies. Chemicals content is a significant part of
the information made available on this publicly-accessible web
resource.
Apparel &
Footwear/outdoor
industry
The OIA Chemicals Management (CM) Framework describes
chemical management actions, including chemical information
requirements. The CM Framework modules CM1.0, CM2.0, and
CM3.0 align with the CiP programme information Objectives 1
and 3 (on Know and Ensure).
Textiles
The Higg Index is a sector-wide tool developed for rating
performance over a broad range of sustainability issues. The
CMM is based on the OIA CM Framework described above. The
Higg Index targets CiP information and contains metrics designed
to measure performance in information exchange and chemicals
management.
bluesign
Textiles
Certification and labelling service provider: the bluesign system
uses “input stream management” to ensure that substances
identified as hazardous do not enter the textile production chain.
For a textile to use the bluesign label, all manufacturing processes
and chemicals involved in its creation must meet the standard.
Oeko-Tex Standard 100
Textiles
Oeko-Tex Standard 100 certification and consumer labelling are
used for textiles that have been independently shown not to
GoodGuide
Textiles Sector initiatives
Outdoor Industry
Association (OIA)
Chemicals
Management
Framework
Higg Index of the
Sustainable Apparel
Coalition, Chemicals
Management Module
(CMM)
23
contain identified harmful substances. The related STeP
(Sustainable Textile Production) verification system audits and
evaluates all relevant environmental aspects of a company’s
operations.
and SteP
see also ecolabels17
Apparel and Footwear
International RSL
Management Group
(AFIRM)
Global Organic Textiles
Standard (GOTS)
American Apparel and
Footwear Association’s
(AAFA)
Voluntary Product
Environmental Profile
(VPEP)
Textiles
AFIRM coordinates the RSL efforts of several major brands. An
RSL toolkit has been produced through AFIRM and the group
provides regular training (i.e., to suppliers) on how to implement
CiP information systems and to gather and transmit reliable data
on restricted substances.
Textiles
World's leading processing standard for textiles made from
organic fibres. The Global Organic Textile Standard provides a
means for tracking and verifying information on textiles made
from organic fibres, and includes both chemicals management
and supply chain CiP information.
AAFA makes publically available bi-annual updates to its RSL
(based globally on existing legislative restrictions for the sector).
Textiles
AAFA’s VPEP is a standardized supplier disclosure form containing
vital information on the chemical makeup of products and their
environmental properties relative to global standards and
regulations. VPEPs are used for product development, compliance
and sustainability initiatives by major companies in the chemical,
textile, apparel and footwear industries.
17
A full list of ecolabels is not appropriate here. The reader is referred to
http://www.ecolabelindex.com/ecolabels/ for an extensive ecolabel listing, including descriptions and
access links.
24