Scoping study for the application of Article 68(2) of REACH to construction articles containing CMR substances with likelihood of consumer exposure : final report.
Date: 2016-03-04
Institutions: Directorate-General for Environment
Subjects: European Chemicals Agency, building materials, carcinogenic substance, chemical product, dangerous substance, environmental law, environmental risk prevention, industrial research, public health, research and development, toxic substance

Scoping study for the 
application of Article 68(2) of 
REACH to construction articles 
containing CMR substances with 
likelihood of consumer 
exposure 

Final Report 

Written by VITO and Cide Socran 

March 2016 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Luxembourg: Publications Office of the European Union, 2016 

ISBN 978-92-79-56991-3 
doi:10.2779/451235 

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Reproduction is authorised provided the source is acknowledged. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
THE INFORMATION AND VIEWS SET OUT IN THIS STUDY ARE THOSE OF THE AUTHOR(S) AND 
DO  NOT  NECESSARILY  REFLECT  THE  OFFICIAL  OPINION  OF  THE  COMMISSION.  THE 
COMMISSION DOES NOT GUARANTEE THE ACCURACY OF THE DATA INCLUDED IN THIS STUDY. 
NEITHER THE COMMISSION NOR ANY PERSON ACTING ON THE COMMISSION’S BEHALF MAY BE 
HELD  RESPONSIBLE  FOR  THE  USE  WHICH  MAY  BE  MADE  OF  THE  INFORMATION  CONTAINED 
THEREIN. 

EUROPEAN COMMISSION 

Directorate-General for Environment 
Directorate A — Green Economy 
Unit A.3— Chemicals 

B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ABSTRACT 

Construction articles may release substances that are carcinogenic, mutagenic or toxic 
for  reproduction  and  classified  Category  1A  or  1B  (CMR  1A/1B)1.  Releases  may  occur 
during installation and service life. 

Through various sources and strategies 31 CMR 1A/1B substances were identified that 
may  be  present  in  construction  articles  present  on  the  European  market.  It  was 
investigated  whether  the  presence  of  CMR  1A/1B  substances  in  construction  articles 
actually  resulted  in  releases.  For  some  substances  (e.g.  formaldehyde),  consumer 
exposure has been demonstrated (emission data, indoor air monitoring data). For other 
substances,  monitoring  data  suggest  that  they  do  not  occur  in  indoor  environments, 
and  thus  the  articles  do  not  lead  to  consumer  exposure.  However,  for  the  majority  of 
the  substances,  the  evidence  is  less  clear  and  more  monitoring  data  are  needed  to 
make a sound assessment.  

In  2015  eight  resilient  floor  coverings  and  two  wall  papers  purchased  on  the  Belgian 
retail market were tested (content, dermal exposure, and test chambers emissions) for 
the  presence  and  release  of  t  71  CMR  1A/1B  substances.  Measurements  only  showed 
low  emissions  (1-10  µg/m³)  of  formaldehyde  after  3  days  for  three  of  the  tested 
materials. No other CMR 1A/1B substances were detected in any of the 10 articles. 

1
 Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures 

1 

 
 
 
                                           
 
RÉSUMÉ 

(par  exemple, 

Les  articles  de  construction  peuvent  rejeter  des  substances  étant  cancérigènes, 
mutagéniques  ou  toxiques  pour  la  reproduction  humaine  et  sont  repris  sous  les 
Catégories  1A  ou  1B  (CMR  1A/1B)2.  Ces  émissions  peuvent  se  produire  durant 
l’installation et au cours de la durée de vie des articles de construction.  
Sur  base  de  diverses  sources  et  stratégies,  31  substances  CMR  1A/1B  ont  été 
identifiées comme étant susceptibles d’être présentes dans des articles de construction 
disponibles sur le marché européen. Il a été examiné si la présence de substances CMR 
1A/1B  dans  les  articles  de  construction  entraînait  effectivement  des  rejets.  Pour 
certaines  substances 
formaldéhyde),  une  exposition  des 
le 
consommateurs  a  été  démontrée  (données  d’émission  et  données  de  contrôle  de  l’air 
intérieur).  Pour  d’autres  substances,  les  données  de  contrôle  indiquent  qu’elles  ne 
provoquent  aucun  rejet  dans  des  environnements  intérieurs,  et  donc  que  les  articles 
n’entraînent  pas  de  risque  d’exposition  pour  les  consommateurs.  Cependant,  pour  la 
majorité des substances, les résultats sont moins évidents et davantage de données de 
contrôle sont nécessaires pour pouvoir réaliser une évaluation pertinente. 
En  2015,  huit  revêtements  de  sol  résistants  et  deux  papiers  peints  achetés  sur  le 
marché de détail belge ont été testés (test du contenu, test d’exposition cutanée et test 
des  émissions  dans  l’air  intérieur)  quant  à  la  présence  et  au  rejet  des  71  substances 
CMR 1A/1B. Les résultats ont montré uniquement de faibles émissions (1-10 µg/m³) de 
formaldéhyde  après  3  jours  pour  trois  des  matériaux  testés.  Aucune  autre  substance 
CMR 1A/1B n’a été détectée dans l’un des dix articles. 

2 Règlement (EC) No 1272/2008 relatif à la classification, à l'étiquetage et à l'emballage des substances et préparations. 

2 

 
 
                                           
 
TABLE OF CONTENTS 

Abstract 

 ______________________________________________________ 1 

Résumé 

 ______________________________________________________ 2 

Table of contents _____________________________________________________ 3 

List of Tables 

 ______________________________________________________ 6 

Glossary 

 ______________________________________________________ 8 

Executive summary ___________________________________________________ 10 

Executive summary ___________________________________________________ 17 

Chapter 1 

Introduction ______________________________________________ 25 

Chapter 2 

List of categories of construction products  ____________________________ 26 

2.1 

2.2 

Idendification of construction articles potentially leading to consumer exposure 

Task 1, Activity 1.2: Market survey of construction products 

26 

38 

Chapter 3 
legislation restricting CMR substances in construction products  _________________________ 44 

CMR substances that are likely to be present in construction articles, and Overview of 

3.1 

Activity 2.1: CMR (cat. 1A and 1B) substances present in construction articles 

44 

3.1.1 

3.1.2 

3.1.3 

Objective  __________________________________________________ 44 

Methodology and results  ________________________________________ 44 

Summary:  CMR 1A/1B substances contained in construction articles _____________ 89 

Activity 2.2: compilation of existing national, European and third countries legislation restricting 

3.2 
CMR substances in construction products 

109 

3.2.1 

3.2.2 

3.2.3 

3.2.4 

EU legislation restricting cmr substances in construction articles.  ______________ 109 

National legislations in EU Member States _____________________________ 113 

Third countries regulation CMR substances in construction articles _____________ 127 

Summary: Legislation on CMR substances in construction articles ______________ 135 

Chapter 4 
possible 

Identification of CASES FOR which consumer exposure to selected CMR substances is 
 ____________________________________________________ 137 

4.1 

4.2 

Objectives and approach 

Exposure scenarios 

4.3  Methods for assessing exposure to substances in construction articles 

137 

138 

138 

4.3.1 

4.3.2 

4.3.3 

4.3.4 

4.3.5 

ECETOC TRA METHOD  _________________________________________ 140 

ECETOC TRA dermal exposure model (consumers) ________________________ 140 

Diffusion based consumer exposure model (RIVM, 2010 and Delmaar et al., 2013)  ___ 144 

Experimental methods for assessing release to indoor air: cen/ts 16516 emission testing 149 

Dermal exposure: extraction with artificial sweat (ds/en iso 105-e04; din 54020)  ____ 151 

3 

 
4.3.6 
determined emission rates: simplifications compared to real world exposure  _____________  152 

Indoor air consumer assessment based on ECETOC, RIVM emission model or experimentally 

4.3.7 

Methods for, and examples of professional exposure to substances in construction articles _ 
  _______________________________________________________  153 

4.3.8 

Gaps in classical methods – uncovered exposure scenarios __________________  154 

4.4 

Specific studies and examples of exposure to CMR substances in construction articles 

155 

4.4.1 

4.4.2 

Exposure to CMR substances emitted to indoor air from PVC floorings and wall coverings155 

CMR substances present in surfaces from sport areas and playgrounds recycled tires  _  166 

4.5 

Likelyhood of Exposure from construction articles to CMR substances from task 2 

172 

4.5.1 
likelihood of consumer exposure, and widespread exposure in EU” ____________________  180 

Group 1: “CMR substances for which there is evidence of presence in CA and with high 

4.5.2 
Group 2: “CMR substances for which there is evidence of presence in CA and with moderate 
likelihood of consumer exposure, exposure in limited fraction of buildings in EU” ___________  180 

Group 3: substances for which there is no evidence that the substances are present in CA in 

4.5.3 
levels > 0.1 %; though these substances have been demonstrated to be released from CA (e.g. as a 
result of secondary reactions, or from impurities) _______________________________  180 

Group 4: CMR substances for which there is evidence of presence in CA available information 

4.5.4 
indicates that exposure is possible; more data needed for confirmation and to assess the extent of 
exposure  181 

4.5.5 
Group 5: CMR substances for which there is evidence of presence in CA for which no 
assessment is possible ________________________________________________  181 

4.5.6 
Group 6: CMR substances for which there is evidence of presence in ca (>0.1 %) with indirect 
evidence for low likelihood of consumer exposure. ______________________________  181 

4.5.7 
likelihood of consumer exposure  _________________________________________  182 

Group 7: CMR substances for which there is evidence of presence in CA with (very) low 

4.5.8 
CMR substances subject to authorisation and with no authorised uses relevant for 
constructon articles  _________________________________________________  183 

4.6 

Summary 

183 

Chapter 5 
products 

Laboratory experiments to determine the presence of CMR compounds in construction 
  ____________________________________________________ 185 

5.1 

5.2 

Literature review 

Laboratory experiments 

5.3  Method description content testing 

185 

185 

188 

5.3.1 

5.3.2 

5.3.3 

5.3.4 

Content screening with SE-GC-MS __________________________________  188 

Headspace screening with SE-GC-MS ________________________________  189 

Quantification with LC-MS/MS ____________________________________  190 

Migration of substances from articles to artificial sweat– Method description  ______  191 

5.4  Method description emission experiments 

192 

5.4.1 

5.4.2 

Emission test chambers ________________________________________  193 

Analytical methods ___________________________________________  197 

5.5 

Results of the laboratory experiments 

198 

5.5.1 

Content screening results with GC-MS _______________________________  198 

4 

 
 
5.5.2 

5.5.3 

5.5.4 

5.5.5 

5.5.6 

Content headspace screening results with GC-MS ________________________ 198 

Content results (quantitative) with LC-MS/MS  __________________________ 199 

Content results of the migration from samples to artificial sweat  ______________ 200 

Results of the emission screening experiments __________________________ 200 

Results of the horizontal reference emission experiments ___________________ 201 

5.6 

Conclusion 

205 

Chapter 6 

Conclusion ______________________________________________ 207 

References 

Annex 1 - List of non-harmonized classified CMR substances (1A/1B) used in construction articles 

Annex 2 – Market survey on construction articles (contains confidential information and may not be 
distributed) 

Annex 3: Criteria for likelihood of exposure to substances present in construction articles 

Annex 4 - Chromatograms obtained with the horizontal emission test reference method 

211 

214 

218 

219 

229 

5 

 
 
LIST OF TABLES 

Table 1: Starting list of product groups, based on mandates from the European Commission to CEN/CENELEC  __ 29 

Table 2: Starting list of product groups, based on scope of CEN/TCs _____________________________ 31 

Table 3: Starting list of relevant ETAGs/EADs  ___________________________________________ 33 

Table 4: Product category prioritization table ___________________________________________ 35 

Table 5: List of product categories for the market study  ____________________________________ 37 

Table 6: Main findings of the market analysis, and forecast of a near-future evolution  _________________ 40 

Table 7: List of CMR 1A/1B substances released from at least one building article in the BUMA database ______ 48 

Table 8: Identification and classification of CMR 1A/1B substances in construction articles based on screening of SVHC 
notification dossiers available from the website of ECHA (consulted during April-June 2015) __________ 54 

Table 9: REACH registered substances with SU19, at least one of the following ERCs: ERC3, ERC5, ERC6d, ERC10a, 

ERC10b or ERC11b, and CMR 1A or 1B classification in the C&L inventory (Source: ECHA dissemination website34, 
consulted in April-June 2015). Harm=harmonised classification; nHarm=non-harmonised classification. ___ 69 

Table 10: Results of responses to Article 33 requests sent to suppliers of construction articles  ____________ 73 

Table 11: Restrictions on use of CMR 1A/1B substances in construction articles under REACH (retrieved from Annex 

XVII) _________________________________________________________________ 77 

Table 12: CMR 1A/1B substances on the Authorization list, and the sunset date  _____________________ 79 

Table 13: List of substances with granted authorizations, and identification of relevance of these uses in the domain of 
manufacturing of construction article use (authorized use granted to at least one producer) __________ 80 

Table 14: CMR 1A/1B substances with an identified use in the construction sector (retrieved from EU RARs)  ___ 83 

Table 15: CMR 1A/1B substances identified by KEMI (2015) and in other sources in this project, as substances being 

present in building products __________________________________________________ 88 

Table 16: CMR 1A/1B substances identified by KEMI (2015) but not by other sources in this project, as substances 

being present in building products  ______________________________________________ 89 

Table 17: List of CMR 1A/1B substances contained in construction articles (compilation from different sources). 

Substances present in the authorization list (Annex XIV of REACH) are marked in bold & underlined  _____ 92 

Table 18: EU Regulations and Directives restricting CMR substances (1A/1B) in construction products  ______ 110 

Table 19: National legislations in EU Member States restricting CMR substances (1A/1B) in construction products113 

Table 20: Overview of countries for which national legislation specifically addressing CMR substances in construction 
products is lacking  _______________________________________________________ 119 

Table 21: An overview of regulated carcinogenic VOCs (categories 1A/1B according to the prEN 16516 emission testing 
protocol)  _____________________________________________________________ 124 

Table 22: An overview of regulated carcinogenic SVOCs (categories 1A/1B) _______________________ 126 

Table 23: Japanese restrictions for interior finishing materials ________________________________ 129 

Table 24: Categories of formaldehyde emitting building materials _____________________________ 130 

Table 25: Key differences between EU-REACH, K-REACH and China REACH ________________________ 135 

Table 26: Overview of existing methods for assessing exposure to substances present in (construction) articles  139 

Table 27: Algorithm for dermal consumer exposure to products and articles (ECETOC TRA v3)  ___________ 141 

Table 28: ECETOC TRA values for the consumer dermal exposure model for PVC flooring and wall paper _____ 142 

Table 29: Algorithm for dermal consumer exposure to products and articles (ECETOC TRA v3)  ___________ 143 

6 

 
Table 30: Fraction released to air according to vapour pressure bands in ECETOC TRA (source: ECETOC, 2009)  _ 143 

Table 31: ECETOC TRA values for the consumer inhalation exposure model for PVC flooring and wall paper ___ 144 

Table 32: Key technical aspects of CEN/TS 16516 (2013)  ___________________________________ 150 

Table 33: Emission strengths of CMR 1A/1B substances released from resilient flooring materials (e.g. PVC, vinyl and 

linoleum), and wall covering (wall paper) in the BUMA database. Calculated reference room concentration at 28 
days reflects the estimated indoor air concentration for the consumer scenario ‘article service lifetime exposure’. 
Calculated reference room concentration at3 days reflects the estimated indoor air concentration for the 
professional and DIY exposure scenario ‘exposure during installation of materials’*  ______________ 157 

Table 34: Measured concentration of phthalates (CMR substances) in indoor air (gaseous phase and suspended dust) 
in indoor environments in the EU ______________________________________________ 163 

Table 35: Phthalate concentrations in indoor settled dust in the EU ____________________________ 165 

Table 36: Estimation of PAH exposure of consumers from rubber granulates using an approach which considered 

experimentally determined migration (source: BfR, 2010) _______________________________ 169 

Table 37: Estimation of PAH exposure of consumers from rubber granulates using the ECETOC TRA approach (source: 
BfR, 2010) _____________________________________________________________ 169 

Table 38: Allocation of substance/construction article pairs into groups of likelihood of exposure to CMR substances in 
construction articles (identification of substance and construction articles: see Chapter 3.  __________ 175 

Table 39: Sample description ____________________________________________________ 185 

Table 40: Overview CMR compounds _______________________________________________ 186 

Table 41: Calibration standards used in the LC-MS/MS content analysis __________________________ 190 

Table 42: Pieces of the samples used for extraction with artificial sweat  _________________________ 191 

Table 43: Overview of the emission test chamber conditions  ________________________________ 194 

Table 44: Overview of the emission test chamber sampling sorbents and corresponding analytical method ___ 196 

Table 45: Retention times of the phthalate standard mix ___________________________________ 200 

Table 46: Overview of the TD-GC-MS results on Tenax after 28 days (in µg/m³) _____________________ 203 

Table 47: Overview of TVOC and TSVOC after 3 and 28 days (in µg/m³) __________________________ 205 

Table 48: Overview of formaldehyde concentrations after 3 and 28 days (in µg/m³) __________________ 205 

7 

 
GLOSSARY 

AgBB 

AREC 

BBP 

BUMA 

BW 

CA 

CAB 

CARB 

CCA 

CEN 

CLP 

CMR 

CP-DS 

CPR 

CPs 

DBP 

DEHP 

DBP 

DIBP 

DIY 

EADs 

ECHA 

EEA 

EGDS 

EOTA 

EPDM 

EPS 

ERCs 

ETAGs 

ETAs 

EV 

HWPW 

KEMI 

German Committee for Health-Related Evaluation of Building Products  

Act on the Registration and Evaluation of Chemicals (Korea) 

Benzyl butyl phthalate 

Prioritization of BUilding MAterials as indoor pollution sources  

Body Weight 

Cellulose Acetate 

Cellulose Acetate Butyrate 

California Air Resources Board 

Chemicals Control Act 

European Committee for Standardization 

Classification, Labelling and Packaging of substances and mixtures (Regulation (EC) 
No 1272/2008) 
Carcinogenic, Mutagenic, Reprotoxic 

Database  on  European  and  national  legislation  on  substances  in  construction 
products 
Construction Products Regulation (EU) No 305/2011 

Construction Products  

Dibutyl phthalate 

Bis(2-ethylhexyl) phthalate 

Dibutyl phthalate 

Diisobutyl phthalate 

Do It Yourself 

European Assessment Documents 

European Chemicals Agency 

European Environment Agency  

Expert Group on Dangerous Substances 

European Organisation for Technical Assessment 

ethylene propylene diene monomer (M-class) 

Expanded Polystyrene 

Environmental Release Categories 

European Technical Approval Guidelines  

European Technical Assessments 

Exfoliated Vermiculite 

Hardwood Plywood  

Swedish Chemical Agency 

K-REACH 

Korean REACH, see AREC 

Lowest Concentrations of Interest 

low-density polyethylene 

Manufacturers and importers 

4,4'

‐D ia m in od ip h e n y lm eth a n e

Medium Density Fiberboard 

Melamine-Formaldehyde 

1-Methyl-2-pyrrolidone 

Only Representative 

Oriented Strand Board 

LCIs 

LDPE 

M/I’s 

MDA 

MDF 

MF 

NMP 

OR 

OSB 

8 

 
 
 
 
PACs 

PB 

Priority Assessment Chemicals 

Particle Board 

PE /LDPE 

Polyethylene / Low Density Polyethylene 

PIR 

Polyisocyanurate 

Polypropylene 
Draft  standard:  Construction  products  -  Assessment  of  release  of  dangerous 
substances - Determination of emissions into indoor air 
Polyurethane foam 

Polymers or copolymers of Vinyl Chloride 

Risk Assessment Reports 

Registration, Evaluation, Authorisation and Restriction of Chemicals (Regulation (EC) 
No 1907/2006) 
Substances of Very High Concern 

Semi Volative Organic Compounds 

Technical Assessment Bodies 

Technical Committees  

Toxic Chemical Control Act 

Technical Specification 

Urea-Formaldehyde 

Unsaturated Polyesters 

Volatile Organic Compounds 

Extruded Polystyrene Foam 

PP 
prEN 16516 

PUR 

PVC 

RAR 

REACH 

SVHCs 

SVOCs 

TABs 

TCs 

TCCA 

TS 

UF 

UP 

VOC 

XPS 

9 

 
 
 
 
EXECUTIVE SUMMARY 

Construction materials for buildings may release substances to the indoor air, which could have 
an  impact  on  the  health  of  residents  or  visitors  to  the  building.  In  addition,  also  dermal 
exposure  during  installation  of  construction  products  and  during  service  life  needs 
consideration.  The  widespread  use  of  construction  products  creates  large  opportunities  for  a 
high  number  of  consumers  to  be  exposed  to  substances  with  chronic  toxicity  properties  that 
are released.  

Hazardous  substances  can  i.a.  be  managed  by  restriction  of  these  substances  individually,  or 
when  used  in  mixtures  or  articles,  in  Annex  XVII  of  the  REACH  Regulation  (EU)  1907/20063. 
The  normal  procedure  to  set  restrictions  under  REACH  involves  a  detailed  assessment  of  the 
risks  posed  by  specific  uses  of  a  substance,  and  the  socio-economic  impacts  of  a  possible 
restriction. In addition, REACH, through Art. 68(2), offers a simplified restriction procedure, as 
regards  consumer  uses,  for  substances  classified  as  carcinogenic,  mutagenic  or  toxic  for 
reproduction  (CMR  Cat.  1A/1B  (hereafter  called  CMR  1A/1B),  according  to  the  Regulation  on 
Classification, Labelling and Packaging (CLP)4). This project studies the possible application of 
Article  68(2)  to  CMR  substances  in  construction  articles,  by  aiming  to  identify  CMR  1A/1B 
substances used in such articles and having the potential to lead to exposure of consumers. 

For  substances  and  mixtures,  merely  the  presence  of  a  CMR  1A/1B  substance  is  enough  to 
assume  exposure.  However,  in  the  case  of  articles,  such  as  construction  articles,  it  is  the 
release  rather  than  the  presence  of  CMR  1A/1B  substances  in  the  article  that  plays  an 
important  role  in  the  assessment  of  potential  exposure.  Releases  from  construction  products 
may occur during the construction and fitting of buildings and/or during the service life of the 
buildings.  

The project consisted of the following tasks:  

• 

Identification  of  different  groups  of    construction  products,  the  estimation  of  the    market 
volume and initial assessment of their relevance for human exposure (Task 1); 

•  Compilation of a list of CMR 1A/1B substances that are likely to be present in construction 
products,  and  exploration  of  the  legislation  restricting  CMR  1A/1B  substances  in 
construction products (Task 2); 
Identification  of  cases  for  which  consumer  exposure  to  selected  CMR  1A/1B  substances 
from  construction  products  is  possible,  and  assessment  of  the  likelihood  of  consumer 
exposure (Task 3); and, 

• 

•  Perform  analyses  to  confirm  the  presence  and  release  of  CMR  1A/1B  substances  in 

construction products (Task 4). 

In  Task  1  a  list  of  construction  products  was  compiled  from  which  consumer  exposure 
(inhalation  and  dermal)  to  their  chemical  content  is  possible.  Consumer  exposure  includes 
exposure during the Do-it-Yourself (DIY) installation and during service life. 

For  construction  products  the  definition  from  the  Construction  Products  Regulation  (EU)  No 
305/2011 (CPR) is applied: any product or kit which is produced and placed on the market for 
incorporation  in  a  permanent  manner  in  construction  works  or  parts  thereof  and  the 
performance of which has an effect on the performance of the construction works with respect 
to the basic requirements for construction works (Article 2.1). 

For  the  purpose  of  this  study  the  diverse  range  of  construction  products  was  limited  to 
products  for  which  harmonized  technical  specifications  are  established  (Article  2.10  of  the 
CPR); they are covering most of the construction products available on the market. 

3 Regulation (EC) No 1907/2006 on Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) 

4 Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures 

10 

 
                                           
 
In  addition,  the  final  compiled  list  was  restricted  to  construction  products  falling  under  the 
definition of articles according to Article 3.3 of REACH. 

To  allow  a  further  refinement  and  limiting  the  large  scope  of  possible  relevant  construction 
products  for  consumer  exposure  a  prioritization  was  made  based  on  expert  judgment  taking 
into  account  the  following  four  factors:  direct  contact  with  indoor  air;  likely  dermal  contact 
during use phase; DIY likely exposure (taking into account the exposure time, exposed surface 
and  manipulations  involvement);  and  its  coverage  by  content/emissions  schemes.  Based  on 
the  prioritization  exercise,  a  market  study  was  performed  to  evaluate  the  quantities 
produced/sold  on  the  European  market,  which  encompassed  the  following  product  categories 
(which were further broken down in subcategories):   

Doors  and  windows,  ceramic  based  products,  thermal  insulation  products,  wall  coverings, 
concrete  and  cement,  wood-based  panels,  masonry,  flooring,  surfaces  for  sport  areas, 
gypsum and gypsum based products,  suspended ceilings, stretched ceilings, terraces, and 
playgrounds. 

For  each  product  category  and  subcategory,  data  on  sales’  volumes  were  gathered  from  a 
review of public documents and websites and a survey of reference stakeholders. Data predict 
an  upward  evolution  in  the  near  future  in  the  sales’  volumes  of  doors  and  windows,  ceramic 
tiles, thermal insulation products, wood based panels, flooring (except cork), and wood/plastic 
composite terraces.  Even though the collected information was not homogeneous, the  survey 
provided  a  good  estimation  of  the  volumes  bought  and  installed  in  Europe.  The  information 
collated  was  often  more  comprehensive  for  construction  products  dominated  by  large 
companies (e.g. for gypsum, cement and concrete).  For the other construction products (e.g. 
for floorings, doors and windows) it was necessary to adopt a multiple cross checking approach 
to estimate market volumes.  Due to the non-accessibility or non-existence of data, the sales’ 
volumes of the following construction products could not be properly assessed: wall coverings, 
stretched ceilings and playgrounds. 

In  Task  2  an  overall  list  of  CMR  1A/1B  substances  that  are  contained  in  construction  articles 
was  compiled  based  on  information  gathered  via  various  sources  and  strategies,  and  where 
possible  to  identify  the  technical  function  of  these  CMR  1A/1B  substances  in  these  articles. 
First of all a list of substances for which there is evidence that they are present in or released 
from  construction  products  was  compiled,  based  on  the  consultation  of  the  following 
complementary sources: 

•  Construction  materials  emission  database:  list  of  volatile  organic  substances  (VOC) 
substances  released  from  construction  articles  into  indoor  air  based  on  past  research 
projects.   

•  Construction materials health based evaluation schemes  for building materials: the 
list  of  the  EU  working  group  deriving  and  recommending  EU-wide  harmonised  health-
based  reference  values  for  the  assessment  of  product  emissions,  based  on  the  so-called 
‘Lowest Concentration of Interest’ (LCI) concept, and the list of the German Committee for 
Health-Related Evaluation of Building Products (AgBB list). 

•  List of CMR 1A/1B  substances in construction  articles retrieved  from  article notification 

dossiers available at the website of ECHA. 

•  Search  in  REACH  registration  dossiers  for  substances  with  Use  Sector  19  (Building  and 

construction work), and additional relevant environmental release categories 

•  REACH Article 33 Requests sent to manufacturers and resellers of construction products 
regarding the presence of substances of very high concern (SVHC) in concentrations > 0.1 
%.  

Identification  of  CMR  1A/1B  substances  in  construction  articles  in  restriction  dossiers, 
retrieved from the website of ECHA. 

Identification  of  authorized  use  of  Annex  XIV  CMR  1A/1B  substances  in  construction 
articles, retrieved from the website of ECHA. 

• 

• 

11 

 
• 

Information  retrieved  from  EU  Risk  Assessment  Reports  of  CMR  1A/1B  substances 
delivered under the Existing Substance Regulation (EEC) No. 793/93. 

Subsequently  the  substances  gathered  from  the  abovementioned  sources  were  screened  for 
harmonised CMR 1A/1B classification in the EU Classification & Labelling Inventory available on 
ECHA’s  website5.  As  a  result,  we  identified  31  CMR  1A/1B  substances,  for  which  we  have 
indications  the  substances  in  present  in  at  least  one  type  of  construction  article,  or  that  the 
substances is released from  at least one type of a construction article. 

Information  regarding  the  content  and  technical  function  of  these  substances  was  collected. 
The widely use of these CMR 1A/1B substances in the construction articles was assessed based 
on the number of cases in which these substances were detected in the consulted sources and 
on  the  manufactured/imported  volume  tonnage  bands  indicated  in  the  registration  dossiers. 
The  latter  provided  an  estimate  of  how  widespread  the  use  of  the  substance  in  general  is. 
However,  it  cannot  be  derived  from  this  which  fraction  of  the  use  specifically  concerns 
construction products. 

In  addition  to  the  information  per  substance,  we  provide  the  following  general  observations 
and considerations:  
1.  Only  the  BUMA  project 6  provides  information  concerning  emissions  from  construction 
articles.  The  other  information  sources  only  provide  information  on  the  content  and/or 
use of substances in the construction articles. It is not always clear whether a substance 
used  for  the  production  of  articles  is  still  present  in  the  final  article.  Also  the  opposite 
might occur: some CMR 1A/1B substances are not used for the production of construction 
articles,  and  are  therefore  assumed  not  to  be  initially  present  in  the  construction  article; 
however,  such  substances  have  been  demonstrated  to  be  released  from  articles  in  test 
chambers.  The  release  might  be  a  result  of  degradation  or  secondary  reactions  (e.g. 
degradation of phthalates in PVC flooring. 

2.  The  high  manufactured/imported  tonnage  bands  of  the  registration  dossiers  and  the 
multiple information sources confirm the presence of the CMR 1A/1B  substances in many 
different  construction articles. The  most widespread  CMR 1A/1B substances identified are 
formaldehyde,  bis(2-ethylhexyl)phthalate  (DEHP),  boric  acid,  disodium  tetraborate 
anhydrous, and acrylonitrile. 

3.  CMR  1A/1B  substances  are  identified  as  being  used  in  a  broad  range  of  construction 
product categories and specific uses: doors and windows, ceramic based products, thermal 
insulation  materials,  wall  covering,  concrete,  wood  based  panels,  PVC  flooring,  and 
gypsum  boards.  For  the  categories  of  “surfaces  for  sport  areas”,  “terraces”  and 
“playgrounds”, no use of CMR 1A/1B substances have been identified; however the use of 
recycled  rubber  tyres  for  synthetic  turf  may  result  in  the  presence  of  CMR  1A/1B 
substances in for example “surfaces for sport areas”. 

4.  For  some  substances  (chloroprene,  dipentylphthalate,  dimethylformamide  (DMF)  and 
benzene),  the  only  significant  information  source  was  the  BUMA  database.  Given  the 
absence  of  REACH  registrations  and  notifications  for  these  substances  in  construction 
articles,  it  can  be  assumed  that  these  substances  are  present  as  an  impurity.  Moreover, 
for  dimethylformamide,  chloroprene  and  dipentylphthalate,  the  release  from  construction 
articles was detected in only 1, 2 and 3 construction articles respectively out of the entire 
BUMA  construction  database  (347  entries  for  articles  and  products);  it  can  therefore  be 
assumed  that  their  presence  only  occurs  in  a  small  minority  of  this  type  of  construction 
articles. 

5 http://echa.europa.eu/information-on-chemicals/cl-inventory-database/ 

6 http://mech.uowm.gr/bumaproject/ 

12 

 
 
                                           
 
5.  For  several  substances  from  the  Authorisation  list  (Annex  XIV),  REACH  notifications  and 
registrations  of  use  in  construction  articles  were  found,  while  no  authorizations  for  a 
specific  use  in  construction  articles  are  in  place  (e.g.  trichloroethylene,  dibutylphthalate, 
lead  chromate,  tris(2-chloroethyl)phosphate,  benzylbutylphthalate).    It  is  expected  that 
the  use  of  these  substances  in  construction  products  will  disappear  in  EU  manufactured 
articles  from  the  “sunset  date”  onwards.  ECHA  can  use  restrictions  to  deal  with imported 
articles (Article 69.2).  

6.  The  response  rate  to  Article  33  Requests  sent  to  162  manufacturers  and  resellers  of 
construction  articles  on  the  Belgian  market  was  rather  poor  (23  %)  and  did not  result in 
the identification of additional CMR 1A/1B substances.   

7.  For a set of other substances than the 31 identified ones (namely: 1-methyl-2-pyrrolidone 
(NMP);  benzyl  butyl  phthalate  (BBP);    zirconia  aluminosilicate;  2,4-dinitrotoluene; 
imidazolidine-2-thione; diarsenic pentaoxide; 2-ethoxyethyl acetate; 1,2-dimethoxyethane  
and trichloroethylene) it is unlikely but cannot be excluded that the substances are used in 
construction articles.  For these substances, no use in construction articles mentioned was 
mentioned in the notification dossiers.  In the section regarding the information contained 
in  registration  dossiers  (“Registration  Information  on  identified  uses  related  to  article 
categories”),  the  following  sentence  was  added  in  the  relevant  dossiers:  “No  registration 
information  available  relating  to  the  use  of  the  substance  in  articles.  The  reason  may  be 
that  the  substance  is  not  registered,  that  no  Article  Category  is  provided  in  the 
registrations  for  the  substance  or  that  the  identified  uses  of  the  registrations  have  been 
claimed confidential”. 

Based  on  this  statement,  it  cannot  be  excluded  that  these  10  substances  are  used  in 
construction articles.  However, the evidence is very weak, and it is based on the available 
information  not  possible  to  verify  their  presence  in  construction  articles,  and,  if  used  in 
construction  articles,  it  cannot  be  identified  in  which  types  of  construction  articles  these 
substances are used. Therefore, these substances are not taken forward to the overall list 
of  CMRs  present  in  construction  articles  unless  there  is  information  regarding  presence 
from other sources in this task, or there is information from exposure data available such 
as for trichloroethylene, BBP, and 1-methyl-2-pyrrolidone (NMP). 

In the second part of Task 2, an overview was made of existing national, European and third 
countries’ legislation restricting CMR 1A/1B substances in construction articles.  

Within  the  EU,  the  REACH  regulation  is  the  most  relevant  law  concerning  CMR  1A/1B 
substances in construction articles. Some specific CMR 1A/1B substance uses are addressed by 
authorisations  and  restrictions,  but  the  use  of  CMR  1A/1B  in  construction  articles  is  not 
generally prohibited. In addition, producers and importers of substances on the Candidate list 
of Substances of Very High Concern (SVHC), amongst which several are CMR 1A/1B, have the 
duty to notify this to ECHA, if the article concentration is above 0.1%. 

Bans  and  restrictions  of  CMR  1A/1B  substances  under  REACH,  and  the  duty  to  notify  ECHA 
about the use of SVHC in construction articles are based on “presence or content” criteria, 
and not on release criteria.    

The  majority  of  EU  Member  States  rely  evidently  heavily  on  EU  legislation  concerning  CMR 
substances in construction articles (via REACH and the CPR), and have no or limited additional 
national  legislation  concerning  CMR  substances  in  articles.  However,  some  Member  States 
have  additional  national  legislation  concerning  the  aspect  of  CMR  1A/1B  in  construction 
articles.  Some  national  legislations  apply  for  specific  groups  of  construction  articles  (e.g. 
Belgium:  flooring  materials;  Germany:  flooring  materials  and  decorative  wall  paper),  while 
other  national  legislations  apply  for  a  broad  group  of  construction  articles  (e.g.  Lithuania:  All 
polymer  construction  products  and  polymer  furniture  for  installation  indoors;  Poland: 
Construction  materials,  facilities  and  components  of  furniture  used  in  rooms  intended  for 
human residence).  

13 

 
 
These  national  legislations  are  in  general  release-oriented.  For  example,  the  German, 
Belgian  and  Lithuanian  legislation  limits  the  release  of  CMR  1A/1B  substances  covered  under 
the prEN 16516 emission testing protocol 7 to maximum model room levels of 1 µg/m³ after 28 
days of emission testing.  

In  addition,  some  countries  have  specific  legislation  for  specific  CMR  substances  in  specific 
applications.  For  example,  Denmark  restricts  the  use  of  Cd  in  construction  articles  (max. 
0.0075% Cd) and the use of formaldehyde in wood based panels. Interestingly, Denmark gives 
priority to release criteria for formaldehyde in wood based panels (max. 0.15 mg/m³ in a test 
room).  However,  if  a  company  is  unable  to  document  the  fulfilment  of  this  requirement,  it  is 
permitted to use panels with a maximum of 25 mg free formaldehyde per 100 g dry matter in 
the panel (i.e. content criteria).  

In  France  it  is  forbidden  to  use  the  following  CMR  1A/1B  substances  in  the  manufacturing  of 
construction and decoration products: trichlorethylene, benzene, DEHP and dibutylphthalate.  

Outside the EU, regulations for construction articles are mostly focussed on formaldehyde such 
as  the  Californian  Airborne  Toxic  Control  Measure  ATCM  93120  and  the  Japanese  Building 
Standard Law Enforcement Order and Notifications. 

In  Task  3  it  was  assessed  for  the  CMR  substances  identified  under  task  2,  whether  their 
presence  in  construction  articles  effectively  provoke  exposure;  hereby  various  use 
scenarios for the consumer and the professional were investigated.  

In  addition,  information  was  gathered  on  methods  for  assessing  exposure  to  CMR  1A/1B 
substances in construction articles. An overview is provided which indicates which information 
is readily available to assess exposure, and which information is currently lacking and needs be 
investigated  (case  by  case)  to  quantify  the  exposure  to  CMR  substances  in  construction 
articles.  

Information gathered during Task 3 confirmed the presence of several CMR 1A/1B substances 
in  several  construction  articles.    Literature  reporting  on  experimental data  demonstrated  that 
some  CMR  1A/1B  substances  are  effectively  released  to  the  indoor  and/or  are  potentially 
released to the skin upon dermal contact.  

Literature  reporting  on  monitoring  data  for  formaldehyde,  benzene  and  phthalates  in 
residential premises confirm that these CMR 1A/1B substances are widely present in the indoor 
environment.  However, other sources (e.g. outdoor air, cleaning products, etc.) in addition to 
construction articles are likely to also contribute to these indoor levels, at least for benzene.   

For  other  CMR  1A/1B  substances,  (e.g.  tris(2-chloroethyl)phosphate  (TCEP)  and  N-methyl-2-
pyrrolidone)  monitoring  data  in  indoor  dust  in  various  dwellings  have  shown  that  these 
substances occur only in a small minority of buildings in the EU. 

Methods to assess exposure to CMR 1A/1B substances for the scenario ‘consumer exposure via 
indoor air during article service lifetime’ are well established (CEN/TS 16516 emission test) and 
embedded  in  regulatory  frameworks  (e.g.  CPR).  These  results  from  experimentally  measured 
emission  rates  have  been  demonstrated  to  match  with  indoor  air  levels  in  real  indoor 
environments (e.g. Missia et al., 2010).   

However,  methods  for  assessing  the  consumer  exposure  scenario  of  dermal  exposure  upon 
skin contact with construction articles are more prone to uncertainties. These uncertainties are 
due to the defaults taken, and the model approach, in particular the default for layer thickness 
and the extrapolation of released amounts to the contact area. In addition, the behaviour data 
included  in  the  models  may  be  criticised  as  too  conservative  and  unrealistic.  In  addition, 
experimentally  determined  migration  data  to  skin  is  prone  to  uncertainties  concerning  the 

7  DRAFT  prEN  16516,  May  2015,  Construction  products  -  Assessment  of  release  of  dangerous  substances  - 
Determination of emissions into indoor air 

14 

 
                                           
 
relevant physico-chemical composition of the extraction media, and the lack of accounting for 
transfer factors. These limitations render it difficult to generate sound exposure estimates for 
dermal  exposure  to  substances  in  construction  articles.  In  contrast  to  indoor  air  exposure, 
dermal  exposure  to  substances  in  construction  articles  is  not  (yet)  embedded  in  an  official 
standard.  

Besides the two most evident consumer exposure scenarios (direct releases to the indoor air,  
and  direct  dermal  contact),  indirect  exposure  scenarios  for  semi-VOC  substances  in 
construction articles have been described in the literature as well: for example, release to the 
dust phase and surfaces and subsequently oral and dermal contact.  For example, monitoring 
data of semi-VOC CMR 1A/1B substances in dust (e.g. DEHP, TCEP) demonstrate that this is a 
likely  pathway  for  exposure,  however,  no  widely  accepted  tools  to  assess  this  exposure  have 
been agreed upon yet (discussions are ongoing at OECD level).   

Data  on  DIY  exposure  and  professional  exposure  scenarios  are  more  scarce  compared  to 
article life service exposure. Professional exposure to substances in construction articles (e.g. 
installers  of  PVC  flooring)  is  not  included  in  the  workers’  exposure  tools  referenced  in  the 
REACH  Guidance.    Exposures  for  this  occupational  group  is  believed  to  be  lower  than  for 
workers  in  contact  with  industrial  processes  where  contact  with  these  substances  during 
manufacture and production is likely. 

In  order  to  assess  the  likelihood  of  exposure  to  CMR  1A/1B  substances  arising  from 
construction articles, 5 criteria have been applied on each of the identified cases from task 2, 
namely  1)  presence  of  CMR  1A/1B  substances  in  construction  articles;    2)  emission  of  CMR 
1A/1B substances in construction articles (from monitoring programs); 3) estimated exposure 
(modelling),  taking 
indoor 
environments;  4):  measured  indoor  exposure  (monitoring  Indoor  Air  Quality  (IAQ)  in 
buildings);  5)  source  apportioning  support  that  construction  articles  are  the  main  source  of 
indoor  exposure.  Moving  from  criterion  1  to  5  gives  increasing  evidence  for  exposure  to  CMR 
1A/1B substances in relation to the presence of construction articles.  

into  account  release,  article 

loading,  exchange  rate 

in 

Based  on  the  scoring  for  these  5  criteria,  the  different  pairs  of  construction  articles  (CA)  and 
CMR  substances  were  organized  into  groups.  Pairs  of  CA/CMR  substances  belonging  to  the 
same  group  have  a  similar  likelihood  of  consumer  exposure  to  CMR  substances  present  in 
construction articles.  

As  a  result,  there  was  a  wide  range  in  evidence  for  exposure  to  CMR  1A/1B  substances  in 
relation  to  presence  of  construction  articles:  on  the  one  hand,  for  some  substances  (e.g. 
formaldehyde),  consumer  exposure  has  been  demonstrated  in  several  ways  (emission  data, 
monitoring  data  in  indoor  air),  the  exposure  is  ubiquitous  in  the  EU  and  indoor  construction 
articles have been demonstrated as a significant source of indoor exposure. On the other hand, 
for other cases, monitoring data below detection limits in all monitored premises suggest that 
the  substance  does  not  occur  in  indoor  environments,  and  thus  the  possible  presence  of  the 
substance  in  construction  articles  does  not  lead  to  consumer  exposure  (e.g.  acrylonitrile). 
However,  for  the  majority  of  the  substances,  the  evidence  is  less  clear.  In  some  cases, 
indications are available that exposure origination from construction articles is probably minor; 
in  other  cases,  no  assessment  could  be  made  based  on  the  available  information,  thus  more 
monitoring data are needed to make a sound assessment possible.  

In  Task  4  analytical  testing  was  performed  on  construction  articles  where  CMR  data  are  not 
readily  available.  The  testing  was  performed  on  8  resilient  PVC  floorcovering  materials  and  2 
wall papers purchased from the  Belgian retail market in 2015. The analytical tests performed 
included content testing, dermal exposure testing, and indoor air emission testing.  

The list of target CMR 1A/1B substances consisted of 71 volatile, semi-volatile and very volatile 
substances.  

For  the  content  testing,  ethyl  acetate  was  used  as  an  extraction  solvent  for  screening,  and 
methanol  for  quantification.  The  10  samples  were  first  screened  for  CMR  1A/1B  content  with 
(headspace) GC-MS techniques. Quantitative content measurements were performed with LC-
MS/MS. It was clearly shown that none of the samples contained CMR 1A/1B substances. The 
content  approach  was  complemented  with  dermal  exposure  experiments.  Transfer  combined 

15 

 
with  migration  at  long  term  dermal  exposure  was  simulated  by  a  one
step  extraction  at 
shaking conditions at pH 5.5 and 37°C with artificial sweat prepared according to DIN EN ISO 
105
E04  (ISO,  2013).  No  CMR  1A/1B  substances  migrated  from  the  articles  to  the  artificial 
sweat.  
‐

The  potential  release  to  indoor  air  of  CMR  substances  from  the  10  samples  was  first 
investigated  by  means  of  the  standard  microchamber  screening  technique.  Quantitative 
emission  measurements  were  performed  with  the  new  European  horizontal  emission  test 
standard (prEn 16516,  2015) in test chambers of 110l, 500l and the complementary test cell 
method (FLEC). The air sampling times were selected to reflect the consumer exposure during 
the  installation  or  lifetime  of  the  article.  Sampling  after  3  days  was  done  to  assess  the 
exposure during installation. Sampling after 28 days was done to assess the lifetime exposure 
in accordance with the JRC report N°27 (2012) “Harmonisation framework for indoor products 
labelling schemes in the EU”. 

‐

Sampling was executed on 6 types of sorbents to adequately capture the whole range of CMR 
substances. The results only showed low emissions (1-10 µg/m³) of formaldehyde after 3 days 
for  three  (2  floor  coverings  and  1  wall  covering)  of  the  10  tested  materials.  No  other  CMR 
1A/1B substances were detected in any of the 10 articles. 

16 

 
 
 
EXECUTIVE SUMMARY 

Les  matériaux  de  construction  destinés  aux  bâtiments  peuvent  rejeter  des  substances  dans 
l’air  intérieur,  ce  qui  pourrait  avoir  un  impact  sur  la  santé  des  résidents  ou  visiteurs  de  ces 
bâtiments.  De  plus,  une  exposition  cutanée  au  cours  de  l’installation  des  produits  de 
construction  et  durant  la  durée  de  vie  de  ces  derniers  doit  également  être  prise  en 
considération.  L’utilisation  généralisée  des  produits  de  construction  implique  de  nombreuses 
occasions, pour un nombre élevé de consommateurs, d’être exposés à des substances libérant 
des propriétés toxiques chroniques. 
Les  substances  dangereuses  peuvent  être  réglementées,  entres  autres,  via  une  restriction  de 
ces  substances,  telles  quelles  ou  lorsqu’elles  sont  utilisées  dans  des  préparations  ou  articles, 
selon  l’Annexe  XVII  de  la  réglementation  REACH  (UE)  1907/20068.  La  procédure  habituelle 
quant  à  l’établissement  de  restrictions  dans  le  règlement  REACH  implique  une  évaluation 
approfondie  des  risques  engendrés  par  des  utilisations  spécifiques  d’une  substance,  ainsi  que 
des  impacts  socio-économiques  d’une  éventuelle  restriction.  De  plus,  REACH,  via  l’Article 
68(2), propose une procédure de restriction simplifiée en ce qui concerne les utilisations par le 
consommateur de substances considérées comme étant cancérogènes, mutagènes ou toxiques 
pour la reproduction humaine (CMR9 Cat. 1A/1B, selon le règlement relatif à la classification, à 
l’étiquetage et à l’emballage (CLP)10). Ce projet étudie l’éventuelle application de l’Article 68(2) 
aux substances CMR dans les articles de construction, en visant à identifier les substances CMR 
l’exposition  des 
Cat.  1A/1B  utilisées  dans  de  tels  produits  et  pouvant  entraîner 
consommateurs.  
Pour les substances et les préparations, la simple présence d’une substance CMR 1A/1B suffit à 
supposer  une  exposition.  Toutefois,  dans  le  cas  des  produits,  tels  que  les  produits  de 
construction, c’est le rejet plutôt que la présence de substances CMR 1A/1B dans le produit 
qui  joue  un  rôle  prépondérant  dans  l’évaluation  de  l’éventuelle  exposition.  Les  produits  de 
construction  peuvent  rejeter  des  substances  lors  de  la  construction  et  de  l’aménagement  de 
bâtiments et/ou pendant la durée de vie des bâtiments.  
Le projet comportait les tâches suivantes :  

• 

Identification  de  différents  groupes  de  produits  de  construction,  estimation  du  volume 
de  marché  et  première  évaluation  de  leur  impact  en  termes  d’exposition  humaine 
(Tâche 1) ;   

•  Compilation d’une liste de substances CMR 1A/1B susceptibles d’être présentes dans les 
produits  de  construction,  et  exploration  de  la  législation  restreignant  les  substances 
CMR 1A/1B dans les produits de construction (Tâche 2) ; 
Identification  de  situations  où  les  consommateurs  s’exposent  potentiellement  à  des 
substances  CMR  1A/1B  sélectionnées  de  produits  de  construction,  et  évaluation  de  la 
probabilité de l’exposition des consommateurs (Tâche 3) ; et  

• 

•  Réalisation  d’analyses  afin  de  confirmer  la  présence  et  le  rejet  de  substances  CMR 

1A/1B dans les produits de construction (Tâche 4). 

Lors  de  la  Tâche  1,  une  liste  de  produits  de  construction  a  été  compilée,  pour  lesquels  il 
existait  une  exposition  (par  inhalation  et  cutanée)  potentielle  des  consommateurs  à  leurs 
composants chimiques. L’exposition des consommateurs inclut l’exposition durant l’installation 
des  produits  par  les  consommateurs  (Do-It-Yourself,  (DIY))  et  durant  la  durée  de  vie  de  ces 
produits.  

8  Règlement  (EC)  No  1907/2006  concernant  l’enregistrement,  l’évaluation,  l’autorisation  et  la  restriction  de  substances  chimiques 
(REACH).  

9 CMR : Carcinogenic, Mutagenic or Toxic for Reproduction, soit cancérogène, mutagène ou toxique pour la reproduction humaine 

10 Règlement (EC) No 1272/2008 relatif à la classification, à l’étiquetage et à l’emballage des substances et préparations. 

17 

 
                                           
 
 
En ce qui concerne les produits de construction, la définition du règlement (UE) No 305/2011 
sur les produits de construction (RPC) est d’application : tout produit ou kit fabriqué et mis sur 
le marché en vue d’être incorporé de façon durable dans des ouvrages de construction ou des 
parties d’ouvrages de construction et dont les performances influent sur celles des ouvrages de 
construction  en  ce  qui  concerne  les  exigences  fondamentales  applicables  auxdits  ouvrages 
(Article 2.1). 
Dans  le  cadre  de  cette  étude,  les  différentes  gammes  de  produits  de  construction  ont  été 
limitées  aux  produits  pour  lesquels  des  spécifications  techniques  harmonisées  sont  établies 
(Article  2.10  du  RPC)  ;  ils  couvrent  la  plupart  des  produits  de  construction  disponibles  sur  le 
marché.  
De  plus,  la  liste  finale  compilée  était  limitée  aux  produits  de  construction  relevant  de  la 
définition d’articles selon l’Article 3.3. de REACH.  
Afin  de  permettre  une  amélioration  ultérieure  et  de  limiter  le  large  éventail  de  produits  de 
construction  potentiellement  pertinents  en  termes  d’exposition  des  consommateurs,  une 
priorisation  a  été  réalisée  sur  base  d’un  jugement  d’experts  prenant  en  considération  les 
quatre  facteurs  suivants :  (i)  contact  direct  avec  l’air  intérieur,  (ii)  contact  cutané  potentiel 
durant  la  phase  d’utilisation,  (iii)  exposition  DIY  potentielle  (en  tenant  compte  de  la  durée 
d’exposition,  de  la  surface  exposée  et  de  l’implication  en  termes  de  manipulation)  et  (iv) 
couverture  en  termes  de  contenu  et  d’émission.  Sur  base  de  l’exercice  de  priorisation,  une 
étude  de  marché  a  été  réalisée  afin  d’évaluer  les  quantités  produites/vendues  sur  le  marché 
européen,  qui  englobait  les  catégories  de  produits  suivantes  (qui  ont  par  la  suite  été 
divisées en sous-catégories) :  
Portes et fenêtres, produits à base de céramique, produits d’isolation thermique, revêtements 
muraux,  béton  et  ciment,  panneaux  à  base  de  bois,  maçonnerie,  revêtements  de  sol, 
revêtements  d’espaces  sportifs,  plâtre  et  produits  à  base  de  plâtre,  plafonds  suspendus, 
plafonds tendus, terrasses et terrains de jeux.  
Pour  chaque  catégorie  et  sous-catégorie  de  produits,  des  données  relatives  aux  volumes  de 
vente  ont  été  rassemblées  grâce  à  l’analyse  de  documents  et  sites  web  publics  et  à  une 
enquête  auprès  d’acteurs  de  référence.  D’après  ces  données,  on  assisterait,  dans  un  avenir 
proche, à une évolution à la hausse des volumes de vente des portes et fenêtres, carreaux en 
céramique,  produits  d’isolation  thermique,  panneaux  à  base  de  bois,  revêtements  de  sol 
(excepté les planchers en liège) et terrasses en matériaux composites bois/plastique. Même si 
les informations collectées n’étaient pas homogènes, l’étude a fourni une bonne estimation des 
volumes achetés et installés en Europe. Les informations collectées étaient généralement plus 
détaillées pour les produits de construction dominés par de grandes sociétés (par exemple, le 
plâtre,  le  ciment  et  le  béton).  Pour  les  autres  produits  de  construction  (par  exemple,  les 
revêtements  de  sol  ainsi  que  les  portes  et  fenêtres),  il  a  été  fallu  adopter  une  approche  de 
vérification  multiple  et  croisée  afin  d’estimer  les  volumes  de  marché.  Etant  donné  la  non-
accessibilité  ou  la  non-existence  de  données,  les  volumes  de  vente  des  produits  de 
construction suivants n’ont pas pu être correctement évalués : revêtements muraux, plafonds 
tendus et terrains de jeux. 
Lors  de  la  Tâche  2,  une  liste  globale  de  substances  CMR  1A/1B  étant  contenues  dans  les 
articles  de  construction  a  été  compilée  sur  base  d’informations  collectées  depuis  différentes 
sources  et  stratégies,  et  lorsqu’il  était  possible  d’identifier  la  fonction  technique  de  ces 
substances  CMR  1A/1B  dans  ces  articles.  Tout  d’abord,  une  liste  des  substances  pour 
lesquelles il a été prouvé la présence dans les produits de construction – ou le rejet par ceux-ci 
–  a  été  compilée,  sur  base  de  la  consultation  des  sources  complémentaires  d’information 
suivantes :  

•  Base  de  données  des  émissions  par  les  matériaux  de  construction :  liste  des 
composés  organiques  volatils  (COV)  rejetés  par  les  articles  de  construction  dans  l’air 
intérieur, sur base de projets de recherche passés ou en cours.  

•  Programmes  d’évaluation  des  matériaux  de  construction  destinés  aux 
bâtiments  basée  sur  leur  impact  sur  la  santé :  la  liste  des  valeurs  de  référence 

18 

 
sanitaires  harmonisées  dans  toute  l’UE  issues  et  recommandées  par  un  groupe  de 
travail européen pour l’évaluation des émissions de produits, sur base du concept dit de 
concentration limite d’intérêt (CLI) 11 et de la liste du Comité allemand pour l’évaluation 
sanitaire des produits de construction (liste AgBB). 

•  Liste des substances CMR 1A/1B dans les articles de construction extraite des dossiers 
de  notification  d’articles  disponibles  sur  le  site  web  de  l’Agence  européenne  des 
produits chimiques (ECHA 12). 

•  Recherche  dans  les  dossiers  d’enregistrement  REACH  de  substances  reprises  sous  le 
Secteur d’Utilisation 19 (travaux de construction et construction de bâtiments) et sous 
d’autres catégories pertinentes quant au rejet dans l’environnement. 

• 

•  Requêtes  REACH  Article  33  envoyées  aux  fabricants  et  revendeurs  de  produits  de 
construction  quant  à la  présence  de  substances  extrêmement  préoccupantes  (SVHC) 13 
pour des concentrations > 0,1%. 
Identification  de  substances  CMR  1A/1B  dans  des  articles  de  construction  dans  des 
dossiers de restriction consultables sur le site web de l’ECHA. 
Identification  de  l’usage  autorisé  de  substances  CMR  1A/1B  (Annexe  XIV)  dans  des 
articles de construction, consultables sur le site web de l’ECHA. 
Informations  consultables  dans  les  rapports  européens  d’évaluation  des  risques 
des  substances  CMR  1A/1B  publiés  sous  le  règlement  sur  les  substances  existantes 
(EEC) No. 793/93. 

• 

• 

Les  substances  identifiées  depuis  les  sources  susmentionnées  ont  ensuite  été  examinées  en 
vue  d’une  classification  CMR  1A/1B  harmonisée  dans  l’inventaire  européen  des  classifications 
et des étiquetages disponible sur le site web de l’ECHA 14. Par conséquent, nous avons identifié 
31  substances  CMR  1A/1B  pour  lesquelles  il  existe  (i)  des  indications  de  présence  dans  au 
moins  une  catégorie  de  matériaux  de  construction  ou  (ii)  des  preuves  d’émission  dans  au 
moins une catégorie de matériaux de construction. 
Les  informations  relatives  au  contenu  et  aux  fonctions  techniques  de  ces  substances  ont  été 
collectées.  L’utilisation  répandue  de  ces  substances  CMR  1A/1B  dans  les  articles  de 
construction a été évaluée sur base (i) du nombre de situations lors desquelles ces substances 
ont  été  détectées  dans  les  sources  consultées  et  (ii)  des  fourchettes  de  volumes  fabriqués  / 
importés  indiqués  dans  les  dossiers  d’enregistrement.  Ces  derniers  ont  fourni  une  estimation 
quant au degré d’utilisation de la substance de manière générale mais ne permettent toutefois 
pas  d’indiquer  quelle  fraction  de  l’utilisation  concerne  spécifiquement  les  produits  de 
construction.  
Outre  les  informations  par  substance,  nous  formulons  les  observations  et  considérations 
générales suivantes :  

toujours  présente  dans 

1.  Seul  le  projet  BUMA 15  fournit  des  informations  quant  aux  émissions  des  articles  de 
construction. Les autres sources d’information fournissent uniquement des informations 
quant au contenu et/ou à l’utilisation de substances dans les articles de construction. 
Il n’est pas toujours possible de déterminer si une substance utilisée pour la production 
d’articles  est 
final.  L’inverse  est  également 
envisageable : certaines substances CMR 1A/1B ne sont pas utilisées dans la fabrication 
d’articles  de  construction,  et  sont,  par  conséquent,  initialement  considérées  comme 
étant  absentes  de  ces  matériaux  de  construction.  Toutefois,  il  a  été  démontré  en 
chambre  de  test  que  ce  type  de  substances  peut  être  émis  des  matériaux  de 
construction.  Cette  émission  peut  être  induite  par  la  dégradation  ou  par  des  réactions 
secondaires (par exemple, la dégradation des phtalates dans le cas des revêtements en 
PVC).  

l’article 

11 En anglais, Lowest Concentration of Interest (LCI). 

12 En anglais, European Chemicals Agency. 

13 En anglais, substances of very high concern.  

14 http://echa.europa.eu/information-on-chemicals/cl-inventory-database/ 

15 BUilding MAterials as indoor pollution sources, http://mech.uowm.gr/bumaproject/. 

19 

 
                                           
 
2.  La  fourchette  élevée  de  quantité  des  volumes  fabriqués  /  importés  des  dossiers 
d’enregistrement  et  les  différentes  sources  d’information  confirment  la  présence  de 
substances  CMR  1A/1B  dans  de  nombreux  articles  de  construction  différents.  Les 
substances  CMR  1A/1B 
le 
formaldéhyde,  le  phtalate  de  bis(2-éthylhexyle)  (DEHP),  l’acide  borique,  le  tétraborate 
de disodium anhydre et l’acrylonitrile. 

les  plus  courantes  sont 

identifiées  comme  étant 

3.  Les  substances  CMR  1A/1B  sont  identifiées  comme  étant  utilisées  dans  une  large 
variété de catégories de produits de construction et d’utilisations spécifiques : portes et 
fenêtres,  produits  à  base  de  céramique,  produits  d’isolation  thermique,  revêtements 
muraux,  béton,  panneaux  à  base  de  bois,  revêtements  en  PVC  et  plaques  de  plâtre. 
Pour les catégories relatives aux ‘revêtements d’espaces sportifs’, aux ‘terrasses’ et aux 
‘terrains  de  jeux’,  aucune  utilisation  de  substances  CMR  1A/1B  n’a  été  identifiée. 
L’utilisation  de  pneus  en  caoutchouc  recyclés  pour  le  gazon  synthétique  peut  toutefois 
entraîner  la  présence  de  substances  CMR  1A/1B  dans,  par  exemple,  les  ‘revêtements 
d’espaces sportifs’. 

4.  Pour  certaines  substances  (chloroprène,  dipentyl  phtalate  (DPP),  diméthylformamide 
(DMF) et benzène), la seule source d’information significative était la base de données 
BUMA.  Etant  donné  l’absence  d’enregistrements  et  de  notifications  REACH  pour  ces 
substances dans les articles de construction, on peut supposer que ces substances sont 
présentes sous forme d’impuretés. De plus, pour le diméthylformamide, chloroprène et 
dipentyl  phtalate,  le  rejet  depuis  des  articles  de  construction  n’a  été  détecté, 
respectivement,  uniquement  que  dans  1,  2  et  3  articles  de  construction  parmi 
l’ensemble  de  la  base  de  données  BUMA  (347  entrées  pour  les  articles  et  produits  de 
construction). On peut donc supposer que leur présence se manifeste uniquement dans 
une petite minorité de ce type d’articles de construction.  

5.  Pour  plusieurs  substances  issues  de  la  liste  d’autorisation  (Annexe  XIV),  des 
notifications et enregistrements d’utilisation REACH dans les articles de construction ont 
été  constatés,  alors  qu’il  n’existe  aucune  autorisation  pour  une  utilisation  spécifique 
dans  les  articles  de  construction  (par  exemple,  trichloréthylène,  phtalate  de  dibutyle, 
chromate  de  plomb,  2,4-dinitrotoluène,  phosphate  de  tris(2-chloroéthyle),  pentoxyde 
de diarsenic, phtalate de benzyle). Il est prévu que l’utilisation de ces substances dans 
les  produits  de  construction  disparaisse  des  articles  fabriqués  en  UE  au-delà  de  leur 
date  de  retrait.  L’ECHA  peut  utiliser  des  restrictions  dans  le  cadre  d’articles  importés 
(Article 69.2). 

6.  Le taux de réponse des requêtes Article 33 envoyées à 162 fabricants et revendeurs 
d’articles de construction sur le marché belge était relativement peu élevé (23%) et n’a 
pas abouti à l’identification de substances CMR 1A/1B supplémentaires.  

7.  Pour  un  ensemble  de  substances  autres  que  les  31  identifiées  (à  savoir  1-méthyl-2-
pyrrolidone (NMP) ; phtalate de benzyle et de butyle (BBP)  zircone aluminosilicate, 2,4 
dinitrotoluène ; imidazolidine -2-thione; pentoxyde de diarsenic ; 2-éthoxyéthyl acétate 
1,2 diméthoxyéthane, et trichloréthylène), il est improbable - mais pas exclu - que ces 
substances  soient  utilisées  dans  des  matériaux  de  construction.  Pour  ces  substances, 
aucune utilisation dans les matériaux de constructions mentionnés n’a été relevée dans 
le dossier de notification. La phrase suivante a été ajoutée dans la section relative aux 
informations contenues dans le dossier d’enregistrement (« Registration Information on 
identified  uses  related  to  article  categories ») :  « Aucune  information d’enregistrement 
n’est disponible concernant une utilisation de la substance dans des  articles. La  raison 
peut être le non-enregistrement de la substance, le fait qu’aucune catégorie d’article ne 
soit  fournie  dans  l’enregistrement  du  produit  ou  que  les  utilisations  des  produits 
enregistrés soient confidentielles.  

Sur  base  de  cette  déclaration,  il  ne  peut  être  exclu  que  les  10  substances  précitées  soient 
utilisées dans des matériaux de construction. Toutefois, sur base des informations disponibles, 
il  est  impossible  de  vérifier  leur  présence  dans  des  matériaux  de  construction  et,  le  cas 
échéant, il serait impossible d’identifier dans quelle catégorie de produit elles seraient utilisées. 
De ce fait, ces  substances  ont été  exclues de  la liste générale des substances  CMR présentes 
dans  les  matériaux  de  construction,  à  moins  que  des  preuves  attestent  de  leur  présence  via 
d’autres sources étudiées dans cette Tâche, ou qu’il existe des données relatives à l’exposition 

20 

 
à  ces  substances  (voir  section  4.5 quant  au  trichloréthylène,  BBP,  1-méthyle-2-pyrrolidone 
(NMP)).   

La  seconde  partie  de  la  Tâche  2  a  permis  d’obtenir  un  aperçu  de  la  législation  actuelle 
nationale, européenne et de pays tiers restreignant les substances CMR 1A/1B dans les articles 
de construction.  
Au  sein  de  l’UE,  le  règlement  REACH  représente  la  loi  la  plus  pertinente  en  termes  de 
substances  CMR  1A/1B  dans  les  articles  de  construction.  Certaines  utilisations  spécifiques  de 
substances  CMR  1A/1B  sont  régies  par  des  autorisations  et  restrictions,  mais  l’utilisation  de 
substances  CMR  1A/1B  dans  les  articles  de  construction  n’est  généralement  pas  interdite.  De 
plus,  les  producteurs  et  importateurs  de  substances  reprises  sur  la  liste  candidate  des 
substances  extrêmement  préoccupantes  (SVHC),  parmi  lesquelles  plusieurs  sont  des  CMR 
1A/1B, ont le devoir d’en informer l’ECHA si la concentration de l’article est supérieure à 0,1%. 
Les  interdictions  et  restrictions  de  substances  CMR  1A/1B  via  le  règlement  REACH,  et 
l’obligation de notifier l’ECHA quant à l’utilisation de SVHC dans les articles de construction se 
basent sur des critères de ‘présence ou contenu’, et non sur des critères de rejet.  
La  majorité  des  Etats  membres  de  l’UE  se  réfère  particulièrement  à  la  législation  européenne 
relative  aux  substances  CMR  1A/1B  dans  les  articles  de  construction  (via  les  règlements 
REACH et RPC) et ne dispose pas, ou peu, d’une législation nationale complémentaire relative 
aux substances CMR 1A/1B dans les articles. Certains Etats membres disposent toutefois d’une 
législation  nationale  complémentaire  relative  à  l’aspect  des  CMR  1A/1B  dans  les  articles  de 
construction. Certaines législations nationales appliquent des groupes spécifiques d’articles de 
construction  (par  exemple,  en  Belgique :  matériaux  de  revêtement  de  sol ;  en  Allemagne : 
matériaux  de  revêtement  de  sol  et  papiers  peints  décoratifs),  tandis  que  d’autres  législations 
nationales  appliquent  un  large  groupe  d’articles  de  construction  (par  exemple,  en  Lituanie : 
tous  les  produits  de  construction  en  polymère  et  mobilier  en  polymère  pour  les  installations 
intérieures ;  en  Pologne :  matériaux  de  construction,  installations  et  éléments  de  mobilier 
utilisés dans des pièces destinées à des demeures résidentielles).  
Ces  législations  nationales  sont  généralement  orientées  vers  l’aspect  de  rejet.  Par 
exemple, les législations allemande, belge et lituanienne limitent le rejet des substances CMR 
1A/1B  couvertes  sous  le  protocole  de  vérification  d’émissions  prEN  1651616  à  des 
concentrations  maximales,  pour  des  pièces  de  référence,  de  1  µg/m³  après  28  jours  de  test 
d’émission.  
De  plus,  certains  pays  disposent  d’une  législation  spécifique  pour  des  substances  CMR 
spécifiques  dans  des  applications  spécifiques.  Par  exemple,  le  Danemark  restreint  l’utilisation 
de  cadmium  (Cd)  dans  les  articles  de  construction  (max.  0,0075%  Cd)  et  l’utilisation  de 
formaldéhyde dans les panneaux à base de bois. Il est intéressant de noter que le Danemark 
donne  la  priorité  aux  critères  de  rejet  du  formaldéhyde  dans  les  panneaux  à  base  de  bois 
(max.  0,15  mg/m³  en  salle  d’essai).  Cependant,  si  une  société  n’est  pas  à  même  d’attester 
l’exécution de cette exigence, il est permis d’utiliser des panneaux présentant un maximum de 
25  mg  de  formaldéhyde  libre  par  100  g  de  matière  sèche  dans  le  panneau  (i.e.  critères  de 
contenu).  
En  France,  il  est  interdit  d’utiliser  les  substances  CMR  1A/1B  suivantes  dans  la  fabrication  de 
produits  de  construction  et  de  décoration :  trichloréthylène,  benzène,  phtalate  de  bis(2-
éthylhexyle) (DEHP) et phtalate de dibutyle. 
En dehors de l’UE, les règlements relatifs aux articles de construction visent principalement le 
formaldéhyde ; citons par exemple le règlement californien ATCM 93120 relatif à la mesure de 
contrôle  des  produits  toxiques  dans  l’air17  et  l’arrêté  japonais  et  ses  notifications  relatifs  au 
respect des lois en matière de normes de construction.  

16 DRAFT prEN 16516, mai 2015, Produits de construction - Evaluation de l’émission de substances dangereuses - Détermination des 
émissions dans l’air intérieur.  
17 http://www.arb.ca.gov/regact/2007/compwood07/fro-final.pdf 

21 

 
 
                                           
 
Lors de la Tâche 3, il a été analysé, pour les substances CMR identifiées lors de la Tâche 2, si 
leur  présence  dans  des  articles  de  construction  entraîne  effectivement  une 
exposition ;  dans  ce  cadre,  divers  scénarios  d’utilisation  -  par  des  consommateurs  et  des 
professionnels - ont été examinés.  
De  plus,  les  informations  ont  été  recueillies  quant  aux  méthodes  d’évaluation  de 
l’exposition à des substances CMR 1A/1B dans les articles de construction. Nous donnons un 
aperçu  indiquant  quelles  informations  sont  facilement  accessibles  pour  l’évaluation  de 
l’exposition,  et  quelles  informations  sont  manquantes  et  doivent  être  explorées  (au  cas  par 
cas)  afin  de  quantifier  l’exposition  à  des  substances  CMR  contenues  dans  les  articles  de 
construction.  
Les informations récoltées lors de la Tâche 3 ont confirmé la présence de plusieurs substances 
CMR  1A/1B  dans  plusieurs  articles  de  construction.  La  littérature  relative  aux  données 
expérimentales  a  démontré  que  certaines  substances  CMR  1A/1B  sont  effectivement  rejetées 
dans l’air intérieur et/ou sont potentiellement libérées sur la peau par contact cutané.  
La  littérature  relative  aux  données  de  contrôle  quant  au  formaldéhyde,  au  benzène  et  aux 
phtalates  au  sein  des  locaux  à  usage  d’habitation  confirme  que  ces  substances  CMR  1A/1B 
sont  largement  présentes  dans  l’environnement  intérieur.  Cependant,  d’autres  sources  (par 
exemple,  air  intérieur,  produits  de  nettoyage,  etc.)  en  sus  des  articles  de  construction  sont 
susceptibles  de  contribuer  également  à  ces  concentrations  à  l’intérieur,  du  moins  pour  le 
benzène.  
Pour  d’autres  substances  CMR  1A/1B  (par  exemple,  phosphate  de  tris(2-chloroéthyle)  (TCEP) 
et  N-méthyl-2-pyrrolidone),  les  données  de  contrôle  de  poussière  intérieure  dans  diverses 
habitations ont montré que ces substances sont présentes seulement dans une petite minorité 
de bâtiments au sein de l’UE.   
Les méthodes permettant d’évaluer l’exposition à des substances CMR 1A/1B pour le scénario 
‘exposition  des  consommateurs  via  air  intérieur  durant  la  durée  de  vie  de  l’article’  sont  bien 
établies  (test  d’émission  CEN/TS  16516)  et  intégrées  dans  des  cadres  réglementaires  (par 
exemple,  RPC).  Ces  résultats  issus  de  taux  d’émission  mesurés  expérimentalement  ont  été 
démontrés  de  manière  à  correspondre  aux  concentrations  de  l’air  intérieur  dans  des 
environnements intérieurs réels (notamment Missia et al., 2010).   
Les méthodes permettant d’évaluer le scénario d’exposition cutanée des consommateurs après 
contact cutané avec des articles de construction font toutefois davantage l’objet d’incertitudes. 
Ces  incertitudes  sont  dues  aux  défauts  constatés,  et  à  l’approche  modèle,  en  particulier  les 
défauts  liés  à  l’épaisseur  de  couche,  et  l’extrapolation  des  quantités  rejetées  vers  la  zone  de 
contact.  Par  ailleurs,  les  données  comportementales  incluses  dans  les  modèles  peuvent  être 
controversées  comme  étant  trop  conservatrices  et  irréalistes.  De  plus,  les  données 
expérimentalement  déterminées  relatives  à  la  migration  cutanée  font  l’objet  d’incertitudes 
quant  à  la  composition  physico-chimique  appropriée  des  moyens  d’extraction,  et  au  manque 
de  comptabilité  de  facteurs  de  transfert.  Ces  limitations  rendent  difficile  la  génération 
d’estimations  d’exposition  pertinentes  quant  à  une  exposition  cutanée  à  des  substances 
présentes  dans  des  articles  de  construction.  Contrairement  à  l’exposition  à  l’air  intérieur, 
l’exposition  cutanée  à  des  substances  présentes  dans  des  articles  de  construction  n’est  pas 
(encore) intégrée dans une norme officielle.  
Outre les deux scénarios d’exposition des consommateurs les plus évidents (émissions directes 
dans  l’air  intérieur  et  contact  cutané  direct),  des  scénarios  d’exposition  indirecte  à  des 
substances  semi-COV  présentes  dans  des  articles  de  construction  ont  également  été  décrits 
dans la littérature (par  exemple, les émissions  des  substances contenues dans des matériaux 
de construction via la poussière et, consécutivement, le contact oral et cutané). Par exemple, 
les données de contrôle des substances CMR 1A/1B semi-COV dans la poussière (par exemple, 
DEHP, TCEP) démontrent qu’il s’agit d’un mode probable d’exposition ; cependant, aucun outil 
largement reconnu pour l’évaluation de cette exposition n’a encore été agréé (des discussions 
sont en cours au niveau de l’OCDE).  
Les  données  relatives  aux  scénarios  d’expositions  DIY  et  professionnelles  sont  plus  rares  par 
rapport  à  celles  relatives  aux  expositions  durant  la  durée  de  vie  d’un  article.  L’exposition 
professionnelle  à  des  substances  contenues  dans  des  articles  de  construction  (par  exemple, 
installateurs  de  revêtements  en  PVC)  n’est  pas  incluse  dans  les  outils  d’exposition  des 
travailleurs  référencés  dans  les  directives  REACH.  Les  expositions  relatives  à  cette  catégorie 
professionnelle  semblent  être  plus  faibles  que  celles  des  travailleurs  en  contact  avec  des 

22 

 
processus  industriels  lors  desquels  un  contact  avec  ces  substances  durant  les  phrases  de 
fabrication et de production est probable.  
De manière à évaluer la probabilité d’exposition à des substances CMR 1A/1B issues d’articles 
de construction, 5 critères ont été utilisés pour chacun des cas identifiés lors de la Tâche 2, à 
savoir (1) présence de substances CMR 1A/1B dans des articles de construction, (2) émission 
de  substances  CMR  1A/1B  dans  des  articles  de  construction  (à  partir  de  programmes  de 
contrôle),  (3)  estimation  de  l’exposition  (modélisation),  en  tenant  compte  des  rejets,  de  la 
charge de l’article et du taux de renouvellement de l’air dans les milieux intérieurs, (4) mesure 
de l’exposition à l’intérieur (vérification de la qualité de l’air intérieur (QAI) dans les bâtiments) 
et  (5)  validation  que  les  articles  de  construction  sont  la  principale  source  d’exposition  à 
l’intérieur.  Le  fait  de  passer  du  critère  1  à  5  indique  une  importance  croissante  quant  à  une 
exposition à des substances CMR 1A/1B par rapport à la présence d’articles de construction.  
Sur base de la cotation de ces 5 critères, les différents couples d’articles de construction (AC) 
et  de  substances  CMR  ont  été  organisés  en  groupes.  Les  couples  AC  /  substances  CMR 
appartenant  au  même  groupe  présentent  une  probabilité  similaire  d’exposition  des 
consommateurs aux substances CMR présentes dans les articles de construction.  
Par conséquent, il existe un large éventail d’éléments de preuve d’exposition à des substances 
CMR  1A/1B  en  fonction  de  la  présence  d’articles  de  construction.  D’une  part,  pour  certaines 
substances (par exemple, formaldéhyde), l’exposition des consommateurs a été démontrée de 
plusieurs manières (données d’émission, données de contrôle de l’air intérieur), l’exposition est 
omniprésente en UE et  les articles de construction intérieurs ont été démontrés  comme étant 
une source significative d’exposition à l’intérieur. D’autre part, pour les autres cas, les données 
de  contrôle  inférieures  au  seuil  de  détection  dans  tous  les  locaux  considérés  indiquent  que la 
substance  n’est  pas  présente  dans  les  environnements  intérieurs,  et  donc  la  présence 
éventuelle de la substance dans les articles de construction n’entraîne pas une exposition des 
consommateurs  (par  exemple,  acrylonitrile).  Cependant,  pour  la  majorité  des  substances,  les 
résultats  sont  moins  évidents.  Dans  certains  cas,  les  informations  disponibles  indiquent  que 
l’origine  d’une  exposition  à  partir  d’articles  de  construction  est  probablement  mineure.  Dans 
d’autres cas, aucune évaluation ne peut être réalisée sur base des informations disponibles, et 
donc davantage de données de contrôle sont nécessaires pour pouvoir réaliser une évaluation 
pertinente.  
Lors de la Tâche 4, des tests analytiques ont été réalisés sur des articles de construction pour 
lesquels des données CMR n’étaient pas facilement accessibles. Les tests ont été réalisés sur 8 
matériaux  de  revêtement  de  sol  à  base  de  PVC  résistant  et  2  papiers  peints  achetés  sur  le 
marché de détail belge en 2015. Les tests analytiques réalisés incluaient le test du contenu, le 
test d’exposition cutanée et le test des émissions dans l’air intérieur.  
La liste des substances CMR 1A/1B cibles consistait en 71 substances  volatiles, semi-volatiles 
et très volatiles. 
Pour le test du contenu, ont été utilisés de l’acétate d’éthyle (en tant que solvant d’extraction 
pour la détection) et du méthanol (pour la quantification). Les 10 échantillons ont d’abord été 
contrôlés  quant  à  leur  contenu  CMR  1A/1B,  sur  base  de  techniques  GC-MS  (« headspace »). 
Les  mesures  quantitatives  du  contenu  ont  été  réalisées  via  LC-MS/MS.  Il  a  clairement  été 
démontré  qu’aucun  des  échantillons  ne  contenait  des  substances  CMR  1A/1B.  L’analyse  du 
contenu  a  été  complétée  par  des  expérimentations  sur  l’exposition  cutanée.  Le  transfert 
combiné  à  une  migration  lors  d’une  exposition  cutanée  long  terme  a  été  simulé  par  une 
extraction en une étape à des conditions d’agitation selon un pH de 5,5 et à une température 
E04 (ISO, 2013). Aucune 
de 37°C, avec de la sueur artificielle selon la norme DIN EN ISO 105
substance CMR 1A/1B n’a migré des articles vers la sueur artificielle.  
‐
Le  rejet  potentiel  dans  l’air  intérieur  de  substances  CMR  depuis  les  10  échantillons  a  d’abord 
été analysé au moyen  de la technique de détection standard par microchambre.  Les mesures 
quantitatives  d’émission  ont  été  prises  suivant  (i)  le  nouveau  test  européen  d’émission 
horizontal  standard  (prEn  16516,  2015)  dans  des  chambres  de  test  de  110  et  500  l  et  (ii) la 
méthode  complémentaire  de  cellule  d’essai  (FLEC).  Les  moments  de  prélèvement  de  l’air  ont 
été  déterminés  de  manière  à  refléter  l’exposition  du  consommateur  durant  l’installation  ou  la 
durée de vie de l’article. Un prélèvement après 3 jours a été réalisé afin d’évaluer l’exposition 
durant  l’installation.  Un  prélèvement  après  28  jours  a  été  réalisé  afin  d’évaluer  l’exposition 
durant  la  durée  de  vie,  selon  le  rapport  JRC  N°27  (2012),  « Cadre  d’harmonisation  des 
systèmes d’étiquetage de produits intérieurs en UE ».  

23 

 
Les  prélèvements  ont  été  réalisés  sur  6  types  d’absorbants  afin  de  bien  capturer  l’ensemble 
des substances CMR. Les résultats ont montré uniquement de faibles émissions (1-10 µg/m³) 
de  formaldéhyde  après  3  jours  pour  3  (2  revêtements  de  sol  et  1  revêtement  mural)  des  10 
matériaux  testés.  Aucune  autre  substance  CMR  1A/1B  n’a  été  détectée  dans  l’un  des  dix 
articles.   

24 

 
 
CHAPTER 1 

INTRODUCTION 

People  spent  eighty  percent  of  their  time  indoors.  Hence  the  quality  of  the  indoor  air  is  of 
utmost  importance  for  maintaining  human  health.  Construction  materials  for  buildings  may 
release substances to the indoor air, which could have an impact on the health of residents or 
visitors  to  the  building.    In  addition,  also  dermal  exposure  during  installation  of  construction 
products  and  during  service  life  (e.g.  flooring,  sports  areas)  needs  consideration.  The 
widespread  use  of  construction  products  creates  large  opportunities  for  a  high  number  of 
consumers to be exposed to substances released from these products. Exposure of consumers 
to substances with chronic toxicity properties should be prevented as much as possible.  

Hazardous  substances  can  i.a.  be  managed  by  restriction  of  these  substances  individually  or, 
when used in mixtures or articles, in Annex XVII of the REACH Regulation (EU) 1907/200618. 
The  normal  procedure  to  set  restrictions  under  REACH  involves  a  detailed  assessment  of  the 
risks  posed  by  specific  uses  of  a  substance,  and  the  socio-economic  impacts  of  a  possible 
restriction. In addition, REACH, through Art. 68(2), offers a simplified restriction procedure, as 
regards  consumer  uses,  for  substances  classified  as  carcinogenic,  mutagenic  or  toxic  for 
reproduction  (CMR  Cat.  1A/1B,  according  to  the  Regulation  on  Classification,  Labelling  and 
Packaging  (CLP)19.  This  project  studies  the  possible  application  of  Article  68(2)  to  CMR 
substances  in  construction  articles,  by  aiming  to  identify  CMR  Cat.  1A/1B  substances  used  in 
such articles and having the potential to lead to exposure of consumers.  

For  substances  and  mixtures,  merely  the  presence  of  a  CMR  1A/1B  substance  is  enough  to 
assume  exposure.  However,  in  the  case  of  articles,  such  as  construction  articles,  it  is  the 
release  rather  than  the  presence  of  CMR  1A/1B  substances  in  the  article  that  plays  an 
important  role  in  the  assessment  of  potential  exposure.  Releases  from  construction  products 
may occur during the construction and fitting of buildings and/or during the service life of the 
buildings.  

This project consisted of the following tasks:  

• 

Identification of different groups of construction articles, the estimation of their market 
volume  and initial  assessment  of  their  relevance  for  human  exposure  via inhalation  or 
dermal contact (Chapter 2);  

•  Compilation  of  a  list  of  CMR  1A/1B  substances  that  are  likely  to  be  present  in 

construction products (Chapter 3); 

•  Exploration of the legislation restricting CMR 1A/1B substances in construction products 

• 

(Chapter 3); 
Identification of cases for which consumer exposure to selected CMR 1A/1B substances 
from  construction  products  is  possible;  assessment  of  the  likelihood  of  consumer 
exposure (chapter 4); and, 

•  Perform  analyses  to  confirm  the  presence  and  release  of  CMR  1A/1B  substances  in 

construction products (chapter 5). 

18 Regulation (EC) No 1907/2006 on Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) 

19 Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures 

25 

 
 
 
                                           
 
CHAPTER 2  LIST OF CATEGORIES OF CONSTRUCTION PRODUCTS 

 2.1 IDENDIFICATION  OF  CONSTRUCTION  ARTICLES  POTENTIALLY  LEADING  TO 

CONSUMER EXPOSURE 

The objective of task 1 (activity 1.1) was to compile a list of construction products (CPs) from 
which  consumer  exposure  (inhalation  +  dermal)  to  their  chemical  content  is  possible, 
considering the following 2 scenarios: 

1.  “consumer  exposure”  scenario:  installation  of  the  construction  products  is  done  by  a 

professional, consumer is exposed during the use phase 

2.  “Do it yourself (DIY) exposure” scenario20: consumer installs the construction products 

himself 

The  compilation  of  this  list is  based  on  criteria  described  hereafter.  For  construction  products 
the definition from the Construction Products Regulation (EU) No 305/2011 (CPR) was applied 
(Article 2 (1)): any product or kit which is produced and placed on the market for incorporation 
in  a  permanent  manner  in  construction  works  or  parts  thereof  and  the  performance  of  which 
has  an  effect  on  the  performance  of  the  construction  works  with  respect  to  the  basic 
requirements for construction works. 

For  the  purpose  of  this  study  the  diverse  range  of  construction  products  was  limited  to 
products for which harmonized technical specifications are available as they are covering most 
of  the  construction  products  available  on  the  market.  Harmonized  technical  specifications are 
established  for  the  purpose  of  assessing  the  performance  of  construction  products  and  are 
defined  in  Article  2(10)  of  the  CPR  as  harmonized  standards  and  European  Assessment 
Documents (EADs). 

In  addition,  the  final  compiled list  will  be  restricted  to  construction  products  falling  under  the 
definition of articles according to Art. 3(3) of REACH. 

For task 1 a construction product is considered relevant when: 

• 

• 

the construction product is normally used to build an indoor environment or is present 
in  an indoor  environment  and  has  the  possibility21  to  release  hazardous  substances  to 
the indoor environment to which individuals can be exposed through inhalation and/or 
dermal contact. For this purpose two use categories will be taken into account: Products 
with  direct  contact  to  indoor  air  and  products  with  no  direct  contact  to  (e.g.  covered 
products) but possible impact on indoor air.  
the construction product is used outdoors and has the possibility to release dangerous 
substances  (CMR  1A/1B)  to  the  outdoor  environment  to  which  individuals  can  be 
exposed through dermal contact 

The starting lists of product groups derived from mandates and productTCs are shown in Table 
1  and  Table  2.  Mandates  are  the  standardization  requests  from  the  European  Commission  to 
the  European  standardization  organisations  (CEN/CENELEC).  The  different  CEN  technical 
committees (CEN/TC) are the  responses of CEN to the different  EC mandates for  establishing 
EU  harmonized  standards  in  the  different  construction  sectors.  Mandates  are  very  broad  in 
scope. The CEN/TCs deal in detail with the topics linked to their product scope hence the more 
general criteria for the different mandates and the further detailed CEN/TC criteria. 

20  As  this  study  is  conducted  in  the  context  of  a  possible  application  of  restrictions  according  to  article  68(2),  the 
exposure of workers is not considered within the scope of this study.  

21 according to a preliminary assessment: final assessment will be made in tasks 3  

26 

 
                                           
 
To  be  able  to  determine  which  product  groups  fall  under  the  scope  of  this  project  and  are 
relevant  for  the  inhalation  and  dermal  consumer  and  DIY  exposure  it  has  to  be  determined 
which  the  intended  uses  of  the  products  are  –  and  important  subcriteria  such  as  large/small 
loading  factors  –  and  which  product  groups  are  currently  already  “labelled”  as  possible 
candidates  by  the  information  available  in  European  working  groups  and  databases  and 
evaluation  protocols  dealing  with  dangerous  substances,  hence  the  selection  of  the  criteria 
listed  below.  If  the  mandate  (product  group)  is  amended  it  means  that  there  is  a  possible 
release of certain dangerous substances to indoor and/or outdoor environment that has to be 
assessed (with the new EU harmonized test methods developed in CEN/TC 351). If there is no 
amendment then it is considered that there is no need for further assessment of the product in 
the context  of release  of dangerous  substances.  The mandates that are amended are thus of 
higher importance in the context of exposure assessment. 

•  The  following  criteria  were  investigated  for  the  mandates 22:  intended  use  of  the 
construction product, potential release of CMR substances, relevant exposure scenarios 
(linked  to  intended  conditions  of  use  phase),  is  the  construction  product  an  article 
according 
labelling 
schemes 23,24,25,26,27,28,29,30,31,32  and  its  appearance  as  product  categories  in  the  BUMA 
database33. 

content/emission 

inclusion 

REACH?, 

to 

in 

•  For  the  CEN/TCs34  covered  by  relevant  mandates  the  following  criteria  were  further 
investigated:  is  the  construction  product  an  article  according  to  REACH?,  for  the 
products  used  indoors:  direct  or  indirect  contact  to  indoor  air,  (normative)  loading 
factor(s), and inclusion in content/emission labelling schemes. 

Mandate  109  (M/109)  Fire  alarm/detection,  fixed  firefighting,  fire  and  smoke  control  and 
explosion  suppression  products  was  considered    out  of  scope  of  this  study  due  to  the  large 
diversity and complexity of the products as well as textile floor coverings (part of M/119) which 
is addressed by another DG GROW project 35. 

22http://ec.europa.eu/enterprise/standards_policy/mandates/database/index.cfm?fuseaction=txtSearch.main&CFID=149963&CFTOKEN=8c6693d3
f879f278-E4B6C388-DA54-9635-C322D8572B889DB5&jsessionid=1d53c2063b3049d40ec527282b402e1b7965TR 
23For the list of schemes the RPA report (2013) “Study on specific needs for information on the content of dangerous 
substances in construction products” was used as reference complemented with schemes focussed on release to indoor 
air such as Greenguard, M1, LQAI, Indoor Air comfort and ICL. The protocols focussed on emissions confirm the trend 
of which mandates are the most covered 
24 Lor M., Vause, K. Dinne, K., Goelen, E. Maes, F., Romain, A.-C., Nicolas, J. and Degrave, C., state of the art report 
(2010)  Horizontal  Evaluation  Method  for  the  Implementation  of  the  Construction  Products  Directive  (HEMICPD): 
http://www.belspo.be/belspo/organisation/publ/pub_ostc/p2/rappp2-05_annex_en.pdf 
25 M1 Emission Classification of Building Materials: Protocol for Chemical and Sensory Testing of Building Materials,  
 The Building Information Foundation RTS 2015, version 22.1.2015 
26 Association for the Control of Emissions in Products for Flooring Installation, Adhesives and Construction Products 
(GEV), GEV - Testing Method Determination of Volatile Organic Compounds for Control of Emissions from Products for 
Flooring Installation, Adhesives, Construction Products and Wood Flooring Coatings, Edition: 15.04.2013 
27  Eurofins  Specifications  Indoor  Air  Comfort  ®and  Indoor  Air  Comfort  Gold,  version  5.3,  03  /  2015, 
http://www.eurofins.com/product-testing-services/information/ecolabels,-quality-labels/indoor-air-comfort-eurofins-certified-products.aspx 
28  ECA  report  No 24:  Harmonisation  of  indoor  material  emissions  labelling  systems  in  the  EU  -  Inventory  of  existing 
schemes, European Commission - Directorate Joint Research Centre - Institute for Health and Consumer Protection - 
Physical and Chemical Exposure Unit, EUR 21891 EN, 2005 
29 Danish Indoor Climate label: http://www.teknologisk.dk/ydelser/dansk-indeklima-maerkning/dim-omfatter/253,2 
30 Emicode label: http://www.emicode.com/index.php?id=1&L=1 
31 Finnish M1 label: http://www.rakennustieto.fi/index/english/emissionclassificationofbuildingmaterials.html 
32 US Greenguard label: http://greenguard.org/en/index.aspx 
33http://www.uowm.gr/bumaproject/ 
34https://www.cen.eu/work/areas/construction/products/Pages/default.aspx 
35 The potential impact on industrial competitiveness of restrictions on certain CMR 1A and 1B substances in articles" - 
Scoping study for the application of art. 68.2 of REACH to CMR substances requiring priority action, 2013, Contract n° 
30-CE-0533337/00-95 under Framework Contract ENTR/29/PP/2010/FC -Lot 1, ICF/AMEC 

27 

 
                                           
 
The  starting list  of  relevant  construction  products  for  which  technical assessments  have  been 
issued  by  Technical  Assessment  Bodies  (TABs)  and  which  are  relevant  to  the  indoor  and 
outdoor environment is shown in Table 336. 

According  to  Art.  66(3)  of  the  CPR  Regulation,  European  Technical  Approval  Guidelines 
(ETAGs)  in  accordance  with  Directive  89/106/EEC  which  is  repealed  by  the  CPR  regulation, 
may  be  used  as  European  Assessment  Documents  (EADs)  for  issuing  European  Technical 
Assessments (ETAs). In 2014 and based on an agreement with the European Commission, the 
European  Organisation  for  Technical  Assessment  (EOTA)  started  to  revise  the  ETAGs  and  to 
develop them into EADs. First new editions of ETAGs will be published in 2016. All ETAGs will 
be updated in 2022. 

All  possible  relevant  product  categories  used  in  ETAGs/EADs  (kits)  are  already  covered  as 
individual  products  in  the  CEN  scope  (Table  2)  and  are  thus  not  further  referenced  to  in  the 
report. 

36 http://eota.eu/en-GB/content/home/2/185/ 

28 

 
 
                                           
 
Table 1: Starting list of product groups, based on mandates from the European Commission to CEN/CENELEC 

e
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(listed 

in 

Y 
Y 

Precast concrete products 
Doors, windows and related 
products 
Membranes 
N 
Thermal insulation products  Y 
Y 
Gypsum products 
N 
Geotextiles 
Y 
Curtain walling 
Y 
Sanitary appliances 
Y 
Structural timber products 
and ancillaries 
Wood based panels 
Cement, building limes and 
other hydraulic binders 
Masonry and related 
products 
Floorings 
Structural metallic sections 

Y 
Y 

Y 
Y 

Y 

29 

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r
a
n
e
c
S

Y 

N 
N 
Y 
N 

Y 
Y 
Y 

N 

t
n
e
m
d
n
e
m
a

S
D
G
E

Y 

Y 
Y 
- 
- 

N 
Y 
- 

- 

s
e
m
e
h
c
s

g
n

i
l
l

e
b
a

l

n
o
i
s
s
i
m
e
/
t
n
e
t
n
o
c

n

i

d
e
r
e
d
i
s
n
o
C

Y 

Y* 
Y 
Y* 
Y* 

Y 
N 
Y 

Y 

e
l
c
i
t
r
a
H
C
A
E
R

Y 

Y 
Y 
N 
N 

Y 
Y 
N 

Y 

Product 
mandates) 

groups 

(listed 

in 

and ancillaries 
Internal and external wall 
and ceiling finishes 
Roof coverings 
Aggregates 
Construction adhesives 
Products related to 
concrete, mortar and grout 
Space heating appliances 
Glass in buildings 
Sealants for non-structural 
use in joints in buildings 
and pedestrian walkways 
External thermal insulation 
composite systems 
* Covered by most of the schemes 
- Not yet discussed in EGDS 

30 

)
S
U
(

d
r
a
u
g
n
e
e
r
G

Y 

N 
N 
Y 
N 

N 
N 
Y 

N 

t
r
o
f
m
o
c

r
i
a

r
o
o
d
n
I

Y 

N 
N 
Y 
N 

N 
N 
Y 

N 

)
l
a
g
u
t
r
o
P
(

I
A
Q
L

N 

N 
N 
N 
N 

N 
N 
N 

N 

)
k
r
a
m
n
e
D
(

L
C
I

Y 

N 
N 
Y 
N 

N 
N 
N 

N 

e
s
a
b
a
t
a
d

C
A
M
U
B

n

i

y
r
o
g
e
t
a
c

t
c
u
d
o
r
P

Y 

N 
N 
Y 
N 

N 
N 
N 

N 

)
d
n
a
n
F
(

l

i

1
M

Y 

N 
N 
Y 
Y 

N 
Y 
Y 

N 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 2: Starting list of product groups, based on scope of CEN/TCs 

e
l
c
i
t
r
a
H
C
A
E
R

r
o
o
d
n

i

t
c
a
t
n
o
c

t
c
e
r
i
D

t
n
e
m
n
o
r
i
v
n
e

Y 

Y 
Intermediate product 
Y 

Y 

Y 
Y 
Y 
Y 
Y 
Y 

N 
Y 

r
o
o
d
n

i

t
c
a
t
n
o
c

t
c
e
r
i
d
n
I

t
n
e
m
n
o
r
i
v
n
e

N 

N 

N 

Y 

N 
Y 
Y 
Y 
Y 
Y 

N 
N 

o
t
n

i

7
3

r
o
t
c
a
f

i

g
n
d
a
o
L

r
i
a

r
o
o
d
n

i

0.05 

0.05 
- 
0.4 

0.4 / 1.0  

1.0 
0.4 / 1 
0.4 / 0.05 / 1 
0.4 / 1 
0.4 /1 
0.4 

0.4/0.05/1.0 
0.05 

n
o
i
s
s
i
m
e
/
t
n
e
t
n
o
c

n

i

d
e
r
e
d
i
s
n
o
C

s
e
m
e
h
c
s

g
n

i
l
l

e
b
a

l

Y 

Y 
Y 
Y 

Y* 

Y 
Y 
Y 
Y 
Y 
Y* 

Y 
Y 

Product groups (listed in CEN/TCs) 

Doors, windows, shutters, building 
hardware and curtain walling 
Oil stoves 
Cement and building limes 
Ceramic tiles 

Thermal insulation materials and 
products 
Wall coverings 
Concrete 
Wood based panels 
Timber structures 
Masonry 
Roof coverings for discontinuous 
laying and products for wall cladding 
Glass in buildings 
Space heating appliances without 
integral heat sources 

Y 

Y 
N 
Y 

Y 

Y 
Y 
Y 
Y 
Y 
Y 

Y 
Y 

37 Loading factor = ratio of the exposed dimension of the test specimen to the empty test chamber volume (for instance: L = 0,4 m2/m3 for floor & ceiling materials, defined in 
CEN/TS 16516 (see Chapter 5)) 

31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                           
 
r
o
o
d
n

i

t
c
a
t
n
o
c

t
n
e
m
n
o
r
i
v
n
e

t
c
e
r
i
D
Intermediate product 
Y 

Intermediate product 
Y 
Y 
N 

e
l
c
i
t
r
a
H
C
A
E
R

Y 
Y 

N** 
Y 
Y 
Y 

Y 
N 
Y 
Y 
Y 
Out of scope 
Y 
Y 
Y 

N 
N 
Y 
Y 
Y 
Y 
Y 
Y 
Y 

N 
N 
N 

Y 

Intermediate product 
Y 
Y 

Y 

r
o
o
d
n

i

t
c
a
t
n
o
c

t
c
e
r
i
d
n
I

t
n
e
m
n
o
r
i
v
n
e

N 

N 
Y 
Y 

N 
Y 
N 
Y 
Y 
Y 
Y 
N 
N 

Y 
N 

N 

o
t
n

i

7
3

r
o
t
c
a
f

i

g
n
d
a
o
L

r
i
a

r
o
o
d
n

i

- 
0.4 

- 
0.05 
0.4 / 1 
0.4 / 1 

0.4 
0.007 
0.4 
0.4 / 1 
0.4 / 1 
0.4 /1 
0.4 / 1 / 0.05 
0,4 
0.05 

- 
0.4 
0,007 

0,4 

n
o
i
s
s
i
m
e
/
t
n
e
t
n
o
c

n

i

d
e
r
e
d
i
s
n
o
C

s
e
m
e
h
c
s

g
n

i
l
l

e
b
a

l

Y 
Y* 

Y 
Y 
Y 
Y 

Y 
Y* 
Y 
Y 
Y 
Y 
Y 
Y 
Y 

Y 
Y 
Y 

Y 

Product groups (listed in CEN/TCs) 

Aluminium and aluminium alloys 
Resilient, textile and laminate floor 
coverings 
Aggregates 
Sanitary appliances 
Round and sawn timber 
Prefabricated reinforced components 
of autoclaved concrete with open 
structure 
Paving units and curbs 
Adhesives 
Surfaces for sport areas 
Precast concrete products 
Gypsum and gypsum based products 
Natural stones 
Plastics 
Suspended ceilings 
Residential solid fuel burning 
appliances 
Pigments and extenders 
Floor screeds and screed materials 
Sealants for joints in building 
construction 
Stretched ceilings 
* Covered by most of the schemes 
** For natural aggregates 

32 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 3: Starting list of relevant ETAGs/EADs 

Title 

REACH article 

Low lambda composite boards 

Gypsum plasterboard for load bearing 
applications 
Pre-fabricated compressed mineral 
wool boards with organic/inorganic 
finish and specified fastening system 
Mechanically jointed solid wood slab 
element for use as structural element 
in buildings 
Solid wood slab element for use as 
structural element in buildings 
Strength graded structural timber - 
square edged logs with wane-chestnut 
Structural sealant glazing systems 
Internal partition kits 
External thermal insulation composite 
systems with rendering 
Liquid applied roof waterproofing kits 
Systems of mechanically fastened 
flexible roof waterproofing systems 
Timber building kits 
Prefabricated stair kits 
Non load-bearing permanent shuttering 
kits/systems based on hollow blocks or 
panels of insulating material or 
concrete 
Self-supporting translucent roof kits 
Light composite wood-based beams 
and columns 
Three dimensional nailing plates 
Composite light weight panels 
Fire protective products 

Pre-fabricated wood-based loadbearing 
stressed skin panels 
Cold storage premises kits 
Watertight covering kits for wet room 
floors and or walls 

Prefabricated building units 
Concrete frame building kits 
Metal frame building kits 
Fire stopping and fire sealing products 
Fire retardant products 
Inverted roof insulation kits 
Cladding kits 

Y 

Y 

Y 

Y 

Y 

Y 

Y 
Y 
Y 

N 
Y 

Y 
Y 
Y 

Y 
Y 

Y 
Y 
Y for "Fire Protective Board, Slab 
and Mat Products and Kits" (part 1), 
N for parts 2-3 
Y 

Y 
Y for Kits based on flexible Sheets & 
Kits based on inherently watertight 
Boards, N for Liquid Applied 
Coverings with or without wearing 
surface 
Y 
Y 
Y 
Y 
N 
Y 
Y 

EAD/ETAG 
number 
040037-00-
1201 
070001-00-
0504 
090001-00-
0404 

130002-00-
0304 

130005-00-
0304 
130012-00-
0304 
ETAG 002 
ETAG 003 
ETAG 004 

ETAG 005 
ETAG 006 

ETAG 007 
ETAG 008 
ETAG 009 

ETAG 010 
ETAG 011 

ETAG 015 
ETAG 016 
ETAG 018 

ETAG 019 

ETAG 021 
ETAG 022 

ETAG 023 
ETAG 024 
ETAG 025 
ETAG 026 
ETAG 028 
ETAG 031 
ETAG 034 

33 

 
To  allow  a  further  refinement  and  limiting  the  large  scope  of  possible  relevant  construction 
products  for  consumer  exposure  a  prioritization  was  made  based  on  expert  opinion/best 
judgment taken into account the four following factors (see Table 4): direct contact into indoor 
air,  likely  dermal  contact  during  use  phase,  DIY  likely  exposure  (taking  into  account  the 
exposure  time,  exposed  surface  and  manipulations  involvement)  and  its  coverage  by 
content/emissions schemes. Each of the four factors was allocated points (see Table 4). If the 
final  score  -  obtained  by  summing  the  points  allocated  for  each  factor  -  was  equal  or  higher 
than  3  the  construction  product  was  considered  relevant  to  be  included  in  the  further 
assessment steps of this study. 

34 

 
 
Table 4: Product category prioritization table 

r
i
a

r
o
o
d
n

i

t
c
a
t
n
o
c

t
c
e
r
i
D
Y 

Y 
Y 
Y 
Y 
Y 
Y 
Y 
Y 
N 

Y 

Y 
Y 
Y 
N 

Product groups 

Doors, windows, shutters, building hardware 
and curtain walling 
Oil stoves 
Ceramic tiles 
Thermal insulation materials and products 
Wall coverings 
Concrete 
Wood based panels 
Timber structures 
Masonry 
Roof coverings for discontinuous laying and 
products for wall cladding 
Space heating appliances without integral 
heat sources 
Resilient, textile and laminate floor coverings 
Sanitary appliances 
Round and sawn timber 
Prefabricated reinforced components of 
autoclaved aerated concrete or lightweight 
aggregate concrete with open structure 

35 

g
n
i
r
u
d

t
c
a
t
n
o
c

l

a
m
r
e
d

e
s
a
h
p

l

y
e
e
k
s
u
L
High 

i

Low 
High 
Low 
Low 
Low 
High 
Low 
Low 
P high 

P high 

High 
High 
High 
Low 

i

l

)
s
n
o
i
t
a
u
p
n
a
m
&
e
c
a
f
r
u
s

,
e
m

i
t
(

e
r
u
s
o
p
x
e

l

y
e
k

i
l

Y
I
D

Low 

Low 
High 
High 
High 
High 
High 
Low 
High 
High 

Low 

High 
Low 
High 
High 

s
e
m
e
h
c
s
/
s
l
o
c
o
t
o
r
p
Low 

y
b

e
g
a
r
e
v
o
C

Low 
Low 
High 
Low 
Low 
Low 
Low 
Low 
High 

Low 

High 
Low 
Low 
Low 

e
r
o
c
s

l

i

a
n
F
3 

2 
4 
4 
3 
3 
4 
2 
3 
2,5 

2,5 

5 
3 
4 
1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
g
n
i
r
u
d

t
c
a
t
n
o
c

l

a
m
r
e
d

e
s
a
h
p

i

l

y
e
e
k
s
u
L
High 
High 
Low 
Low 
Low 
Low 
Low 
Low 

i

l

)
s
n
o
i
t
a
u
p
n
a
m
&
e
c
a
f
r
u
s

,
e
m

e
r
u
s
o
p
x
e

l

y
e
k

i
l

i
t
(

Y
I
D
High 
Low 
High 
High 
Low 
High 
Low 
High 

y
b

e
g
a
r
e
v
o
C

s
e
m
e
h
c
s
/
s
l
o
c
o
t
o
r
p
Low 
Low 
Low 
Low 
Low 
Low 
Low 
Low 

e
r
o
c
s

l

i

a
n
F
2 
3 
3 
3 
2 
3 
2 
3 

1 for high chance 
of dermal contact 

1 for high 
exposure 

1 if considered in 
more than 9 
protocols/schemes  

Considered 
relevant if ≥ 3 

0 for low exposure  0 if only 

considered in <9 
protocols/schemes 

0.5 for 
potentially high 
chance of dermal 
contact 
0 for low chance 
of dermal contact 

r
i
a

r
o
o
d
n

i

t
c
a
t
n
o
c

t
c
e
r
i
D
N 
Y 
Y 
Y 
Y 
Y 
Y 
Y 

2 if 
direct 
contact 
0 for 
indirect 
contact 

Product groups 

Paving units and curbs 
Surfaces for sport areas 
Precast concrete products 
Gypsum and gypsum based products 
Natural stones 
Suspended ceilings 
Residential solid fuel burning appliances 
Stretched ceilings 

POINTS ALLOCATED 

36 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Upon  request  by  the  Commission  the  product  categories  terrace  decking  and  playground 
surfaces  are  added  to  the  selection;  hence  the  concern  for  dermal  exposure  of  children  to 
outdoor  construction  articles  is  also  addressed.  There  is  no  Mandate  addressed  to  CEN  for 
covering Terraces and Playgrounds38. These articles are not covered by CEN TC 217 (Surfaces 
for sport areas) which covers only indoor surfaces for multi-sports use. 

The  prioritization  finally  led  to  14  construction  product  (article)  categories  for  the  market 
analysis in task 1.2. The final list is shown in Table 5.  

Note that some products categories listed in Table 5 may cover both articles and mixtures, e.g. 
Thermal  insulation  materials  (example:  Spray  Polyurethane  Foam  (SPF)  insulation,  sub-
chapter  5.1.5  CMR  Market  survey  report  in  Annex  2),  Concrete  (&  cement)  and  Gypsum  and 
gypsum  based  products  (example:  Plaster  powders,  sub-chapter  12.1.2  CMR  Market  survey 
report). 

Table 5: List of product categories for the market study 

# 

Product category 

1 
   1a 
   1b 
2 
   2a  
   2b 
3 
4 
5 
  5a 
  5b 
  5c 
6 
7 
8 
8a 
8b 
9 
10 
11 
12 
13 
14 

Doors, windows, shutters, building hardware and curtain walling 
Doors and windows 
shutters, building hardware and curtain walling 
Ceramic based products 
Ceramic based products: tiles 
Ceramic based products: Sanitary appliances 
Thermal insulation materials and products 39 
Wall coverings 
Concrete and concrete products39 
Concrete 
Precast concrete products 
Admixtures for concrete, mortar and joints 
Wood-based panels 
Masonry 
Floor coverings  
Resilient, textile and laminate floor coverings 
Round and sawn timber (for parquet flooring) 
Surfaces for sport areas 
Gypsum and gypsum based products39 
Suspended ceilings 
Stretched ceilings 
Terraces 
Playgrounds 

38 Only the product group terrazzo tiles for internal and external use is currently covered by CEN/TC 229 

39 Within these product categories some products are articles, others are mixtures  

37 

 
                                           
 
 2.2 TASK 1, ACTIVITY 1.2: MARKET SURVEY OF CONSTRUCTION PRODUCTS  

The full report on the market survey is confidential (see Annex 2). 

A. Context 

The  construction  industry  provides  up  to  20  million  direct  jobs  and  contributes  with  about  10 
%  to  the  EU‘s  GDP.  This  sector  is  relevant  for  job  creation,  drives  economic  growth,  and 
provides solutions to address climate, and energy challenges. 

The construction sector also faces increasing challenges related to its environmental impact, in 
particular  energy  and  water  consumption  as  well  as  CMR  substances  contained  in  some 
products. 

In order to evaluate the quantities produced/sold on the European market, this study includes 
a market survey for the construction products identified under activity 1.1. 

The objectives of this market survey were:  

-  To describe products, sub-products and materials and identify key stakeholders; 
- 

For  each  product  category,  to  gather  market  data  regarding  the  consumption  and 
identify major trends affecting the market 

The scope of this market analysis encompassed the following product categories:   

-  Doors and windows 
-  Ceramic based products 
-  Thermal insulation products 
-  Wall coverings 
-  Concrete and cement 
-  Wood-based panels 
-  Masonry 
Flooring 
- 
-  Surfaces for sport areas 
-  Gypsum and gypsum based products 
-  Suspended ceilings 
-  Stretched ceilings 
-  Terraces 
-  Playgrounds 

Each category has been divided into several sub-categories: in total, 60 sub-categories were 
analysed.  

38 

 
 
 
 
 
B.  Methodology 

In  order  to  carry  out  this  market  survey,  the  methodology  followed  has  been  based  on  two 
distinct phases: 

-  Documentary  research:  this  phase  was  intended  to  gather  the  relevant  public 
documentation by consulting sources such as the Internet, existing market studies and 
European databases (EuroStat, Prodcom, etc.). This research allowed CIDE-SOCRAN to 
obtain general data on  the concerned product  categories as well as an initial overview 
of the main stakeholders in the field.  

-  Qualitative  survey:  the  aim  was  to  contact  the  reference  stakeholders  in  order  to 
validate  the  assumptions  of  the  quantification  of  the  market  and  the  distribution  by 
product  and  building  type.  This  phase  also  allowed  CIDE-SOCRAN  to  gain  an 
understanding of the supply chains and distribution networks.  

During  this  market  survey,  more  than  15  associations,  federations  or  companies  have  been 
contacted.  

Based  on  this  methodology,  reliable  information  has  been  found  for  most  of  the  product 
categories. However, the research faced some major challenges: 

-  Geographic  scope:  depending  on  the  source,  the  gathered  market  information 
addresses  different  geographical  areas:  European  Union,  Western  Europe,  European 
Economic  Area  and  even  undefined  “Europe”.  Even  though  the  data  were  refined  in 
order  to  provide  a  picture  as  homogeneous  as  possible,  the  reader  must  be  aware  of 
that limitation when comparing the volumes between categories/ products.  

-  Unavailable  information:  for  some  product  categories,  public  information  was  not 

available or could not be validated as a reliable source; 

-  Cooperation  with  official  professional  organizations:  14  official  European  Federations 
were  contacted.  Unfortunately,  only  6  accepted  to  participate  and  shared  reliable 
market data and analysis. The others declined to participate for the following reasons: 

o  Not willing to share information for free; 
o  Lack or absence of internal information; 
o  Reluctance to participate to this market study.  

-  Heterogeneous  information:  depending  on  the  source,  market  data  covers  production 
or/and  consumption.  The  volumes  are  also  expressed  in  different  metrics:  square 
meters, cubic meters, tons and even monetary volumes. 

These difficulties made it impossible to gather information for 3 product categories (stretched 
ceilings, wall coverings and playgrounds).  

C.  Highlights 

The following table (Table 6) highlights the main findings of the market analysis. Regarding the 
evolution, we relied on existing market analysis to give a forecast for the years to come.  

39 

 
 
 
 
 
Table 6: Main findings of the market analysis, and forecast of a near-future evolution 

Main product category 

Doors & windows 

Sub-product 

Interior Doors 

Windows 

Ceramic tiles 

Covered area 

Type of data 

Western Europe 

Europe 

Sales 

Sales 

Year 

2013 

Volumes 

Recent evolution 

25.7 M 

 

20042005 

115-125 M 

Europe 

Consumption 

2010 

1,49 B m2 

Ceramic based products 

Bricks and roof tiles 

Europe 

Consumption value 

2013 

5.34 B € 

Sanitaryware 

Europe 

Consumption value 

2013 

1.49 B € 

Glasswool 

Stonewool 

Thermal insulation 
materials and products 

Expanded Polystyrene (EPS) 

Extruded Polystyrene Foam (XPS) 

Polyurethane Foam (PUR) 

Others 

Natural products 

Wall papers 

Wall coverings 

Fiberglass wall papers 

Panelling 

Cement 

Europe 

Europe 

Europe 

Europe 

Europe 

Europe 

Europe 

/ 

/ 

/ 

Demand 

Demand 

Demand 

Demand 

Demand 

Demand 

/ 

/ 

/ 

/ 

2012 

2012 

2012 

2012 

2012 

2012 

/ 

/ 

/ 

/ 

75.9 M m3 

34.5 M m3 
50.48 M m3 

11.94 M m3 
18.49 M m3 
1.35 M m3 

/ 

/ 

/ 

/ 

EUR28 

Consumption 

2013 

139 M tons 

Concrete & cement 

40 

Concrete (generic) 

Europe 

Production 

2013 

338 M m³ 

Precast concrete 

Europe 

Production 

2013 

84 M m³ 

Ready-mixed concrete 

Europe 

Production 

2013 

217 M m³ 

 
 
(based on previous 
years) 
  
(based on previous 
years) 
 
(based on previous 
years) 
 

 

 

 

 

 

 

/ 

/ 

/ 
 
(based on previous 
years) 
 
(based on previous 
years) 
 
(based on previous 
years) 
 
(based on previous 
years) 

 
 
Main product category 

Sub-product 

Covered area 

Type of data 

Year 

Volumes 

Concrete to be mixed 

Europe 

Production 

2013 

50.7 M m³ 

Recent evolution 
 
(based on previous 
years) 

Wood-based panels 

Masonry 

Admixtures for concrete, mortar and 
grout 

OSB 

Plywood 

Glulam 

MDF 

Particle boards 

Hardboard 

Masonry units 

Stone 

Mortar for masonry 

Europe 

Europe 

Europe 

Europe 

Europe 

Europe 

Europe 

Europe 

Europe 

Europe 

Sales 

2013 

39.2 M tons 

Production 

Consumption 

Consumption 

Production 

Consumption 

Production 

Sales 

Consumption 

2013 

2013 

2009 

2013 

2013 

2013 

2013 

2008 

6 M m3 

7.22 M m3 
3.8 M m3 

14.5 M m3 
33.5 M m3 
3.8 M m3 

59.1 M tons 

22.97 M 
tons 

Sales 

2013 

39.2 M tons 

PVC (resilient) 

Europe 

Consumption 

2011 

430.5 M m² 

Linoleum (resilient) 

Europe 

Consumption 

2011 

29 M m² 

Rubber (resilient) 

Europe 

Consumption 

2011 

22.7M m² 

Flooring 

Cork flooring (resilient) 

Europe 

Consumption 

2011 

11.2 M m² 

Laminate flooring 

Europe 

Consumption 

2011 

392 M m² 

Wood flooring/ parquet 

Europe 

Consumption 

2012 

87 M m² 

Ceramics 

Western Europe 

Consumption 

2012 

655.7 M m² 

/ 

 

 

 

 

 

 

/ 

/ 

/ 
 
(based on previous 
years) 
 
(based on previous 
years) 
 
(based on previous 
years) 
 
(based on previous 
years) 
 
(based on previous 
years) 
 
(based on previous 
years) 
 
(based on previous 
years) 

41 

 
Recent evolution 
 
(based on previous 
years) 

/ 

/ 

/ 

/ 

/ 

/ 

/ 

/ 
 
(based on previous 
years) 
 
(based on previous 
years) 
 
(based on previous 
years) 

Main product category 

Sub-product 

Covered area 

Type of data 

Year 

Volumes 

Surfaces for sports area 
(outdoor) 

Surfaces for sports area 
(indoor) 

Artificial turf (synthetic) 

Natural turf 

Mineral flooring 

Wood 

PVC 

PU 

Rubber 

Linoleum 

Others (VCT) 

EU 

/ 

/ 

Europe 

Europe 

Europe 

Europe 

Europe 

Europe 

Consumption 

2012 

31.76 M m² 

/ 

/ 

Trade 

Trade 

Trade 

Trade 

Trade 

Trade 

/ 

/ 

2010 

2010 

2010 

2010 

2010 

2010 

/ 

/ 

11.2 M m² 

6 M m² 

2.3 M m² 

1.15 M m² 

0.92 M m² 

1.38 M m² 

Plasterboards (for walls and ceilings) 

Europe 

Consumption 

2013 

1,9 M m² 

Gypsum and gypsum 
based products 

Suspended ceilings 

Stretched ceilings 

Wet felt 

Soft felt 

Gypsum ceiling tiles 

Metal 

PVC sheets 

Tropical wood decking 

Terraces 

Wood plastic composite (WPC) 

Playgrounds 

42 

Concrete 

Synthetic 

Plaster powders 

Europe 

Consumption 

2013 

5 M tons 

Gypsum blocks 

EU 

Consumption 

2013 

20 M m² 

Gypsum ceiling tiles 

Europe 

Production 

Europe 

Europe 

Europe 

Europe 

/ 

Europe 

Europe 

/ 

/ 

Sales 

Sales 

Sales 

Sales 

/ 

Imports 

Production 

/ 

/ 

2013 

2009 

2009 

2009 

2009 

/ 

2014 

2012 

/ 

/ 

See 
plasterboard
s 
75.26 M m2 
38.34 M m2 

12.78 M m2 
12.78 M m2 

/ 
457 k m3 

174 k tons 

/ 

/ 

/ 

/ 

/ 

/ 

/ 

/ 

 

/ 

/ 

 
 
 
D. Conclusion 

Even  though  the  collected  information  was  not  homogeneous,  this  survey  provides  a  good 
picture  of  the  volumes  manufactured  and/  or  installed  in  Europe.  It  has  to  be  noted  that  the 
information  was  often  more  comprehensive  in  concentrated  industries  dominated  by  big 
players  (e.g.  for  gypsum,  cement  and  concrete).  In  fragmented  industries  such  as  floorings, 
doors  and  windows,  good  quality  information  was  more  difficult  to  find  and  hence,  market 
research  firms  are  quite  active  to  sell information  for  a  high  price.  However,  the  approach  of 
crosschecking  information  from  multiple  sources  helped  to  address  those  more  difficult 
categories.   

Still, not all categories could have been properly covered: 

•  Wall coverings: no information available at all (among the sources used); 
•  Stretched ceilings: emerging market with no data available in the public domain or from 

the professional organizations. 

•  Playgrounds: serious doubts about whether this information really exists to date. 

43 

 
 
 
CHAPTER 3  CMR  SUBSTANCES  THAT  ARE  LIKELY  TO  BE  PRESENT  IN 
CONSTRUCTION  ARTICLES,  AND  OVERVIEW  OF  LEGISLATION 
RESTRICTING CMR SUBSTANCES IN CONSTRUCTION PRODUCTS 

 3.1 ACTIVITY  2.1:  CMR  (CAT.  1A  AND  1B)  SUBSTANCES  PRESENT  IN 

CONSTRUCTION ARTICLES 

3.1.1 OBJECTIVE 

The  objective  of  this  task  was  to  identify  CMR  1A/1B  substances  that  are  contained  in 
construction  articles  present  on  the  market  in  the  EU,  and,  where  possible,  to  identify  the 
technical function of these CMR 1A/1B substances in these articles.  

3.1.2 METHODOLOGY AND RESULTS  

A  list  of  substances  for  which  there  is  evidence  that  they  are  present  in  or  released  from 
construction  materials  was  compiled,  based  on  consultation  of  various  sources.  It  was 
examined  which  substances  in  this  list  have  CMR  1A/1B  properties.  These  results  correspond 
with the overall aim of this task which was to compile a list of CMR 1A/1B substances that are 
likely to be present in construction articles.  

Activity 2.1.1: Inventory of CMR substances with a harmonized classification or self-classified 

The EU Classification & Labelling Inventory available on ECHA’s website40 contains information 
on  substances  with  a  harmonised  classification  and  thus  included  in  Annex  VI  of  the  CLP 
Regulation, as well as information on self-classification provided in REACH registration dossiers 
and  C&L  notifications.  The  inventory  was  searched  by  applying  selection  criteria  for  Health 
Hazard  (codes:  Carc.  1A;  Carc.  1B;  Muta.  1A;  Muta.  1B;  Repr.  1A;  Repr.  1B).  The  following 
order of priority was given to classification:  
•  1st priority: Harmonised classification 
• 

In  absence  of  harmonized  classification:  notified  classifications  (=  self-classifications), 
with priority to: green-flagged ‘Joint entries’ 

•  Other notified classifications were considered in case there was no flagged joint entry  

The  Classification  &  Labelling  Inventory  was  extracted  by  applying  criteria  for  Health  Hazard 
relevant for CMR 1A/1B properties (codes: Carc. 1A; Carc. 1B; Muta. 1A; Muta. 1B; Repr. 1A; 
Repr.  1B.  The  resulting  list  (>  7800  hits)  was  used  to  verify  the  substances  present  in  or 
released from construction articles for CMR 1A/1B properties. 

40 http://echa.europa.eu/information-on-chemicals/cl-inventory-database/ 

44 

 
 
 
 
 
 
 
 
                                           
 
Activity 2.1.2: inventory of CMR substances present in construction articles 

Several  complementary  approaches  were  followed  to  identify  CMR  substances  present  in 
construction articles: 

•  Construction  materials  emission  database:  Compilation  of  a  list  of  substances 
released  from  construction  articles  into  indoor  air;  gathered  from  past  or  on-going 
research  projects  (e.g.  BUMA)  in  the  field  of  emission  of  volatile  organic  substances 
(VOC);  this  list  of  VOC  substances  was  subsequently  screened  for  CMR  1A/1B 
classification. 

•  Construction materials health based evaluation schemes for building materials: a 
list of substances included in emission evaluation criteria from construction articles into 
indoor  air;  these  lists  are  established  in  the  framework  of  voluntary  or  mandatory 
evaluation  of  VOC  emission  from  building  materials  (list  of  the  EU  working  group 
deriving and recommending EU-wide harmonised health-based reference values for the 
assessment  of  product  emissions,  based  on  the  so-called  ‘Lowest  Concentration  of 
Interest’ (LCI) concept, hereafter called the EU-LCI list41; list of the German Committee 
for  Health-Related Evaluation of Building Products, hereafter called the AgBB list); this 
list was subsequently screened for CMR 1A/1B classification.  

•  List of CMR 1A/1B substances in construction articles retrieved from article notification 

dossiers available at the website of ECHA 42.  

•  List of CMR substances in construction articles retrieved from substance registration 
dossiers  available  at  the  website  of  ECHA.  In  accordance  with  Art.  7(6)  REACH,  the 
notification obligation under Art. 7(2) does not apply if the substance has already been 
registered  fort  that  use  (i.e.  in  an  article).  Therefore  a  search  was  performed  on  the 
use description in the registration dossiers. Substances were selected by their sector 
of  use  and  environmental  release  categories  (ERCs),  according  to  the  Use  Descriptor 
System  (REACH  guidance  R.12 43).  The  information  was  gathered  from  the  ECHA 
dissemination website44. 

•  REACH  Article  33  Requests  sent  to  manufacturers  and  resellers  of  construction 

• 

• 

• 

articles regarding the presence of SVHCs in concentrations > 0.1 %. 
Identification  of  CMR  substances  in  construction  articles  in  restriction  dossiers, 
retrieved from the website of ECHA 45. 
Identification  of  authorized  use  of  Annex  XIV  CMR  substances  in  construction  articles, 
retrieved from the website of ECHA 46. 
Information  retrieved  from  EU  Risk  Assessment  Reports  of  CMR  1A/1B  substances 
delivered  under  the  Council  Regulation  (EEC)  No.  793/93  (Existing  Substance 
Regulation).  

It is noted that the first type of database (e.g. BUMA emission database) reflects the emissions 
(release)  of  CMR  substances  from  construction  products,  while  the  REACH  data  sources 
(notifications,  registrations,  restrictions)  inform  about  the  presence  in  and/or  use  of 
substances for the production of construction articles. However, it is not always clear whether 
a substance used in the production of an article is still present in the article itself, or whether 
the  substance  was  released  or  reacted  with  other  substances  during  the  production  process, 
and thus is as such not present in the article. Hence, the use of a substance for producing an 
article  is  used  as  a  proxy  for  the  presence  of  substance  of  an  article.  This  assumption  will 
need to be verified for each individual case (Chapter 4).  

41 http://www.eu-lci.org/EU-LCI_Website/Home.html  
42http://echa.europa.eu/information-on-chemicals/candidate-list-substances-in-articles-table 
43 http://echa.europa.eu/guidance-documents/guidance-on-reach 
44 http://echa.europa.eu/information-on-chemicals/registered-substances 
45 http://echa.europa.eu/regulations/reach/restriction 
46 http://echa.europa.eu/regulations/reach/authorisation 

45 

 
 
                                           
 
Each of these approaches listed above is discussed more in detail in the following paragraphs.  

3.1.2.1  CONSTRUCTION MATERIALS EMISSION DATABASE 

We took benefit from an existing database ‘BUMA’ containing emission rates of Volatile Organic 
Substances  (VOCs)  from  construction  articles  and  products.  The  BUMA  database  has  been 
developed  during the  EU  funded  7th  Framework  Project  ‘Prioritization of  Building  Materials  as 
indoor  pollution  sources’  (BUMA) 47  (2003-2008).  The  BUMA  project  aspired  to  gain  a  better 
understanding of the sources of hazardous compounds existing in the indoor environment and 
play a key role in the determination of the well-being and comfortable living of the occupants. 
The outputs of the BUMA project aimed to be used by policy makers, health professionals and 
building material producers in the European Union. 

The BUMA database brings together emission rates from construction products covered by the 
Construction  Product  Directive.  The  database  contains  emission  data  from  various  individual 
scientific reports and publications reviewed during the project, and data generated during the 
BUMA project.  

The BUMA database contains (VOC) emission data for:  

•  adhesives (including flooring adhesives) 
•  gypsum products and plaster boards 
• 
• 

internal and external wall ceiling finishes  
thermal insulation products (all construction insulations, not insulations as (part of) wall 
or ceiling materials) 
•  wood based panels 
•  paints and varnishes  
•  Flooring materials (PVC flooring, textile, laminate...) 

The  BUMA  database  contains  emission  data  for  about  350  construction  products  and  articles. 
For each material in the database, the emission rate (expressed as µg/h/m² of  material) s is 
recorded,  for  one  or  more  time  intervals  following  start  of  the  emission  chamber  test 
(generally from 1 to 28 days after onset of the test).  

Given  the  age  of  the  studies  included  in  the  BUMA  database  (namely  before  2008),  it  is 
questionable  whether  the  BUMA  database  reflects  adequately  the  nowadays  market  of 
construction materials in the EU. Nevertheless, since no other more recent database exists, it 
serves as the best available source of information of VOC emissions.  

It  is  expected  that  (recent)  legislations  on  emissions  from  construction  articles  (e.g.  flooring 
materials in Germany and Belgium (see 3.2.2) will be a significant driver for the generation of 
more  recent  and  thus  more  relevant  data  for  the  EU  market.    However,  it is  anticipated  that 
these data will have a confidential character, and not become publically available. 

The  BUMA  database  does  not  provide  details  on  the  brand  of  materials,  where  and  how  the 
materials  have  been  purchased  (randomly  or  in  case  of  concern),  and  neither  product 
ingredient or labelling information. However, it gives a general statement saying that materials 
in BUMA Database present building materials commonly used in Europe.  

It  should  be  noted  that  the  BUMA  database  is  the  result  of  a  scientific  research  programme, 
and  therefore  does  not  represent  a  regularly  updated  inventory  of  CMR  releases  from 
construction  articles  on  the  market  (which  would  be  the  case  in  a  monitoring  campaign  from 
authorities/inspections) – so, the BUMA database gives rather a snapshot of materials present 
on  the  EU  market,  and  not  an  overall  picture  of  emissions  of  (CMR)  substances  from 

47 http://www.uowm.gr/bumaproject/) 

46 

 
 
                                           
 
construction articles on the market. In addition, it only captures CMR substances which fit into 
the analytical frame of the available testing methods (e.g. CEN/TS 16516). They cover mainly 
VOCs;  but  are  not  suitable  to  identify  several  semi-volatile  organic  compounds  (SVOCs)  and 
non-volatile substances.  

Further, it should be noted that it is unknown whether the emissions from the BUMA database 
come from products containing a substance above or below 0.1 %. It cannot be excluded that 
emissions  originate  from  articles  containing  <  0.1  %  CMR  (and  thus  not  falling  under  the 
notification obligations of REACH Article 33). 

In  total,  the  BUMA  database  contains  emissions  of  more  than  400  substances  released  by  at 
least  one  construction  material  from  the  database  (database  contains  350  construction 
products  and  articles).  All  substances  in  this  database  were  screened  for  CMR  properties  (by 
overlaying  with the  C&L  inventory  of  ECHA  from  task  2.2.1).  Of  the  400  emitted  substances, 
only  a  minority  have  CMR  1A/1B  properties.  Twelve  of  these  substances  have  a  harmonized 
CMR  1A/1B  classification;  from  the  substances  without  harmonized  classification, none  of  the 
substances is self-classified as CMR in the joint entries; for one substances without harmonized 
classification,  and  without  a  joint  entry,  at  least  one  of  the  notifiers  classified  the  substances 
as Repr 1B (alpha-terpinene).  

Available information  on  emission  of  CMR  substances  1A/1B  from  articles  was  extracted  from 
the BUMA database and reported in Table 7.   

47 

 
Table 7: List of CMR 1A/1B substances released from at least one building article in the BUMA database 

Substance 

CMR classification 

2-Ethoxyethanol 

CMR 1A/1B according to 
harmonized classification 

2-Ethoxy-ethylacetate  CMR 1A/1B according to 
harmonized classification 

Chloroprene 

CMR 1A/1B according to 
harmonized classification 

N,N-dimethyl-
acetamide 

CMR 1A/1B according to 
harmonized classification 

Dipentyl phthalate 

Dimethyl formamide 

Benzene 

CMR 1A/1B according to 
harmonized classification 

CMR 1A/1B according to 
harmonized classification 

CMR 1A/1B according to 
harmonized classification 

Trichloroethene 

Diisobutyl phthalate 

Dibutyl phthalate  

CMR 1A/1B according to 
harmonized classification 

CMR 1A/1B according to 
harmonized classification 

CMR 1A/1B according to 
harmonized classification 

48 

Number of 
materials in BUMA 
database emitting 
substance 

4 

10 

2 

1 

3 

1 

48 

5 

6 

8 

Material groups* 

Emission rates** 

Cat  8a:  Resilient,  textile  and  laminate 
floor coverings 
Cat 6: wood based panels 
Cat 8a: Resilient, textile and 
laminate floor coverings 

Cat 8a: Resilient, textile and 
laminate floor coverings 

0 – 7.7 µg/h/m² 

4 – 20 µg/h/m² 

2 – 120 µg/h/m² 

Cat 10: Gypsum and gypsum based 
products 

1 – 6 µg/h/m² 

Cat 4: Wall coverings 

0.8 – 2 µg/h/m² 

Cat 8a: Resilient, textile and 
laminate floor coverings  

10 µg/h/m² 

Cat  8a  :  Resilient,  textile  and 
laminate floor coverings 
Cat 10: Gypsum and gypsum based 
products 
Cat 8b: Round and sawn timber 
Cat 6: Wood based panels 
Cat 4: Wall covering 
Cat  8a:  Resilient, 
laminate floor coverings 
Cat 6: Wood based panels 
Cat 4: Wall covering 

textile  and 

0.1 – 46 µg/h/m² 

1 – 17 µg/h/m² 

0.1 – 0.5 µg/h/m² 

Cat 4: Wall covering 

1 – 37 µg/h/m² 

 
 
Substance 

CMR classification 

1-Methyl -2- 
pyrrolidone 

Alfa-terpinene 

CMR 1A/1B according to 
harmonized classification 

(no joint entries); 1 out 
of 18 separate 
classification 
submissions have Carc 
1B classification 

Number of 
materials in BUMA 
database emitting 
substance 

Material groups* 

Emission rates** 

10 

1 

Cat  8a:  Resilient, 
laminate floor coverings 

textile  and 

0 – 82 µg/h/m² 

Cat 6: Wood based panels 

35 – 360 µg/h/m² 

Formaldehyde 

CMR 1A/1B according to 
harmonized classification 

140 

1 -640 µg/h/m² 

textile  and 

Cat  8a:  Resilient, 
laminate floor coverings 
Cat 10: Gypsum and gypsum based 
products 
Cat 8b: Round and sawn timber 
Cat 6: Wood based panels 
Cat 4: Wall covering 
Cat 3: Thermal insulation materials 

*categories of material groups as identified in task 1 (Table 5) 

**range in emission rates represent the range in different materials and range in duration of emission test  

49 

 
 
Possible health implications of these emissions will be further elaborated in task 3 and 4 of this 
study.  

As  a  very  brief  guidance,  substances  classified  as  CMR  1A/1B  and  present    in  the  list  (Table 
21)  of  the  regulated  carcinogenic  VOCs  (available  in  the  draft  standard  prEN  1651687  on  the 
assessment  of  release  of  dangerous  substances  from  construction  products  and  the 
determination of emissions into indoor air (for the above list: this is the case for benzene and 
trichloroethylene)  should  not  exceed  a  level  of  1  µg/m³  in  a  reference  room  (after  28  days 
testing)  .  This  corresponds  to  a  maximum  emission  rate  of  2  µg/m²/h  at  day  28  (conversion 
concentration  into  emission  rate  by  accounting  for  a  loading  rate  of  1  m²/m³  (applicable  for 
walls  according  to  CEN/TS  16516  and  an  air  exchange  rate  of  0.5/h  (according  to  CEN/TS 
16516)  

However,  for  other  substances  on  the  list  (e.g.  formaldehyde)  emission  rates  below  200 
µg/m²/h  (for  formaldehyde)  could  be  considered  as  of  low  concern  for  health  since  this 
emission  rate  corresponds  for  a  loading  rate  of  1m²/m³  and  ventilation  rate  of  0.5/h  to 
reference room concentrations below 100 µg/m³ (which is the health based criteria according 
to  the  AgBB  protocol  –  see  further  in  3.1.2.2).  Analogously,  emission  rates  below  16  and  22 
µg/m²/h (respectively for 2-ethoxyethanol and 2-ethoxy ethylacetate) could be considered as 
of  low  concern  for  health  since  this  emission  rate  corresponds  for  a  loading  rate  of  1m²/m³ 
and  ventilation  rate  of  0.5/h  to  reference  room  concentrations  below  respectively  8  and  11 
µg/m³  (which  is  the  health  based  criteria  according  to  the  AgBB  protocol  –  see  further  in 
3.1.2.2). 

Several of the CMR substances in table 7 are released from only one or a few materials (e.g. 
alfa-terpinene;  dimethyl  formamide;  N,N-dimethyl  acetamide;  chloroprene)  in  the  BUMA 
database and these emissions from this type of construction materials are therefore assumed 
to be rather an exception than a rule. Other substances (benzene and formaldehyde) seem to 
be  released  from  a  substantial  fraction  of  materials  in  the  BUMA  database:  formaldehyde 
appeared to be released from 140 construction materials in the BUMA database, (range: 1- 60 
µg/h/m² - median: 19 µg/m²) and emissions come from a broad range of construction article 
types.  

Also benzene appeared to be released from 48 construction articles in the BUMA database. For 
a substantial fraction of these cases, the emission levels are low from an analytical perspective 
of  view  (e.g.  median  release:  2.3  µg/m²/h),  and  in  these  ranges,  emission  levels  might  be 
affected by analytical artefacts48; however, for another fraction of the materials the emissions 
are above background levels (P7549 release: 6 µg/m²/h) and cannot be ascribed to analytical 
artefacts.  

The  relative  large  numbers  of  emission  data  for  benzene  (and  the  median  value  of  2.3 
µg/m²/h) are rather surprising, since these levels are above the criteria for benzene according 
to the prEN 16516 50; and thus are not compliant to legal frameworks where EU member states 
having  implemented  the  compliance  to  prEN  16516  for  maximum  emissions  of  VOCs  and 
SVOCs  from  construction  articles  (i.e.  Belgium  for  flooring  materials;  Germany  for  flooring 
materials  and  decorative  wall  paper),  where  there  is  a  maximum  emission  level  of  CMR 
substances 1A/B set at 1 µg/m³ (test chamber at 28 days).  However, these emission data for 
benzene  date  from  the  period  before  legislation  on  maximum  emissions  of  VOCs  and  SVOCs 
from construction articles in Germany and Belgium, and may not reflect the current situation.  

48 Annex F of prEN 16516, May 2015 

49 P75 is the 75th Percentile of the available emission values from the database 

50  Draft  standard  for  Construction  products  -  Assessment  of  release  of  dangerous  substances  -  Determination  of 
emissions into indoor air 

50 

 
 
                                           
 
3.1.2.2  CONSTRUCTION MATERIALS HEALTH BASED EVALUATION SCHEMES 

The list of substances included in emission schemes setting evaluation criteria for construction 
articles (AgBB and EU-LCI51) into indoor air has been screened for CMR 1A/1B classification.  

The  AgBB  evaluation  criteria  have  been  developed  in  the  framework  of  the  national  building 
code in Germany. Some special requirements  of this code apply to selected building products 
used  indoors.  In  particular,  floor  coverings  must  be  tested  for  their  emissions  of  volatile 
organic  compounds  (VOCs)  and  must  meet  the  requirements  of  an  evaluation  scheme 
administered  by  the  German  Committee  for  Health-Related  Evaluation  of  Building  Products 
(AgBB).  This  AgBB  scheme  is  titled  “Health-related  Evaluation  Procedure  for  Volatile  Organic 
Compounds Emissions (VOC and SVOC) from Building Products”. 

The  AgBB  evaluation  scheme  established  so-called  “Lowest  Concentrations  of  Interest”  (LCIs) 
for a long list (about 200 compounds and compound groups) of VOC substances. The definition 
of  VOCs  in  this  context  is  ‘substances  within  a  chromatographic  retention  time  range  of  n-
hexane  through  n-hexadecane  (C6  –  C16)  plus  semi-volatile  organic  compounds  (SVOCs) 
within a retention time range of C16 through C22. 

The  LCI  value  is  the  lowest  concentration  above  which,  according  to  best  professional 
judgement,  the  pollutant  may  have  some  effect  on  people  in  the  indoor  environment 
(definition  according  to  ECA  Report  No.18,  1997).  In  practice,  an  LCI  value  represents  the 
maximum  concentration52  allowed  to  be  measured  in  a  test  chamber  28  days  after      the 
material has been placed in a test chamber.     

The EU-LCI evaluation criteria result from an EU harmonization of national LCI values (mainly 
Germany  and  France)  which  was  elaborated  by  the  EU-LCI  working  group,  and  covers  the 
same list of substances as in the AgBB schema. 

A substance being present in the AgBB /EU-LCI list does however not indicate how widespread 
the  emission  of  these  substances  from  construction  materials  are;  rather,  it  stipulates  the 
maximum  tolerable  emission  levels  of  VOCs  to  the  indoor  air  environment  from  a  health 
perspective point of view.  

From  the  total  of  about  200  substances,  three  of  the  AgBB/  EU-LCI  substances  (namely  2-
methoxy  ethanol,  2-ethoxyethanol,  2-ethoxyethylacetate)  are  classified  as  CMR  1A/1B 
(according  to  harmonized  classification),  with  the  EU-LCI  value  for  2-methoxy  ethanol  =  3 
for  2-
µg/m³;  EU-LCI  value 
ethoxyethylacetate  =  11  µg/m³.  The  AgBB  criteria  for  emissions  of  VOC  with  CMR  1A/1B 
properties are identical to the EU-LCI criteria.  It is noted that formaldehyde (classified as Carc 
1B) is not (yet) included in the EU-LCI list, and thus does not contribute to the calculation of 
the R-value53 (criteria R < 1) according to the EU-LCI scheme. However, a separate criterion of 
maximum  100  µg/m³  formaldehyde  in  a  test  chamber  after  28  days  is  also  included  in  the 
AgBB evaluation procedure.  

for  2-ethoxyethanol  =  8  µg/m³  and  EU-LCI  value 

51 http://www.eu-lci.org/EU-LCI_Website/Home.html 

52  materials  emissions  expressed  as  a  test  chamber  concentration  (µg/m³)    can  be  converted  to  emission  rates 
(µg/h/m²)  based  on  materials  loading  (surface  area  of  materials  in  test  chamber)  and  ventilation  rate  in  the  test 
chamber 

53The  R  value  is  the  sum  of  the  ratio  of  individual  VOCi  concentrations  to  their  respective  LCIi  values,  i.e.  R  =  Σ 
(Ci/LCIi) of assessable VOCs.  

51 

 
 
                                           
 
3.1.2.3  NOTIFICATION DOSSIERS AVAILABLE AT WEBSITE OF ECHA 

According  Article  7(2)  of  REACH,  producers  and  importers  have  to  notify  to  ECHA  the 
substances listed on the Candidate list which are present in their articles, if both the following 
conditions are met: (i) the substance is present in their relevant articles above a concentration 
of  0.1%  weight  by  weight;  and  (ii)  the  substance  is  present  in  these  relevant  articles  in 
quantities  totaling  over  one  ton  per  year.  Companies  have  to  notify  no  later  than  six  months 
after the inclusion of the substance in the Candidate List 

There  are  two  cases  when  a  notification  will  not  need  to  be  required:  (i)  the  producer  or 
importer  of  an  article  can  exclude  the  exposure  of  humans  and  the  environment  to  the 
substance during normal or reasonably foreseeable conditions of use of the article, including its 
disposal. In these cases, the producers and importers will give appropriate instructions to the 
recipient of the article; and (ii) the substance has already been registered by a manufacturer 
or importer in the EU for that use. 

The REACH website hosts a database with information on Candidate List substances in articles 
(http://echa.europa.eu/information-on-chemicals/candidate-list-substances-in-articles-table). 
This  information  provides  a  list  of  Substances  of  Very  High  Concern  (SVHCs)  included  in  the 
Candidate  List  which  are  present  in  articles  that  are  available  for  consumer  use  on  the  EU 
market. The data is based both on the notifications that companies have submitted to ECHA as 
well as on the information contained in the registration dossiers. 

This information database at the latest update (31 March 2015) contained  a list of 155 SVHC 
substances.  Out  of  these  155,  135  have  CMR  1A/1B  properties  (according  to  harmonized 
classification) and were selected for the purpose of this study.  

For  each  of  these  substances,  it  was  checked  how  many  notifications  have  been  reported  to 
ECHA.  If  at  least  one  notification  was  reported,  the  notification  dossier  was  checked  to  find 
whether  and  which  construction  materials  are  indicated  in  the  dossiers.  For  27  CMR  1A/1B 
substances,  at  least  one  notification  dossier  was  available  at  the  website  of  ECHA.    For 
substances  without  a  notification  dossier,  information  was  retrieved  from  the  registration 
dossiers, which is described in section 3.1.2.4. 

The construction materials mentioned in the notification dossiers have then been classified into 
the categories of task 1.1. The result of this activity is summarized in Table 8. However, it is 
noted  in  several  cases,  the  use  mentioned  in  the  notification  dossiers  does  not  fit  into 
categories of task 1.1. 

In some cases, a use is mentioned for a broad category ‘stone, glass, ceramic articles, plaster’; 
however, it is not clear whether the substance is used in all of the subcategories (mentioned as 
a group), or only in one, two or three of these groups. The group of ‘stone, glass, plaster and 
ceramic  articles,  plaster’  is  quite  broad,  and  can  be  allocated  to  several  categories  (task  1.1 
categories):  

•  Cat 1: Windows, doors, ... 
•  Cat 2: Ceramic based products 
•  Cat 5: Concrete and concrete products  
•  Cat 7: Masonry  
•  Cat 10: Gypsum boards and gypsum products 

When  there  was  doubt  whether  the  substance  was  used  in  all  these  categories,  it  is  marked 
with ‘?’ 

In  summary,  out  of  the  155  SVHC  substances  on  the  Candidate  List,  27  substances  have  a 
CMR 1A or 1B classification and at least one notification of use in articles on the REACH portal 
(articles including but not limited to construction articles). 

For  2  out  of  the  27  substances,  none  of  the  identified  article  uses  was  relevant  for  the 
construction sector (this was the case for trixylyl phosphate, coal tar pitch and).  

52 

 
 
 
For 13 CMR 1A/1B SVHC substances from the notification dossiers, a clear use in construction 
articles was found. This was the case for: bis(2-ethylhexyl)phthalate (DEHP), dibutyl phthalate 
(DBP), aluminosilicate refractory ceramic fibres covered by index number 650-017-00-8 in CLP 
Annex  VI,  diisobutyl  phthalate,  boric  acid,  disodium  tetraborate  anhydrous,  diboron  trioxide, 
orange  lead  (lead  tetroxide),  lead  chromate  molybdate  sulphate  red  (C.I.  Pigment  Red  104), 
tris(2-
lead 
chloroethyl)phosphate and trilead dioxide phosphonate. 

(C.I.  Pigment  Yellow  34), 

sulfochromate  yellow 

chromate, 

lead 

The  technical  function  of  these  CMR  1A/1B  substances  used  in  the  manufacturing  of  these 
construction products is not mentioned in the publicly available part of the notification reports.  

These  13  substances  can  be  divided  into  broad  groups  of  CMR  1A/1B  substances  used  in 
construction articles: on the one hand, several plasticizers are used in plastic articles used in 
the construction sector (e.g. DEHP in flooring coverings, DBP in roll doors), on the other hand, 
several  metal  compounds,  acids  or  oxides  are  used  for  manufacturing  of  stone,  plastic, 
cement, glass and ceramic articles. 

For 2 other substance from the 27 dossiers, the relevance for construction articles is unclear:  
for  lead  monoxide  and  lead  titanium  zirconium  oxide,  the  registration  information  mentions 
use as ‘consumer use of ceramics’ in article category ‘stone, plaster, cement glass and ceramic 
articles’.    However,  its  notification  information  mentions  only  use  in  ‘piezoceramic  sensor’, 
which is not a construction use.  Therefore, it is likely that the use of piezoceramic sensor’ was 
in  the  registration  dossier  (probably)  generalized  to  a  broader  category,  including  uses  in 
construction sector. 

For  another  10  substances  (1-methyl-2-pyrrolidone  (NMP);  benzyl  butyl  phthalate  (BBP); 
zirconia  aluminosilicate,  2,4-dinitrotoluene;  imidazolidine-2-thione;  diarsenic  pentaoxide;  2-
ethoxyethyl  acetate;  1,2-dimethoxyethane;  trichloroethylene  and  N,N-dimethylacetamide)    it 
is  unlikely  but  cannot  be  excluded  that  the  substances  are  used  in  construction  articles.    For 
these  10  substances,    we  could  not    find  a  clear  notification  for  a  use  in  construction  articles 
mentioned  in  the  notification  dossiers.  In  the  section  regarding  the  information  contained  in 
registration  dossiers  (“Registration  Information  on 
identified  uses  related  to  article 
categories”),  the  following  sentence  was    added  in  10  dossiers:  “No  registration  information 
available relating to the use of the substance in articles. The reason may be that the substance 
is not registered, that no Article Category is provided in the registrations for the substance or 
that the identified uses of the registrations have been claimed confidential”. 

In  the  notification  dossier  of  N,N-dimethylacetamide,  the  use 
in  "reprocessing  of 
Spandex/elastane fibre'  is mentioned. Spandex is mainly used for manufacturing of garments 
and not for fibres in construction articles. 

Based  on  this  statement,  it  cannot  be  excluded  that  these  10  substances  are  used  in 
construction  articles.  However,  the  evidence  is  very  weak,  and  it  is  based  on  the  available 
information  not  possible  to  verify  their  presence  in  construction  articles,  and,  if  used  in 
construction  articles  -    it  cannot  be  identified  in  which  types  of  construction  articles  these 
substances  are  used.  Therefore,  these  substances  are  not  taken  forward  to  the  overall list  of 
CMRs  present  in  construction  articles  unless    other  criteria  there  provide  indications  for 
consumer  exposure  (see  further  in  4.5:  e.g.  for  trichloroethylene,  BBP,  1-methyl-2-
pyrrolidone, NMP and N,N-dimethylacetamide). 

53 

 
 
 
 
 
  
Table  8:  Identification  and  classification  of  CMR  1A/1B  substances  in  construction  articles  based  on  screening  of  SVHC  notification  dossiers 
available from the website of ECHA (consulted during April-June 2015) 

Name 

Cat 1:  

Doors,  windows,  shutters, 
building 
and 
curtain walling 

hardware 

Cat 2:  

Ceramic based products 

Cat 3:  

Thermal 
materials and products 

insulation 

Cat 4:  

Wall coverings 

specific article(s)? 

specific article(s)? 

specific article(s)? 

specific article(s)? 

Bis (2-
ethylhexyl)phthalate 
(DEHP) 

yes: 

fences roll doors 
seals for windows, 
doors 
wooden doors 

Dibutyl phthalate 
(DBP) 

Aluminosilicate 
Refractory Ceramic 
Fibres are fibres 
covered by index 
number 650-017-
00-8 in Annex VI 

Diisobutyl phthalate 

Boric acid 

Disodium 
tetraborate 
anhydrous 

Lead titanium 
zirconium oxide 

Diboron trioxide 

54 

yes:   roll doors 

?  

use in stone, plaster, 
cement, glass and 
ceramic articles 

- 

? 

? 

- 

? 

stone, plaster, 
cement, glass and 
ceramic articles 
stone, plaster, 
cement, glass and 
ceramic articles 

stone, plaster, 
cement, glass and 
ceramic articles 

- 

- 

? 

? 

? 

?  

? 

use in stone, plaster, 
cement, glass and 
ceramic articles 

- 

- 

- 

- 

stone, plaster, 
cement, glass and 
ceramic articles 
stone, plaster, 
cement, glass and 
ceramic articles 

yes  service life of 

cellulose insulation 

yes  service life of 

cellulose insulation 

used in piezoceramic 
sensor 

stone, plaster, 
cement, glass and 
ceramic articles 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

 
 
 
  
 
 
  
 
  
 
  
 
 
  
 
 
 
  
  
 
  
 
Name 

Cat 1:  

Doors,  windows,  shutters, 
and 
building 
curtain walling 

hardware 

Cat 2:  

Ceramic based products 

Cat 3:  

Thermal 
materials and products 

insulation 

Cat 4:  

Wall coverings 

specific article(s)? 

specific article(s)? 

specific article(s)? 

specific article(s)? 

1-Methyl-2-
pyrrolidone (NMP) 

Orange lead (lead 
tetroxide) 

- 

Lead chromate 
molybdate sulphate 
red (C.I. Pigment 
Red 104) 

yes: 

Lead sulfochromate 
yellow (C.I. Pigment 
Yellow 34) 

yes: 

Benzyl butyl 
phthalate (BBP) 

- 

yes  consumer use of 

ceramics 

fences: roll doors 
service life of coated 
articles: stone, 
plaster, cement, 
glass and ceramic 
articles 
fences: roll doors 
service life of coated 
articles: stone, 
plaster, cement, 
glass and ceramic 
articles 

? 

? 

- 

service life of coated 
articles: stone, 
plaster, cement, 
glass and ceramic 
articles 

service life of coated 
articles: stone, 
plaster, cement, 
glass and ceramic 
articles 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

55 

 
 
  
  
 
 
  
 
  
  
 
  
 
  
 
  
 
  
 
Name 

Cat 5:  

Cat 6:  

Concrete  and 
products 

concrete 

Wood-based panels 

Cat 7:  

Masonry 

Cat 8:  

Floor coverings 

specific article(s)? 

specific article(s)? 

specific article(s)? 

specific article(s)? 

Bis (2-
ethylhexyl)phthalate 
(DEHP) 

- 

- 

? 

? 

? 

Dibutyl phthalate 
(DBP) 

Aluminosilicate 
Refractory Ceramic 
Fibres are fibres 
covered by index 
number 650-017-
00-8 in Annex VI 

Diisobutyl phthalate 

Boric acid 

Disodium 
tetraborate 
anhydrous 

Lead titanium 
zirconium oxide 

- 

- 

- 

- 

use in stone, plaster, 
cement, glass and 
ceramic articles 

stone, plaster, 
cement, glass and 
ceramic articles 
stone, plaster, 
cement, glass and 
ceramic articles 

yes:  use of borates in 

plaster/wood 

yes:  use of borates in 

plasterboards and 
wood 

Diboron trioxide 

? 

stone, plaster, 
cement, glass and 
ceramic articles 

56 

- 

- 

- 

- 

? 

- 

? 

? 

- 

? 

yes: 

floor covering made 
by PVC, flooring 
plastic floor tiles 
plastic flooring 
PVC floor coverings 
(cushion vinyl) 

- 

- 

use in stone, plaster, 
cement, glass and 
ceramic articles 

yes:  PVC floor covering 

(cushion vinyl) 

stone, plaster, 
cement, glass and 
ceramic articles 
stone, plaster, 
cement, glass and 
ceramic articles 

stone, plaster, 
cement, glass and 
ceramic articles 

- 

- 

- 

- 

 
 
  
 
  
  
 
  
 
 
 
  
  
 
  
 
 
  
  
 
  
 
 
 
Name 

Cat 5:  

Cat 6:  

Concrete  and 
products 

concrete 

Wood-based panels 

Cat 7:  

Masonry 

Cat 8:  

Floor coverings 

specific article(s)? 

specific article(s)? 

specific article(s)? 

specific article(s)? 

1-Methyl-2-
pyrrolidone (NMP) 

Orange lead (lead 
tetroxide) 

Lead chromate 
molybdate sulphate 
red (C.I. Pigment 
Red 104) 

Lead sulfochromate 
yellow (C.I. Pigment 
Yellow 34) 

Benzyl butyl 
phthalate (BBP) 

? 

? 

- 

- 

- 

- 

- 

yes:  pigments in articles 

? 

(wood) 

yes:  pigments in wood 

? 

articles 

- 

- 

- 

- 

- 

- 

- 

service life of coated 
articles: stone, 
plaster, cement, 
glass and ceramic 
articles 
service life of coated 
articles: stone, 
plaster, cement, 
glass and ceramic 
articles 

service life of coated 
articles: stone, 
plaster, cement, 
glass and ceramic 
articles 
service life of coated 
articles: stone, 
plaster, cement, 
glass and ceramic 
articles 

57 

 
 
  
  
 
  
 
  
  
 
  
 
 
 
  
 
  
 
Name 

Cat 9: 

Surfaces for sport areas 

Cat 10: 

Gypsum and gypsum based 
products 

Cat 11: Suspended ceilings  
Cat 12: Stretched ceilings 
Cat 13: terraces 
Cat 14: playgrounds 

Other construction articles 

specific article(s)? 

specific article(s)? 

specific article(s)? 

tarpaulin covers (as 
roofing) 
shower hoses (sanitary 
appliances- 
insulation and sealing 
materials in air-
conditioning units and heat 
pumps 
tarpaulin covers (roofing) 

Bis (2-
ethylhexyl)phthalate 
(DEHP) 

Dibutyl phthalate 
(DBP) 

Aluminosilicate 
Refractory Ceramic 
Fibres are fibres 
covered by index 
number 650-017-
00-8 in Annex VI 

Diisobutyl phthalate 

Boric acid 

Disodium 
tetraborate 
anhydrous 

Lead titanium 
zirconium oxide 

Diboron trioxide 

- 

- 

- 

- 

- 

- 

- 

- 

58 

- 

- 

? 

use in stone, plaster, 
cement, glass and 
ceramic articles 

yes:  use of borates in 

? 

? 

plaster/wood 
stone, plaster, 
cement, glass and 
ceramic articles 

stone, plaster, 
cement, glass and 
ceramic articles 

- 

- 

- 

- 

- 

- 

- 

- 

 
 
 
  
 
  
  
 
  
  
  
  
  
 
 
  
  
  
  
  
  
  
  
  
 
 
  
  
  
  
  
Name 

Cat 9: 

Surfaces for sport areas 

Cat 10: 

Gypsum and gypsum based 
products 

Cat 11: Suspended ceilings  
Cat 12: Stretched ceilings 
Cat 13: terraces 
Cat 14: playgrounds 

Other construction articles 

specific article(s)? 

specific article(s)? 

specific article(s)? 

- 

- 

? 

? 

- 

- 

- 

- 

- 

- 

service life of coated 
articles: stone, 
plaster, cement, 
glass and ceramic 
articles 
service life of coated 
articles: stone, 
plaster, cement, 
glass and ceramic 
articles 

tarpaurin covers  
(e.g. roofing) 

tarpaulin covers  
(e.g. roofing) 

1-Methyl-2-
pyrrolidone (NMP) 

Orange lead (lead 
tetroxide) 

Lead chromate 
molybdate sulphate 
red (C.I. Pigment 
Red 104) 

Lead sulfochromate 
yellow (C.I. Pigment 
Yellow 34) 

Benzyl butyl 
phthalate (BBP) 

- 

- 

- 

- 

- 

59 

 
 
 
  
 
  
  
  
 
  
  
  
  
  
  
  
 
  
  
Name 

no. of 
notifications  

 EC 
Number 

CAS 
Number 

Classification 

General  
(unspecified materials) 

Carcinogenic  
(article 57 a) 

no consumer use of articles has been indicated in the 
notification dossier; 
 no information on identified uses related to article 
categories is mentioned in the notification dossier 

266-
028-2 

65996-
93-2 

Carcinogenic  
(article 57a) 

231-
846-0 

7758-97-
6 

215-
267-0 

1317-36-
8 

Carcinogenic 
and toxic for 
reproduction 
(articles 57 a 
and 57 c) 
Toxic for 
reproduction 
(Article 57 c) 

204-
826-4 

127-19-5  Toxic for 

reproduction 
(article 57 c) 

no consumer of articles has been indicated in the 
notification dossiers;from the other information regarding 
identified uses related to article categories in the 
notification dossiers, none could be related to the articles 
for use in the construction sector (e.g. plastic articles: 
binding agent for clay pigeons, refractory for steelmaking - 
sliding nozzle plate) 
building material 

piezoceramic sensor  

No consumer use of articles has been identified  
from the other information regarding identified uses related 
to article categories in the notification dossiers, the use in 
"reprocessing of Spandex/elastane fibre' is mentioned. 
Spandex is mainly used for manufacturing of garments; it 
is not clear whether and to what extent Spandex in 
construction sector 

Zirconia 
Aluminosilicate 
Refractory Ceramic 
Fibres are fibres 
covered by index 
number 650-017-00-8 
in Annex VI 
Pitch, coal tar, high 
temp. 

Lead chromate 

Lead monoxide (lead 
oxide) 

N,N-
dimethylacetamide 

2 

2 

2 

2 

2 

60 

 
  
  
Name 

no. of 
notifications  

 EC 
Number 

CAS 
Number 

Classification 

General  
(unspecified materials) 

2,4-Dinitrotoluene 

2 

204-
450-0 

121-14-2  Carcinogenic 
(article 57a) 

Tris(2-
chloroethyl)phosphate 

2 

204-
118-5 

115-96-8  Toxic for 

reproduction 
(article 57c) 

Imidazolidine-2-
thione (2-imidazoline-
2-thiol) 

2 

202-
506-9 

96-45-7 

Toxic for 
reproduction 
(Article 57 c) 

No consumer use of articles has been identified;  
No other information on identified uses related to articles is 
available. The reason may be that the substance is not 
registered, that no Article Category is provided in the 
registrations for the substance or that the identified uses of 
the registrations have been claimed confidential. 
no consumer use of articles has been identified 
from the other information regarding identified uses related 
to article categories in the notification dossiers: the use of 
this substance in the category "stone, plaster, cement, 
glass and ceramic articles" has been mentioned 
No consumer use of articles has been identified 
No other information on identified uses related to articles is 
available. The reason may be that the substance is not 
registered, that no Article Category is provided in the 
registrations for the substance or that the identified uses of 
the registrations have been claimed confidential. 

61 

 
Name 

Cat 1:  

Doors,  windows, 
shutters, 
building  hardware  and curtain 
walling 

Cat 2:  

Ceramic based products 

Cat 3:  

Thermal  insulation 
and 
materials 
products 

Cat 4:  

Wall coverings 

specific article(s)? 

specific article(s)? 

specific article(s)? 

specific article(s)? 

- 

- 

fences: roll doors 

?   Used in piezoceramic sensor 

generalized to 'ceramic articles' in 
dossier.  
Not sure whether this 
generalization is appropriate??? 

used as coating for 
stone, plaster, cement, 
glass and ceramic 
articles 

?  used as coating for stone, plaster, 
cement, glass and ceramic articles 

- 

- 

- 

- 
- 

- 

- 
- 

- 

- 

- 

- 
- 

- 

- 
- 

- 

Zirconia 
Aluminosilicate 
Refractory Ceramic 
Fibres are fibres 
covered by index 
number 650-017-00-8 
in Annex VI 
Pitch, coal tar, high 
temp. 
Lead chromate 
Lead monoxide (lead 
oxide) 

- 

- 

yes: 
- 

N,N-
dimethylacetamide 
2,4-Dinitrotoluene 
Tris(2-
chloroethyl)phosphate 

Imidazolidine-2-
thione (2-imidazoline-
2-thiol) 

- 

- 
? 

- 

62 

 
 
  
 
  
 
  
 
  
 
 
 
  
 
  
  
 
  
 
 
  
 
  
 
 
  
 
  
 
  
 
  
 
Name 

Cat 5:  

Cat 6:  

Concrete  and 
products 

concrete 

Wood-based panels 

Cat 7:  

Masonry 

Cat 8:  

Floor coverings 

specific article(s)? 

specific article(s)? 

specific article(s)? 

specific article(s)? 

- 

- 

- 

- 

- 

- 

- 

- 

used as coating for 
stone, plaster, 
cement, glass and 
ceramic articles 

Zirconia 
Aluminosilicate 
Refractory Ceramic 
Fibres are fibres 
covered by index 
number 650-017-00-8 
in Annex VI 
Pitch, coal tar, high 
temp. 
Lead chromate 

Lead monoxide (lead 
oxide) 
N,N-
dimethylacetamide 
2,4-Dinitrotoluene 

Tris(2-
chloroethyl)phosphate 

Imidazolidine-2-
thione (2-imidazoline-
2-thiol) 

- 

- 

- 

- 

- 

- 

? 

- 

63 

- 

- 

- 

- 

- 

- 

? 

- 

used as coating for 
stone, plaster, 
cement, glass and 
ceramic articles 

- 

- 

- 

- 

- 

- 

- 

- 

 
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
 
 
  
 
  
 
Other construction articles 

tarpaulin coverings (e.g. 
roofing) 

Name 

Cat 9: 

Surfaces for sport areas 

Cat 10: 

and 
Gypsum 
based products 

gypsum 

11: 

Suspended 

Cat 
ceilings  
Cat  12:  Stretched  ceilings 
terraces 
Cat 
Cat 14: playgrounds 

13: 

specific article(s)? 

specific article(s)? 

specific article(s)? 

Zirconia 
Aluminosilicate 
Refractory Ceramic 
Fibres are fibres 
covered by index 
number 650-017-00-8 
in Annex VI 

Pitch, coal tar, high 
temp. 

Lead chromate 

Lead monoxide (lead 
oxide) 

N,N-
dimethylacetamide 

2,4-Dinitrotoluene 

Tris(2-
chloroethyl)phosphate 

Imidazolidine-2-
thione (2-imidazoline-
2-thiol) 

- 

- 

- 

- 

- 

- 

- 

- 

64 

- 

- 

- 

- 

- 

- 

? 

- 

used as coating for 
stone, plaster, 
cement, glass and 
ceramic articles 

- 

- 

- 

- 

- 

- 

- 

- 

 
 
 
  
 
  
  
  
 
  
  
  
 
  
  
 
  
  
  
 
  
  
  
 
  
  
  
  
  
  
 
  
  
Name 

# of 
notifications 

EC 
Number 

CAS 
Number 

Classification 

General  
(unspecified materials) 

Trixylyl phosphate 

1 

Trilead dioxide 
phosphonate 

Diarsenic 
pentaoxide 

2-Ethoxyethyl 
acetate 

1 

1 

1 

246-
677-8 

25155-
23-1 

Toxic for 
reproduction 
(Article 57 c) 

235-
252-2 

12141-
20-7 

Toxic for 
reproduction 
(Article 57 c) 

215-
116-9 

1303-28-
2 

Carcinogenic 
(article 57a) 

203-
839-2 

111-15-9  Toxic for 

reproduction 
(article 57c) 

1,2-
Dimethoxyethane 

1 

203-
794-9 

110-71-4  Toxic for 

reproduction 
(Article 57 c) 

Trichloroethylene 

1 

201-
167-4 

79-01-6 

Carcinogenic 
(article 57 a) 

65 

no consumer use has been identified 
from the information on identified uses related to article 
categories, no identified use could be linked specifically to the 
construction sector (example of identified use: industrial use 
of lubricants) 
no consumer use of articles has been identified' is mentioned  
however: 'use of lead-stabilized plastic materials as an 
internal structural component of buildings is' mentioned later 
on in the text; not possible to allocate this to one specific 
category 
no consumer use of articles has been identified 
No other information on identified uses related to articles is 
available. The reason may be that the substance is not 
registered, that no Article Category is provided in the 
registrations for the substance or that the identified uses of 
the registrations have been claimed confidential. 
No consumer use of articles has been identified 
No other information on identified uses related to articles is 
available. The reason may be that the substance is not 
registered, that no Article Category is provided in the 
registrations for the substance or that the identified uses of 
the registrations have been claimed confidential. 
From the AC mentioned in the notification dossiers, none could 
be directly related to the construction sector (e.g. machinery, 
lithium manganese dioxide battery)  
No other information on identified uses related to articles is 
available. The reason may be that the substance is not 
registered, that no Article Category is provided in the 
registrations for the substance or that the identified uses of 
the registrations have been claimed confidential. 
No consumer use of articles has been identified 
No other information on identified uses related to articles is 
available. The reason may be that the substance is not 
registered, that no Article Category is provided in the 
registrations for the substance or that the identified uses of 
the registrations have been claimed confidential. 

 
Name 

Cat 1:  

Doors,  windows,  shutters, 
building 
and 
curtain walling 

hardware 

Cat 2:  

Ceramic based products 

Cat 3:  

Thermal 
materials and products 

insulation 

Cat 4:  

Wall coverings 

specific article(s)? 

specific article(s)? 

specific article(s)? 

specific article(s)? 

Trixylyl phosphate 

Trilead dioxide 
phosphonate 
Diarsenic 
pentaoxide 
2-Ethoxyethyl 
acetate 
1,2-
dimethoxyethane 
Trichloroethylene 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

Name 

Cat 5:  

Concrete 
products 

Cat 6:  

and 

concrete 

Wood-based panels 

Cat 7:  

Masonry 

Cat 8:  

Floor coverings 

specific article(s)? 

specific article(s)? 

specific article(s)? 

specific article(s)? 

Trixylyl phosphate 

Trilead dioxide 
phosphonate 
Diarsenic 
pentaoxide 
2-Ethoxyethyl 
acetate 
1,2-
Dimethoxyethane 
Trichloroethylene 

- 

- 

- 

- 

- 

- 

66 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

 
 
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
  
  
  
 
 
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
  
  
  
 
 
Name 

Cat 9: 

Surfaces for sport areas 

Cat 10: 

Gypsum and gypsum based 
products 

Cat 11: Suspended ceilings  
Cat 12: Stretched ceilings 
Cat 13: terraces 
Cat 14: playgrounds 

other construction articles 

specific article(s)? 

specific article(s)? 

specific article(s)? 

Trixylyl phosphate 

Trilead dioxide 
phosphonate 

- 

- 

- 

- 

- 

- 

use of lead-stabilized 
plastic materials as an 
internal structural 
component of buildings  

- 

- 

- 

Diarsenic 
pentaoxide 
2-Ethoxyethyl 
acetate 
1,2-
Dimethoxyethane 
Trichloroethylene 
*?: not clear from notification dossier whether this substance is prevailing in every type of material, or only in one or more material(s) with the group of 
‘Glass, plaster, cement, stone, ceramic tiles’ 

- 

- 

- 

- 

- 

- 

- 

- 

- 

SVHC notification dossiers on the ECHA website were consulted in April-June 2015 

67 

 
 
 
 
  
 
  
  
  
 
  
  
 
  
  
  
 
  
  
  
 
  
  
  
  
  
  
 
 
 
3.1.2.4  USE DESCRIPTION IN REACH REGISTRATION DOSSIERS  

In  accordance  with  Art.  7(6)  of  REACH,  the  notification  obligation  under  Art.  7(2)  for  SVHC 
substances  in  articles  does  not  apply  if  the  substance  has  already  been  registered  fort  that 
use.    A  number  of  CMR  substances  used  in  products  for  construction  and  building  work  was 
retrieved from substance registration dossiers available at the website of ECHA. Therefore 
a search was performed on the use description in the registration dossiers. Substances were 
selected by their sector of use and environmental release categories (ERCs), according to the 
Use Descriptor System (REACH guidance R.12 54).  
Information  on  the  uses  of  substances  was  collected  from  the  ECHA  dissemination  website55. 
REACH  registrants  are  recommended  to  describe  the  identified  uses  of  their  substances 
according  to  the  standardised  system  provided  by  the  Use  Descriptor  System  in  the  REACH 
guidance R.1256. This system includes the 

sector of use (SU), 
chemical product category (PC), 

• 
• 
•  process category (PROC), 
•  environmental release category (ERC), and 
•  article category (AC). 

The  relevant  descriptors  for  the  purpose  of  the  selection  of  substances  present  in  building 
products  are  the  SU  and  the  ERC.  Article  category  is  also  relevant  but  a  search  by  article 
category is not provided on the ECHA website. 

The following specific use descriptors were selected for the substance selection: 

Use descriptor  Name 

SU19 
ERC3 
ERC5 
ERC6d 

ERC10a 

ERC10b 

ERC11b 

Building and construction work 
Formulation in materials 
Industrial use resulting in inclusion into or onto a matrix 
Industrial use of process regulators for polymerisation processes in 
production of resins, rubbers, polymers 
Wide dispersive outdoor use of long-life articles and materials with low 
release 
Industrial use of process regulators for polymerisation processes in 
production of resins, rubbers, polymers 
Wide dispersive outdoor use of long-life articles and materials with low 
release 

The  selection  was  made  by  listing  all  the  substances  with  SU19  and  at  least  one  of  the 
following  ERCs:  ERC3,  ERC5,  ERC6d,  ERC10a,  ERC10b  or  ERC11b.  The  resulting  list  was 
compared with the list of substances classified CMR 1A or 1B by a harmonised classification or, 
for  substances  without  harmonised  classification,  by  the  flagged  joint  entry  in  the  C&L 
inventory. This search resulted in a final list of 26 substances of which: 

•  14 have a harmonised classification CMR 1A or 1B (substances in italic in Table 9) 
•  1 has a harmonised classification CMR2 and a non-harmonised classification CMR 1A 

54 http://echa.europa.eu/guidance-documents/guidance-on-reach 
55 http://echa.europa.eu/information-on-chemicals/registered-substances 
56 http://echa.europa.eu/guidance-documents/guidance-on-reach 

68 

 
 
 
 
                                           
 
•  2 have a harmonised classification but not for CMR, and a non-harmonised classification 

CMR 1A  

•  9 have no harmonised classification and a non-harmonised classification CMR 1A or 1B  

For  the  purpose  of  the  present  study,  we  will  only  consider  the  14  substances  from  the  first 
bullet, which have a harmonised CMR 1A or 1B classification. The other substances (bullet 2, 3 
and 4) are included in the list in Annex 1. 

Note that Sweden launched a harmonised C&L proposal for cadmium carbonate (EC 208-168-
9), for carc1B. and muta1B. This substance is registered with SU19 and ERC3 (see Annex 1). 

Table  9:  REACH  registered  substances  with  SU19,  at  least  one  of  the  following  ERCs:  ERC3, 
ERC5,  ERC6d,  ERC10a,  ERC10b  or  ERC11b,  and  CMR  1A  or  1B  classification  in  the  C&L 
in  April-June  2015). 
inventory 
Harm=harmonised classification; nHarm=non-harmonised classification. 

(Source:  ECHA  dissemination  website44,  consulted 

Einecs No. 

Name 

ERC*  CMR 1A 1B 

200-001-8 

formaldehyde 

yes 

Harm1B 

200-849-9 

ethylene oxide 

yes 

Harm1B 

201-039-8 

dibutyltin dilaurate 

yes 

nHarm1A 

203-466-5 

acrylonitrile 

yes 

Harm1B 

204-118-5 

tris(2-chloroethyl) 
phosphate 

yes 

Harm1B 

212-449-1 

dibutyltin oxide 

yes 

nHarm1B 

213-928-8 

dibutyltin di(acetate) 

yes 

nHarm1B 

213-934-0 

tris(2-
methoxyethoxy)vinylsila
ne 

yes 

nHarm1B 

215-125-8 

diboron trioxide 

yes 

Harm1B 

215-146-2 

cadmium oxide 

yes 

Harm1B 

215-175-0 

diantimony trioxide 

yes 

215-222-5 

zinc oxide 

yes 

Harm: CMR2; 
nHarm1A 
Harm: not 
classified CMR; 
nHarm1A 

215-540-4 

215-693-7 

disodium tetraborate, 
anhydrous 
lead sulfochromate 
yellow 

yes 

Harm1B 

yes 

Harm1A 

222-103-1 

dibutoxydibutylstannane  yes 

nHarm1B 

231-100-4 

lead 

yes 

nHarm1A 

231-150-7 

beryllium 

yes 

Harm1B 

Total  Tonnage  Band  per 
annum 

1,000,000+ tonnes per 
annum 
1,000,000+ tonnes per 
annum 
100 - 1,000 tonnes per 
annum 
1,000,000 - 10,000,000 
tonnes per annum 
10 - 100 tonnes per 
annum 
1,000 - 10,000 tonnes per 
annum 
10 - 100 tonnes per 
annum 

1,000 - 10,000 tonnes per 
annum 

100 - 1,000 tonnes per 
annum 
1,000 - 10,000 tonnes per 
annum 
10,000+ tonnes per 
annum 

100,000 - 1,000,000 
tonnes per annum 

100,000 - 1,000,000 
tonnes per annum 
1,000 - 10,000 tonnes per 
annum 
10 - 100 tonnes per 
annum 
1,000,000 - 10,000,000 
tonnes per annum 
10 - 100 tonnes per 
annum 

69 

 
 
Einecs No. 

Name 

ERC*  CMR 1A 1B 

231-152-8 

cadmium 

yes 

Harm1B 

231-847-6 

copper sulphate 

233-139-2 

boric acid 

233-826-7  magnesium nitrate 

yes 

yes 

yes 

Harm: not 
classified CMR; 
nHarm1A 

Harm1B 

Harm1B 

234-371-7 

potassium pentaborate 

yes 

Harm1B 

234-541-0 

disodium octaborate 

yes 

nHarm1A 

235-759-9 

242-555-3 

245-152-0 

lead chromate 
molybdate sulfate red 
dimethyl 
propylphosphonate 
dibutylbis(pentane-2,4-
dionato-O,O')tin 

yes 

Harm1A 

yes 

nHarm1B 

yes 

nHarm1A 

Total  Tonnage  Band  per 
annum 

1,000 - 10,000 tonnes per 
annum 

10,000 - 100,000 tonnes 
per annum 

100,000 - 1,000,000 
tonnes per annum 
Intermediate Use Only 
10 - 100 tonnes per 
annum 
1,000 - 10,000 tonnes per 
annum 
1,000 - 10,000 tonnes per 
annum 
100 - 1,000 tonnes per 
annum 
100 - 1,000 tonnes per 
annum 

*  ERC3,  ERC5,  ERC6d,  ERC10a,  ERC10b,  or  ERC11a,  or  a  combination  of  these  ERCs;  substances  with 
harmonised CMR 1A/1B classification are in italic 

3.1.2.5  ARTICLE 33 REQUESTS  

As  a  complementary  approach  to  searching  in  publically  available  databases  and  reports,  we 
made  use  of  the  consumer’s  right  (Article  33  of  REACH)  to  request  information  from  the 
manufacturers/ and importers of articles on SVHCs content in construction articles.  

This exercise was focused on the Belgian market because it was out of scope and capacity of 
this project to identify and address manufacturers and importers of construction articles for a 
broad range of European countries. Therefore, the results covering the Belgian market cannot 
be  generalized  to  other  EU  countries;  however,  several  players  on  the  Belgian  market  which 
have been addressed are also active on EU markets outside Belgian. 

Identification of suppliers of construction articles  

We  aimed  to  send  Article  33  request  to  the  main  suppliers  (manufacturers,  importers, 
distributers) of the 14 categories of construction articles on the Belgian market (categories cfr. 
Task 1.1).  

In order to identify the relevant manufacturers, importers and sellers, and to find their contact 
information,  2  complementary  databases  of  the  construction  sectors  have  been  screened: 
‘Batibouw’ and ‘Techcom’ database.  

Batibouw database:  

Batibouw  is  the  largest  exhibition  of  the  construction  sector  in  Belgium,  both  oriented  at 
professionals  and  consumers.  The  main  big  players  in  construction  sector  in  Belgium  are 
present  at  the  Batibouw  exhibition.  The  Website  of  Batibouw57  hosts  a  contact  database  of 
manufacturers,  importers  and  sellers  of  construction  articles.  This  database  was  used  to  find 

57 http://www.batibouw.be/  

70 

 
 
 
                                           
 
contact details of manufacturers, importers and sellers of construction articles for each of the 
categories identified in task 1.1.  
Techcom database 58  

The  Techcom  database  of  the  Belgian  Building  Research  Institute  is  a  database  for 
professionals,  building  contractors,  listing  building  products  and  manufacturers.  Most  of  the 
products available on the Belgian market are included in the database. This database was also 
used to find contact details of manufacturers, importers and sellers of construction articles for 
each of the categories identified in task 1.1 

The Batibouw and Techcom databases resulted in some overlapping information; nevertheless, 
they  also  had  a  complementary  value:  on  the  one  hand,  some  categories  are  not  or  poorly 
presented  at  the  Batibouw  exhibition  e.g.  “wall  covering”,  “surfaces  for  sport  areas”,  “wood 
based panels”); on the other hand, Batibouw is more oriented towards consumers compared to 
the professional database of Techcom. 

Based  on  screening  of  Batibouw  and  Techcom  database,  about  200  manufacturers,  importers 
and sellers have been identified. These 200 companies have been contacted by e-mail in Dutch 
and English. The following e-mail was sent:  

“Dear Madam, Sir,  

This question frames in REACH regulation (EC/1907/2006).  

Based on Article 33 of REACH, I would like to request whether your company sells (as producer 
or  importer)  construction  articles  (e.g.  gypsum  based  products  or  other  construction  articles) 
containing  substances  (>  0.1  %  weight  basis)  classified  as  substances  of  very  high  concern 
(SVHC)  according  to  Article  57  of  the  REACH  regulation  (EC/1907/2006).  A  list  of  these 
substances  can  be 
the  ECHA  website  (European  Chemicals  Agency): 
http://echa.europa.eu/candidate-list-table. 

found  on 

If this is the case, can you inform me in which articles the substances are present, and what is 
the identity (name, CAS no.) and eventually technical function of these substances?  

If none of your construction articles contains SVHC substances, can you please confirm that as 
well? 

This  question  frames  in  the  consumer  right  to  receive  this  information  from  suppliers  free  of 
charge within 45 days of receipt of the request (Article 33 of REACH).  

Thank you in advance for your feedback! 

Results of Article 33 requests  

In  general,  the  response  rate  was  poor  (23  %  of  the  addressed  companies  answered  the 
request) and there was a large diversity in response to the Article 33 requests:  

A first group of respondents have experience with this kind of questions: they have addressed 
this  question  before  and  have  a  standard  letter  of  declaration  (for  use  in  supply  chain/ 
published on websites)  – and have provided a letter with a formal declaration concerning the 
presence of SVHCs in articles.  

A  second  group  of  respondents  have  confirmed  by  means  of  a  short  ‘sec’  e-mail  that  their 
products  do  not  contain  SVHCs  >  0.1  %,  without  further  explanation  how  they  come  to  this 
conclusion.  

58 http://www.wtcb.be/?goto=techcom) 

71 

 
 
 
                                           
 
A third group of respondents answered that they do not know how to address the request, or 
they  give  irrelevant  or  incomplete  information  (e.g.  leaching  testing  report  of  specific 
compound). 

A  fourth  (small)  group  respondents  refused  to  answer  the  request.  They  considered  the 
contractant of this study not being in position of a consumer in relation to the manufacturer, 
and  thereby  declared  that  the  manufacturer  has  not  obligation  to  respond  to  the  Article  33 
request.  

The largest group of addressed companies (77 %) did not respond to the request.  

The results by construction article category are listed in Table 10.  

In  conclusion,  the  Article  33  request  responses  resulted  in  identification  of  only  2  SVHCs 
present in levels > 0.1 % in identified construction articles:  

•  Use of benzylbutylphthalate in flooring material.  

o  Note that this information is consistent with information found in registration 
dossiers  (the  use  of  benzylbutylphthalate  is  mentioned  in  relation  to  SU  19 
(building  and  construction  work)  and  ERC  3  (formulation  in  materials); 
though, in the registration dossier, the type of materials is not specified).  

Benzylbutylphthalate is classified as CMR 1A/1B (harmonized classification: Repr 1B). 

•  Use  of  hexabromocyclododecane  in  XPS  used  as  insulation  materials,  in  EPS  used  as 

insulation material), and in EPS as element of a bath 

Hexabromocyclododecane  is  not  classified  as  CMR  1A/1B  (joint  entry:  Repr  2),  but 
identified as a SVHC due to its PBT properties. 

72 

 
 
 
Table 10: Results of responses to Article 33 requests sent to suppliers of construction articles  

category 
number 

category 
name 

# companies 
contacted 

# companies 
responded 

responses (number of companies per response type) 

declaration: 
no 
articles 
with  SVHCs 
> 0.1 % 

no clear answer 

confirmed presence of SVHCs > 0.1 
% in articles 

20 

5 

2 

3  one company did not want to 

0 

doors, 
windows, 
shutters, 
building 
hardware 
and curtain 
walling' 

1 

2a 

2b 

73 

10 

9 

ceramic 
based 
products: 
tiles 

ceramic 
based 
products: 
sanitary 
appliances 

1 

3 

2 

respond because they consider 
VITO not in the position of a 
consumer, so VITO cannot use 
Article 33 of REACH to gather 
this type of information  
2 other companies did not 
know how to address the 
question, and where to find the 
relevant formation. They were 
not informed by their suppliers 
about SVHCs in the 
products/articles they bought 
as raw materials 
the company declares being 
compliant with REACH but they 
do not address our specific 
question about SVHCs in 
articles 

1 

1  one producer declares the 

presence of HBCDD 
(hexabromocyclododecane) in 
expanded polystyrene 
(polystyrene foam; styrofoam) 
as an element of a bath  

 
 
 
 
 
  
  
  
  
  
  
category 
number 

category 
name 

# companies 
contacted 

# companies 
responded 

responses (number of companies per response type) 

3 

thermal 
insulation 
materials 

declaration: 
no 
articles 
with  SVHCs 
> 0.1 % 

no clear answer 

confirmed presence of SVHCs > 0.1 
% in articles 

20 

11 

7 

1  one producer says that their 

3  water tight coating (based on 

products use Alu-foils and inert 
polymer PD that include 
specific substances (such as 
flame retardants) but that 
these components are 
completely encapsulated in the 
base polymer, so that all risks 
are minimized  
so, they do not answer 
whether their articles contain 
SVHCs in > 0.1 % 

polyurethane): (Aradur 
HY1102) 0.3 - 0.4% 

--> used as curing agent in 
professional liquid water 
tightening products  
(not clear from their answer 
whether they sell the final 
products as an article, or 
whether their answer is 
pertaining to preparations only 
(and thus out of scope here) 

use of 
hexabromocyclododecane in 
XPS (> 0.1 %); producer A. 
Technical function: flame 
retardant 

use of 
hexabromocyclododecane in 
EPS (> 0.1 %). producer B. 
Technical function: flame 
retardant 

wall covering  16 
15 
concrete and 
concrete 
products 

2 
1 

2 

4 
5 

74 

 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
category 
number 

category 
name 

# companies 
contacted 

# companies 
responded 

responses (number of companies per response type) 

declaration: 
no 
articles 
with  SVHCs 
> 0.1 % 

no clear answer 

confirmed presence of SVHCs > 0.1 
% in articles 

17 

14 
25 

wood based 
panels 
masonry 
 resilient, 
textile and 
laminate 
flooring 

round and 
sawn timber 
(for parquet 
flooring) 
surfaces for 
sport areas 

18 

6 

gypsum and 
gypsum 
based 
products 
suspended 
ceiling 
stretched 
ceilings 
terraces  

9 

11 

6 

0 

6 

7 
8a 

8b 

9 

10 

11 

12 

13 

75 

1 

5 
8 

0 

1 

3 

3 

1 

1 

5 
6 

3 

2 

1 

0 
1  no clear answer about SVHCs 

0 
1  one producer declares 

(>0.1 %) in articles: they only 
say their products are 
formaldehyde & 
pentachlorophenol free or 
emission levels compliant with 
Ü-sign 

producing a flooring covering 
containing 1 percent weight by 
weight: benzylbutylphthalate 

1  answer does not address 

adequately the question: they 
have given us a test report of 
(leaching) heavy metals, 
compliance with DIN 18035-7 
testing (does not say so much 
about other CMR substances 
and levels > 0.1 % 

1 

is a sales representative and 
cannot answer the question  

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
category 
number 

category 
name 

# companies 
contacted 

# companies 
responded 

responses (number of companies per response type) 

14 

playgrounds 

5 

2 

2  one company have delivered 

declaration: 
no 
articles 
with  SVHCs 
> 0.1 % 

no clear answer 

confirmed presence of SVHCs > 0.1 
% in articles 

an analysis report of release of 
PAHs from the playmats;  
however: this does not respond 
to the question about SVHCs in 
0.1% or above 
a second company declares not 
using 'Chinese rubbish', only 
'Belgian made' articles, and 
concludes therefore that their 
articles - to their knowledge - 
do not contain 'toxic 
substances' 

76 

 
 
 
 
 
 
  
  
  
 
 
3.1.2.6  RESTRICTIONS ON THE USE OF CMR 1A/1B SUBSTANCES IN CONSTRUCTION ARTICLE  

Restrictions  under  REACH  are  a  risk  management  measure  to  protect  human  health  and  the 
environment  from  unacceptable  risks  posed  by  chemicals.  Restrictions  may  limit  or  ban  the 
manufacture, placing on the market or use of a substance.  

Annex  XVII  of  the  REACH  Regulation  contains  a  list  of  restrictions  under  REACH.  Annex  XVII 
was  screened  for  restrictions  which  are  specific  applicable  for  content  or  release  of  CMR 
substances from construction articles.  

Upon  consultation  (May  2015),  the  Restriction  list  has  105  entries  (i.e.  restriction  to  105 
substances/group  of  substances/mixtures);  51  referring  to  substances  with  CMR  1A/1B 
properties. The large majority of restrictions apply to substances in mixtures and preparations. 
A minority is applicable for articles.  

Table 11 lists the restrictions which apply for construction articles. 

The  information  form  this  source  can  be  regarded  rather  as  an  elimination  list  (CMR  1A/1B 
substances not or limited present in construction articles), and obviously does not contribute to 
the ‘positive’ list of CMR 1A/1B substances which is the target of task 2.1. 

Table  11:  Restrictions  on  use  of  CMR  1A/1B  substances  in  construction  articles  under  REACH 
(retrieved from Annex XVII)  

Substance 

CAS no. 

Restriction for construction articles 

Di-μ-oxo-di-n-
butylstanniohydroxyborane/ 
Dibutyltin hydrogen borate 
C8H19BO3Sn (DBB) 

75113-37-0 

Cadmium 

7440-43-9 

77 

on 

from 

impact 

indirect 

in  mixtures 

restriction  with 
construction articles: 
“Shall not be placed on the market, or used, 
as  a  substance,  or 
in  a 
concentration  equal  to,  or  greater  than  0,1 
%  by  weight.  However,  the  first  paragraph 
shall  not  apply  to  this  substance  (DBB)  or 
mixtures  containing  it  if  these  are  intended 
solely  for  conversion  into  articles,  among 
which this substance will no longer feature in 
a  concentration  equal  to  or  greater  than  0,1 
% in the article.” 
Shall  not  be  used  in  mixtures  and  articles 
produced 
following  synthetic 
organic  polymers  (hereafter  referred  to  as 
plastic material):… several of these materials 
are construction articles:  
polymers  or  copolymers  of  vinyl  chloride 
(PVC)  [3904  10]  [3904  21]  —  polyurethane 
(PUR) [3909 50] — low-density polyethylene 
(LDPE),  with  the  exception  of  low-density 
polyethylene  used  for  the  production  of 
coloured  masterbatch  [3901  10]  —  cellulose 
acetate  (CA)  [3912  11]  —  cellulose  acetate 
butyrate  (CAB)  [3912  11]  —  epoxy  resins 
[3907  30]  —  melamine-formaldehyde  (MF) 
resins  [3909  20]  —  urea-formaldehyde  (UF) 
resins  [3909  10]  —  unsaturated  polyesters 
(UP) [3907 91] 

the 

 
 
 
Substance 

CAS no. 

Restriction for construction articles 

Chromium VI compounds 

Creosote, wash oil 
Creosote oil, wash oil 
Distillates (coal tar), 
naphthalene oils, 
naphthalene oil 
Creosote oil, acenaphthene 
fraction,wash oil 
Distillates (coal tar), upper, 
heavy anthracene oil 
Anthracene oil 
Tar acids, coal, crude, crude 
phenols 
Low temperature tar oil, 
alkaline, extract residues 
(coal), low temperature coal 
tar alkaline 
Asbestos fibres: Crocidolite 
Asbestos fibres: Amosite 
Asbestos fibres: 
Anthophyllite 
Asbestos fibres: Actinolite 
Asbestos fibres: Tremolite 
Asbestos fibres: Chrysotile 
Asbestos fibres: Chrysotile 

8001-58-9 
61789-28-4 
84650-04-4 

90640-84-9 

65996-91-0 

90640-80-5 
65996-85-2 
122384-78-5 

12001-28-4 
12172-73-5 
77536-67-5 
77536-66-4 
77536-68-6 
12001-29-5 
132207-32-0 

Cement  and  cement-containing  mixtures 
shall not be placed on the market, or used, if 
they  contain,  when  hydrated,  more  than  2 
mg/kg  (0,0002  %)  soluble  chromium  VI  of 
the total dry weight of the cement. 
Wood  treated  with  this  substance  shall  not 
be  placed  in  the  market,  except  for  wood 
installations: 
industrial 
treated 
benzo[a]pyrene  at  a  concentration  of  less 
than 50 mg/kg (0,005 % by weight), and (ii) 
water extractable phenols at a concentration 
of less than 3 % by weight. 

in 

Special  provisions  on  the  labelling  of  articles 
containing asbestos (Appendix 7) 

78 

 
 
 
 
 
 
 
 
 
 
 
 
 
3.1.2.7  AUTHORIZED USE OF CMR 1A/1B IN CONSTRUCTION ARTICLES 

The first step in the authorisation process under REACH is the identification of substances that 
may have serious effects on human health or the environment, the so called Substance of Very 
High  Concern  (SVHC).  If  identified  as  SVHC,  the  substance  is  added  to  the  Candidate  List. 
After  a  regulatory  process,  SVHCs  of  the  Candidate  List  may  be included  in  the  Authorisation 
List  (REACH  Annex  XIV)  and  become  subject  to  authorisation.  These  substances  cannot  be 
placed  on  the  market  or  used,  either  on  their  own,  in  a  mixture  or  for  incorporating  into  an 
article, after a given date (the sunset date) unless an authorisation is granted for specific uses, 
or  the  use  is  exempted  from  authorisation  (Table  12).  At  this  moment,  for  none  of  the 
substances on the Authorisation list, a use relevant for construction has been exempted from 
Authorisation.  

Table 12: CMR 1A/1B substances on the Authorization list, and the sunset date 

Substance name 

CAS number  Sunset date 

Latest 

Application date 

Sodium chromate 

Strontium chromate 

7775-11-3 

21/09/2017 

21/03/2016 

7789-06-2 

22/01/2019 

22/07/2017 

Ammonium dichromate 

7789-09-5 

21/09/2017 

21/03/2016 

2,2'-dichloro-4,4'-methylenedianiline 
(MOCA) 
4,4’- Diaminodiphenylmethane (MDA) 

101-14-4 

22/11/2017 

22/05/2016 

101-77-9 

21/08/2014 

21/02/2013 

Sodium dichromate 

10588-01-9 

21/09/2017 

21/03/2016 

1,2-Dichloroethane (EDC) 

107-06-2 

22/11/2017 

22/05/2016 

Potassium 
hydroxyoctaoxodizincatedichromate 
Bis(2-methoxyethyl) ether (Diglyme) 

11103-86-9 

22/01/2019 

22/07/2017 

111-96-6 

22/08/2017 

22/02/2016 

Tris(2-chloroethyl)phosphate (TCEP) 

115-96-8 

21/08/2015 

21/02/2014 

Bis(2-ethylhexyl) phthalate (DEHP) 
2,4 – Dinitrotoluene (2,4-DNT) 

117-81-7 
121-14-2 

21/02/2015 
21/08/2015 

21/08/2013 
21/02/2014 

Lead chromate molybdate sulphate red  
(C.I. Pigment Red 104) 

12656-85-8 

21/05/2015 

21/11/2013 

Diarsenic pentaoxide 

Diarsenic trioxide 

Chromium trioxide 

1303-28-2 

21/05/2015 

21/11/2013 

1327-53-3 

21/05/2015 

21/11/2013 

1333-82-0 

21/09/2017 

21/03/2016 

Pentazinc chromate octahydroxide 

49663-84-5 

22/01/2019 

22/07/2017 

Acids generated from chromium trioxide 
and their oligomers. Group containing: 
Chromic acid, Dichromic acid, Oligomers 
of chromic acid and dichromic acid 

7738-94-5 

21/09/2017 

21/03/2016 

Lead chromate 

Arsenic acid 

Potassium dichromate 

Potassium chromate 

Sodium dichromate 

Trichloroethylene 

Diisobutyl phthalate (DIBP) 

Dibutyl phthalate (DBP) 

79 

7758-97-6 

21/05/2015 

21/11/2013 

7778-39-4 

22/08/2017 

22/02/2016 

7778-50-9 

21/09/2017 

21/03/2016 

7789-00-6 

21/09/2017 

21/03/2016 

7789-12-0 

21/09/2017 

21/03/2016 

79-01-6 

84-69-5 

84-74-2 

21/04/2016 

21/10/2014 

21/02/2015 

21/08/2013 

21/02/2015 

21/08/2013 

 
Substance name 

CAS number  Sunset date 

Latest 

Application date 

Benzyl butyl phthalate (BBP) 

85-68-7 

21/02/2015 

21/08/2013 

The  placing  on  the  market  and  use  of  Substances  of  Very  High  Concern  included  in  the 
Authorisation  List  requires  an  authorisation.  A  manufacturer,  an  importer  or  a  downstream 
user can apply for an authorisation.  Applications for authorisation are submitted to ECHA. At 
the end of the authorisation process, which includes a public consultation and the development 
of  opinions  by  ECHA's  Committees  on  Risk  Assessment  and  Socio-economic  Analysis,  the 
European Commission decides on the granting or refusing of authorisations. 

The  REACH  dissemination  website  hosts  a  list  of  adopted  opinions  and  previous  consultations 
on  applications  for  authorization59.    Upon  screening  of  this  part  of  the  ECHA  website,  56 
applications were found.  

These  were  screened  for  authorized  uses  of  CMR  1A/1B  substances  in  uses  relevant  for  the 
construction sectors, with authorization granted to at least one producer. 

The result of this screening is listed in Table 13. 

Table  13:  List  of  substances  with  granted  authorizations,  and  identification  of  relevance  of 
these uses in the domain of manufacturing of construction article use (authorized use granted 
to at least one producer) 

Substances 

CMR 
classification 

Technical 
function 

Authorized use in domain of construction 
articles* 

plasticizer  Use in manufacturing of PVC articles, of 
which several are used as construction 
article (e.g. PVC flooring, window frames, 
plastic pipes) 
(cat 1, 8a) 
No authorized use in domain of 
construction articles 
No authorized use in domain of 
construction articles 
Use in production of expanded 
polystyrene (EPS) with onward use in 
building applications (e.g. insulation 
materials) 

Flame 
retardant 

Bis(2-ethylhexyl) 
phthalate (DEHP) 

Repr 1B 

Diarsenic trioxide 

Carc 1A 

Repr 1B 

Repr 2 

Dibutyl phthalate 
(DBP) 
Hexabromocyclo-
dodecane (HBCDD), 
alpha-
hexabromocyclo-
dodecane, beta-
hexabromocyclodod
ecane, gamma-
hexabromocyclo-
dodecane 
Lead chromate 

Carc 1B Repr 
1A 

No authorized use in domain of 
construction articles 

59 
authorisation-previous-consultations 

http://echa.europa.eu/addressing-chemicals-of-concern/authorisation/applications-for-

80 

 
 
 
 
 
 
                                           
 
Substances 

CMR 
classification 

Technical 
function 

Authorized use in domain of construction 
articles* 

Lead chromate 
molybdate sulphate 
red  
(C.I. Pigment Red 
104) 

Carc 1B Repr 
1A 

Lead sulfochromate 
yellow  
(C.I. Pigment 
Yellow 34) 

Carc 1B Repr 
1A 

Trichloroethylene 

Carc 1B 
Muta 2 

To be further elucidated whether the use 
is indirectly relevant for construction 
articles:  
Authorized use: “Distribution and mixing 
pigment powder in an industrial 
environment into solvent-based paints for 
non-consumer use” 
It needs to be further investigated 
whether these paints for non-consumer 
use are used in the manufacturing of 
construction articles or not 
To be further elucidated whether the use 
is indirectly relevant for construction 
articles:  
Authorized use: “Distribution and mixing 
pigment powder in an industrial 
environment into solvent-based paints for 
non-consumer use” 
It needs to be further investigated 
whether these paints for non-consumer 
use are used in the production of 
construction articles or not 
No authorized use in domain of 
construction articles 

*construction articles considered relevant for this project (list of categories in task 1.1) 

Several  of  these  substances  have  been  used  in  construction  articles  in  the  past,  and  will 
potentially be used until the sunset date/application date (e.g. DBP, DEHP; ECT). For some of 
these substances, no authorised use relevant for use in construction articles has been granted 
(e.g. DIBP, DBP, and BBP). 

However,  the  authorisation  regime  only  applies  to  uses  of  SVHC  substances  in  Annex  XIV  in 
Europe,  and  as  such  does  not  apply  to  articles  containing  Annex  XIV  substances,  as  long  as 
these articles have been produced outside the European Economic Area. It follows that articles 
(such as furniture, textiles, toys, DVDs, books, kitchen appliances and other electronic devices, 
vehicles,  insulation  materials  etc.)  produced  in  the  European  Economic  Area  may  not  contain 
these  substances  unless  an  authorisation  was  granted  for  the  specific  use,  while  articles 
produced outside the EEA area and imported to the EEA may contain Annex XIV substances.  

After the sunset date, ECHA should – according to Article 69 (2) - consider whether the use of 
the substance in articles poses a risk that is not adequately controlled and if this is the case, 
prepare a dossier which conforms to the requirement of an Annex XV dossier for restriction.  

Since restrictions on the presence of a substance in articles also apply to imported articles, the 
additional  step  of  imposing  restrictions  should  prevent  consumers  also  from  exposure  to 
SHVCs released from imported articles.  

3.1.2.8  EU RISK ASSESSMENT REPORTS  

Risk  Assessment  Reports  (RAR)  written  by  the  EC  under  the  Existing  Substance  Regulation 
(EEC No 793/93) were screened for CMR 1A/1B substances, and uses relevant for construction 
articles were identified.  

Of  the  141  substances  for  which  a  RAR  was  available,  14  substances  were  classified  as  CMR 
1A/1B.  Eleven  of  these  substances  have  a  use  in  a  construction  sector  application  (see  Table 

81 

 
 
 
 
 
14). Relevant information, such as construction article category in which the CMR is used and 
information regarding technical function, is mentioned in Table 14. 

82 

 
 
 
Table 14: CMR 1A/1B substances with an identified use in the construction sector (retrieved from EU RARs) 

Substance 

Application domain (construction articles) 

Technical function 

Reference 

Tris(2-
choroethyl)-
phosphate 
(TCEP) 

Benzene 

Roof insulation 

Impurity formed as a 
reaction by-product in the 
manufacture of other 
commercial flame 
retardants 

RAR of TCEP  
(EC, 2008)60 

RAR of benzene  
(EC, 2008)61 

RAR of 
propylene 
oxide62  

RAR of DMS63 

RAR of TCE64 

Consumer exposure section of RAR does not mention construction 
articles as a relevant exposure route;  
However, it is used in paint-related products, and therefore, it can be 
assumed that painted construction article might contain benzene 

Propylene oxide  monomer or chemical intermediate is for the manufacture of 

Dimethyl 
sulphate 

Trichloroethylene 

propylene glycols, which can be used in construction industries 
However, the amount of residual monomer present in final products 
used by consumers is very low and therefore consumer exposure is 
expected to be negligible 
No direct use in construction articles mentioned in the RAR. 
DMS is mainly used as a chemical intermediate; no uses in 
manufacturing of construction articles 
The only consumer use of trichloroethylene appears to be for spot 
cleaning fabrics. Construction articles as a source of TCE are not 
mentioned in the RAR  
However, However, it is used in paint-related products, and 
therefore, it can be assumed that painted construction articles 
might contain TCE 

Dibutyl phthalate  No information. Relevant parts of the RAR  not available at website of 

ECHA 

60 http://echa.europa.eu/documents/10162/f42be21b-33a3-4063-ad4d-2b0f937e41b4 
61 http://echa.europa.eu/documents/10162/be2a96a7-40f6-40d7-81e5-b8c3f948efc2 
62 http://echa.europa.eu/documents/10162/c9918161-1be3-4b76-9088-72eaee9cfaca 
63 http://echa.europa.eu/documents/10162/dd7693e6-0573-4e59-8888-b45787970e7a 
64 http://echa.europa.eu/documents/10162/d30e53cc-89e7-4d1c-89c0-7ec216f84d48 

83 

 
 
 
 
 
 
 
 
                                           
 
Substance 

Application domain (construction articles) 

Technical function 

Reference 

BBP 

1-Vinyl-2-
pyrrolidone 

Buta-1,3-diene 

2-Ethoxyethanol 

(CAS 110-80-5) 

DEHP 

‘Indoor Air’ is mentioned. Not explicitly linked to construction articles 
(construction  articles  are  not  mentioned  in  the  RAR).  Uses  in  paints 
and adhesives are mentioned. Given the use in paints and adhesives, 
it  can  be  assumed  that  painted  construction  articles  might 
contain BBP. 
N-VP monomer is not used directly in consumer products but may be 
present in trace amounts as a residue in products containing PVP. 
Consumer use of these products may result in exposure to residual 
monomer 
Consumer uses include a wide range of applications (such as curing 
inks, lacquers); use in construction article is not explicitly mentioned; 
however, Given the use in inks and lacquers, it can be assumed that 
construction articles treated with inks or lacquers may 
contain 1-vinyl-2-pyrrolidone. 
Two potential consumer uses might give rise to exposure: release 
from carpet backings and food packaging materials;  
So no use of construction materials 
Consumer use: paints;  
No explicitly mentioning of construction articles;  
However, it can be assumed that painted construction articles might 
contain 2-ethoxyethanol  
Used as plasticizer in Flexible PVC, used in many different 
articles e.g. toys, building material such as flooring, cables, 
profiles and roofs 

RAR BBP65 

RAR 66 

RAR Buta-1,3-
diene67 

RAR 2-
ethoxyethanol68 

plasticizer 

RAR DEHP 

65 http://echa.europa.eu/documents/10162/b8497638-00ad-442e-9a8f-02e212570b54 
66 http://echa.europa.eu/documents/10162/7ccc8738-3827-473c-bc86-dd0dd7c8e712 
67 http://echa.europa.eu/documents/10162/cf3931bd-8b42-49e2-a0b9-4acc71a37375 
68 http://echa.europa.eu/documents/10162/8df7f6fd-9268-4d0a-a881-f4cad9bb6df0 

84 

 
 
 
 
 
 
                                           
 
Substance 

Application domain (construction articles) 

Technical function 

Reference 

Cadmium metal 
and Cadmium 
oxide 

1°:  Cadmium  sulphide  and  cadmium  sulphoselenide  are  used  as 
bright yellow to deep red pigments in ceramics, glasses, enamels, 
plastics,  and  artists  colours.  Cadmium  metal or  cadmium  oxide  are 
used  as  starting  material  for  the  production  of  these  pigments  and, 
according to Industry, not present in the consumer’s product 

Cadmium-based  stabilisers  are  used  to  retard  the  degradation 
processes  which  occur  in  polyvinylchloride  (PVC)  and  related 
polymers  on  exposure  to  heat  and  ultraviolet  light  (sunlight) 
Cadmium  oxide  and  cadmium  metal  are  used  as  starting  materials 
for the production of the cadmium organic salts but are not present, 
according to Industry, in the final consumer’s product. 

Brazing  material  containing  up  to  20%  w/w  Cd  can  be  purchased 
by  the  consumer  through  Do-It-Yourself  shops.  One  may  assume 
that  consumer  uses  of  brazing  material  are  likely  to  be  infrequent 
and  duration  of  exposure  is  expected  to  be  shorter  than  in  an 
industrial  setting.  In  case  of  use  by  the  consumer  of  such  brazing 
sticks, mainly inhalation exposure should be considered. 

Pigments 

RAR  Cd  oxide 
and metal69 

stabilizers 

Disodium 
tetraborate  

The  major  uses  of  borates  in  Europe  are  for  insulation  and  textile 
fibreglass,  frit  and  glazes  for  ceramics  (23%),  cleaning  and 
bleaching (12%) and borosilicate glass (7%), 

Nickel (CAS no 
7440-02-0) 

Nickel  used  in  production  of  stainless  steel  (with  uses  of  steel  in 
construction sector) 

RAR Ni70  

69 http://echa.europa.eu/documents/10162/2f39ec55-4530-48f5-8ed9-31be889229cd 
70 http://echa.europa.eu/documents/10162/cefda8bc-2952-4c11-885f-342aacf769b3 

85 

 
 
 
 
 
 
 
 
 
 
 
                                           
 
Substance 

Application domain (construction articles) 

Technical function 

Reference 

Sodium 
Chromate And  

Consumer  exposure  to  Cr(VI)  from  the  five  chromates  under  review 
is  considered  to  be  relevant  only  in  the  case  of  copper  chrome 
arsenate (CCA) treated wood 

RAR  Chromium 
substances71 

Sodium 
Chromate 

Sodium 
Dichromate 

Disodium 
tetraborate, 
anhydrous 
Boric acid, 

Single  exposure  of  children  as  a  result  of  contact  with  CCA  treated 
wooden playing structures 

and  single  exposure  of  adults  handling  CCA  treated  wood  for  use 
outdoors e.g. building fences are estimated to be extremely low 

Heat-resistant glass  

Ceramics 
Steel and non-ferrous products 
Wood products and cellulose insulation 

Create optimal glass 
fiberization 

Flame retardants 

71 http://echa.europa.eu/documents/10162/7e573c8f-70e7-4c3f-9cf4-22e843491bc6 

86 

 
 
 
 
 
 
 
 
 
 
 
                                           
 
3.1.2.8.1 

INFORMATION FROM OTHER SOURCES ON CMR SUBSTANCES IN CONSTRUCTION ARTICLES  

Natural fibres used for insulation are typically treated with flame retardants, and mixed 
with a binder. Commonly used flame retardants are disodium tetraborate (borax) (Rep 
cat  1B)  and  ammonium  phosphate.  The  binders  are  often  polyester-based 72,73.  Also 
biocides may be added. 

Reports  of  the  Swedish  Chemical  Agency  (KEMI)  on  a  proposal  for  phasing  out 
phthalates which are toxic for reproduction and endocrine-disrupting  74 confirm the use 
of  phthalates  in  several  construction  articles,  such  as  plastic  construction  materials, 
floor coverings, insulation materials, wall coverings, profiles for door and windows and 
coated panels. 

Figures  in  the  report  of  KEMI  reflect  general  numbers  (tonnage  use/application 
domains)  for  phthalates  as  a  group;  it  was  not  possible  to  split  up  the  numbers  into 
phthalates with CMR 1A/1B properties versus phthalates without CMR 1A/1B properties. 

Trends of shifting from use of phthalates to phthalate-free plasticizers (e.g. DINCH) are 
noted.  
A second report  of KEMI75 reports  on volumes  of CMR substances (Cat.  1 & Cat. 2) in 
several types of plastics. it cannot be derived from the report which and how much of 
these  plastics  are  being  used  as  construction  articles  (which  is  the  purpose  of  our 
study); however: it does inform that large quantities of CMR substances (Cat. 1 & Cat. 
2) are used in plastics (and thus potentially also in the construction sector): in total 117 
CMR cat 1 &2 substances (>0.1%) are used in the manufacturing of plastics according 
to the Swedish Product Register, with an overall tonnage of 156 321 ton.  

The information in the report did not allow us to identify which CMR 1A/1B substances 
are used in which construction articles in Sweden.  
A  Swedish  report  on  the  environmental  and  health  risks  of  synthetic  turf76,  considers 
the composition of synthetic turf and concludes that based on the existing knowledge, 
the  risks  are  small.  However  exposure  data  are  scarce.  Synthetic  turf  often  contains 
rubber  granulate  from  waste  tyres,  which  in  turn  contain  several  substances  of  very 
high  concern,  such  as  polyaromatic  hydrocarbons  (PAHs),  phthalates  and  certain 
metals.  Most  PAHs  are  persistent  and  bioaccumulative;  some  are  classified  as 
carcinogenic  Cat.  2.    Some  phthalates,  such  as  diethylhexyl  phthalate  (DEHP),  dibutyl 
phthalate  (DBP)  and  butylbenzyl  phthalate  (BBP)  are  classified  as  reprotoxic  Cat.  1.  
Lead  affects  reproduction,  and  can  damage  the  nervous  system  and  cognitive 
development.  Chromium(VI)  is  carcinogenic.  Other  rubber  components  such  as  alkyl 
phenols and metals (zinc, copper, cadmium) are of great concern for the environment; 
however, they are not classified as CMR.    

In  a  recent  report  dealing  with  hazardous  substances  in  construction  products,  the 
Swedish Chemicals Agency identified 46 substances that are used in building products 
(KEMI, 2015). The sources for the selection of the substances were REACH dossiers and 

72 http://www.greenspec.co.uk/building-design/insulation-plant-fibre/  
73 Life Cycle Assessments of natural Fibre Insulation Materials. Final Repot, February 2008. Richard J Murphy 
and Andrew Norton 
74 http://www.kemi.se/Documents/Publikationer/Trycksaker/Rapporter/Rapport7-14-Ftalatuppdraget.pdf 
75 http://www.kemi.se/Documents/Publikationer/Trycksaker/Rapporter/Report-3-14.pdf 
76 Synthetic turf from a chemical perspective – a status report. Kemilalieinspektionen KEMI PM 3/06. 

87 

 
 
                                           
 
the EU-LCI (Lowest Concentration of Interest) list of limit values. KEMI considered the 
following categories of products: 

Insulation: plastic, wood wool, mineral wool 

-  Floor coverings: PVC, wood, tapestry, ceramics 
-  Paint: oil- and water based 
-  Boards: gypsum, cement, wood 
- 
-  Wall paper 
-  Glue, window kit, joints and more 
-  Tubes and pipes 
- 

Interior- and joinery products 

From the 46 substances identified by KEMI, 17 are classified CMR 1A/1B. From these 17 
CMR  1A/1B  substances,  nine  substances  are  also  identified  in  other  sources  in  this 
project as substances used in building materials, and are presented in Table 15. 

Table 15: CMR 1A/1B substances identified by KEMI (2015) and in other sources in this 
project, as substances being present in building products 

Substance 

CAS No. 

CMR classification 

1,2-Dimethoxyethane 

2-Ethoxyethanol 

2-Ethoxy-ethylacetate 

Acrylonitrile 

Dimethyl formamide 

Ethylene oxide 

Formaldehyde 

1-Methyl -2- pyrrolidone 

Tris(2-chloroethyl)phosphate 

110-71-4 

110-80-5 

111-15-9 

107-13-1 

68-12-2 

75-21-8 

50-00-0 

872-50-4 

115-96-8 

Repr 1B 

Repr 1B 

Repr 1B 

Carc 1B 

Repr 1B 

Carc 1B, Muta 1B 

Carc 1B, Muta 2 

Repr 1B 

Carc 2, Repr 1B 

Eight CMR 1A/1B substances  that were identified by KEMI were not found in any other 
source in this project as substances used in building products, probably at least partly 
due  to  the  broader  scope  of  the  KEMI  categories  which  also  included  glues,  paint,  kit 
and tapestry. These eight substances are listed in Table 16. 

88 

 
 
 
 
 
 
 
Table 16: CMR 1A/1B substances identified by KEMI (2015) but not by other sources in 
this project, as substances being present in building products 

Substance 

CAS No. 

CMR 
classification 

Use (REACH 
dossier) 

Bis(2-methoxyethyl) ether 
(Diglyme) 
2-Methoxypropyl acetate 

70657-70-4 

Repr 1B 

111-96-6 

Repr 1B 

Solvent 

2-Methoxy-1-propanol 

1589-47-5 

Repr 1B 

2-Methoxyethanol 

2-Methoxyethyl Acetate 

Acrylamide 

109-86-4 

110-49-6 

79-06-1 

N-ethyl-2-pyrrolidone 

2687-91-4 

Repr 1B 

Repr 1B 

Carc 1B, Muta 
1B, Repr 2 
Repr 1B 

Triethylene glycol dimethyl 
ether 

112-49-2 

Repr 1B 

No REACH dossier 
available 
No REACH dossier 
available 
Surface coatings 

Intermediate  

Monomer 

Coatings  

Solvent  

3.1.3 SUMMARY:  CMR 1A/1B SUBSTANCES CONTAINED IN CONSTRUCTION ARTICLES 

An overall list of CMR 1A/1B substances contained in construction articles was compiled 
based on information gathered via various sources and strategies (Table 17). The list is 
limited  to  substances  with  harmonised  CMR  1A/1B  classification.  A  list  of  non-
harmonised CMR substances contained in construction articles is included in Annex 1 of 
this report.  

In total, 31 CMR 1A/1B substances with at least one use in a construction article have 
been identified.  

Table 17 lists for each of the CMR 1A/1B substances with a use in a construction article 
information regarding the article category, or specific article in which the substances is 
used,  together  with  information  regarding  the  content  and  technical  function  of  the 
substances.  The  widely  use  of  the  CMR  1A/1B  substances  in  the  articles  was  roughly 
assessed  based  on  the  number  of  cases  in  which  the  substance  was  detected  in  the 
consulted sources, and on the manufactured/imported volume tonnage bands indicated 
in the registration dossiers. The latter might be informative to get a rough idea on how 
widespread the use of the substance is in general. However, it cannot be derived from 
this which fraction of the use specifically concerns construction articles. 

In  addition  to  the  information  per  substance  (listed  in  Table  17),  we  provide  the 
following general observations and considerations:  

1.  Only  the  BUMA  database  provides  information  concerning  emissions  from 
construction articles. The other information sources only provide information on the 
content  and/or  use  of  substances  in  the  production  of  construction  articles; 
however,  it  is  not  always  clear  whether  a  substances  used  for  the  production  of 
articles  is  still  present  in  the  final  article,  or  whether,  for  example,  the  substance 
reacted  with  other  substances,  and  is  no  longer  present  in  the  article.  Hence,  the 
use  of  a  substance  for  the  production  of  an  article  is  used  as  a  proxy  for  the 
presence  of  substance  of  an  article.  This  assumption  will  need  to  be  verified  for 
each  individual  case  (task  3).  Also  the  opposite  might  occur:  some  CMR  1A/1B 

89 

 
 
 
 
substances  are  not  used  for  the  production  of  construction  articles,  and  are 
therefore  assumed  not  to  be  initially  present  in  the  construction  article;  however, 
such  substances  have  been  demonstrated  to  be  released  from  articles  in  test 
chambers.    The  release  might  be  a  result  of  degradation  or  secondary  reactions 
(e.g. degradation of phthalates in PVC flooring). 

2.  Given  the  high  manufactured/imported  tonnage  bands  of  the  registration  dossiers 
and/or  the  multiple  information  sources  confirming  the  presence  of  the  CMR  in 
various  construction  sources,  several  CMR  1A/1B  substances  seem  to  have  a 
widespread  use  in  construction  articles.  This  is  the  case  for  formaldehyde,  DEHP, 
boric acid, disodium tetraborate anhydrous, acrylonitrile. 

3.  The identified uses of CMR 1A/1B substances in construction articles reflect a broad 
range of article categories and specific uses: CMR substances 1A/1B substances are 
used in the manufacturing of doors and windows, ceramic based products, thermal 
insulation  materials,  wall  covering,  concrete,  wood  based  panels,  PVC  flooring, 
gypsum  boards.  For  the  categories  of  “surfaces  for  sport  areas”,  “terraces”  and 
“playgrounds”, no use  of CMR substances  in these construction articles have been 
identified; however the use of recycled rubber tires for synthetic turf may result in 
the presence of CMR 1A/1B substances in for example “surfaces for sport areas”. 
4.  For  some  substances,  the  only  significant  information  source  was  the  BUMA 
database.  This  is  the  case  for  chloroprene,  dipentylphthalate,  dimethylformamide 
and benzene. Given the absence of REACH registrations and notifications for these 
substances  in  construction  articles,  it  can  be  assumed  that  these  substances  are 
present as an impurity (and likely present in concentrations < 0.1%). Moreover, for 
dimethylformamide,  chloroprene  and  dipentylphthalate, 
from 
construction  articles  was  detected  in  only  1,  2  and  3  construction  articles 
respectively out of the entire BUMA construction database (347 entries for articles 
and products); and therefore, it can be assumed that presence of these substances 
in  this  type  of  construction  articles  occurs  in  a  small  minority  of  this  type  of 
construction articles. 

release 

the 

5.  For several substances from the Authorisation list (Annex XIV), REACH notifications 
and  registrations  of  use  in  construction  articles  were  found  (which  date  probably 
from  before  the  sunset  date),  while  no  authorizations  for  a  specific  use  in 
construction  articles  are  in  place  (e.g.  trichloroethylene,  dibutylphthalate,  lead 
chromate,  2,4-dinitrotoluene,  Tris(2-chloroethyl)phosphate,  diarsenic  pentaoxide, 
benzylbutylphthalate).  It  is  expected  that  the  use  in  the  EU  of  these  CMR 
substances in construction products will disappear in EU manufactured articles from 
the “sunset date” onwards. Currently, there is no impact on these CMR levels from 
imported  articles.  However,  ECHA  can  use  restrictions  (Article  69.2)  to  deal  with 
imported articles. 

6.  For some substances (1-methyl-2-pyrrolidone (NMP); benzyl butyl phthalate (BBP)  
imidazolidine-2-thione;  diarsenic 
zirconia  aluminosilicate,  2,4-dinitrotoluene; 
pentaoxide; 2-ethoxyethyl acetate; 1,2-dimethoxyethane  and trichloroethylene) it 
is  unlikely  but  cannot  be  excluded  that  the  substances  are  used  in  construction 
articles.  For these substances, no use in construction articles was mentioned in the 
notification  dossiers.  In  the  section  regarding  the  information  contained  in 
registration dossiers (“Registration Information on identified uses related to article 
categories”),  the  following  sentence  was  added  in  the  relevant  dossiers:  “No 
registration  information  available  relating  to  the  use  of  the  substance  in  articles. 
The reason may be that the substance is not registered, that no Article Category is 
provided  in  the  registrations  for  the  substance  or  that  the  identified  uses  of  the 
registrations have been claimed confidential”. 
Based  on  this  statement,  it  cannot  be  excluded  that these  substances  are  used  in 
construction  articles.  However,  the  evidence  is  very  weak,  and  it  is  based  on  the 
available  information  not  possible  to  verify  their  presence  in  construction  articles, 
and,  if  used  in  construction  articles  -  it  cannot  be  identified  in  which  types  of 
construction  articles  these  substances  are  used.  Therefore,  these  substances  are 

90 

 
 
not taken forward to the overall list of CMRs present in construction articles unless 
there is information regarding presence from other sources in this task, or there is 
information from exposure data available (see further in 4.5: for trichloroethylene, 
BBP, 1-methyl-2-pyrrolidone and NMP). 

91 

 
 
 
  
 
Table 17: List of CMR 1A/1B substances contained in construction articles (compilation from different sources). Substances present in 
the authorization list (Annex XIV of REACH) are marked in bold & underlined 

Substance 

EC-
number 

CAS-
number 

Use in construction 
articles 

Likelihood/widespreadness 
of occurrence in 
construction articles 

Concentration of 
SVHC in article 

Technical 
function 

Information 
source(s) of 
presence of this 
CMR 1A/1B in 
construction 
article 

are 
by 

Aluminosilicate 
Ceramic 
Refractory 
fibres 
Fibres 
covered 
index 
number  650-017-00-
8  in  Annex  VI    of 
Regulation  (EC)  No 
1272/2008 

Formaldehyde 

200-
001-8 

50-00-0 

in  stone,  plaster, 
and 
glass 

use 
cement, 
ceramic articles 

unknown 

not  mentioned  in 
consulted sources 

SVHC 
notifications 
(ECHA  dissemination 
website) 

(cat.  1,  cat.  2,  cat.  5, 
cat. 7, cat. 10)  

Resilient, 
laminate floor coverings 

textile 

and 

widespread  occurrence  of 
formaldehyde 
these 
materials 

in 

vast  majority  of  data 
pertain 
emission 
to 
strengths  to  indoor  air 
(1-640  µg/h/m²)  and 
not 
formaldehyde 
content in the articles 

to 

is 
formaldehyde 
the 
used 
in 
production 
of 
resins  that  act  as 
glues  used 
for 
manufacturing  of 
construction 
articles 

Construction 
materials 
database BUMA; 

emission 

Gypsum  and  gypsum 
based products 

Round and sawn timber 

Wood based panels 

Wall covering 

92 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
  
  
  
  
 
 
 
  
  
  
  
 
 
 
  
  
  
  
 
 
 
  
Substance 

EC-
number 

CAS-
number 

Use in construction 
articles 

Likelihood/widespreadness 
of occurrence in 
construction articles 

Concentration of 
SVHC in article 

Technical 
function 

Thermal 
materials 

insulation 

SU  19:  building  and 
construction work; ERC 3 
in 
(formulation 
materials);  not 
further 
specified 

yearly tonnage band: 

1,000,000+ tonnes  

Information 
source(s) of 
presence of this 
CMR 1A/1B in 
construction 
article 

REACH 
registration 
dossiers:  substance 
used  in  building  and 
construction 
work 
(SU 19); formulation 
in materials (ERC 3) 

Dimethyl formamide 

200-
679-5  

68-12-2 

Benzene 

200-
753-7  

71-43-2 

Resilient, 
laminate floor coverings 

textile 

and 

Resilient, 
laminate floor coverings 

textile 

and 

Gypsum  and  gypsum 
based products 

Round and sawn timber 

Wood based panels 

Wall covering 

painted articles 

93 

small 

very 
occurrence  (1  material 
BUMA database) 

number 

of 
in 

available data pertain to 
emission  strengths 
to 
indoor  air  (10  µg/h/m²) 
and  not  to  content  in 
the articles 

not  mentioned  in 
consulted sources 

Construction 
materials 
database BUMA; 

emission 

widespread  occurrence  of 
benzene  releases  in  these 
materials 

available data pertain to 
emission  strengths 
to 
indoor  air  (10  µg/h/m²) 
and  not  to  content  in 
the articles 

not  mentioned  in 
consulted sources 

Construction 
materials 
database BUMA; 

emission 

RAR of benzene (EC, 
2008) 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
  
  
  
  
 
 
 
  
  
  
  
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Substance 

EC-
number 

CAS-
number 

Use in construction 
articles 

Likelihood/widespreadness 
of occurrence in 
construction articles 

Concentration of 
SVHC in article 

Technical 
function 

Ethylene oxide  

200-
849-9  

75-21-8 

SU  19:  building  and 
construction work; ERC 5 
(industrial  use  resulting 
in  inclusion  into  or  onto 
a  matrix);  not  further 
specified 

tonnage  band:  >  1,000,000 
tonnes/year 

unknown 

not  mentioned  in 
consulted sources 

Information 
source(s) of 
presence of this 
CMR 1A/1B in 
construction 
article 

registration 
REACH 
dossiers:  substance 
used  in  building  and 
construction 
work 
(SU  19);  (ERC  5) 
(ECHA  dissemination 
website) 

limited number of occurrence 
BUMA 
(5  materials 
database) 

in 

available data pertain to 
emission  strengths 
to 
(1-17 
air 
indoor 
µg/h/m²)  and  not  to 
content in the articles 

not  mentioned  in 
consulted sources 

Construction 
materials 
database BUMA; 

emission 

>  0.1  %  (threshold  for 
notification) 

not  mentioned  in 
consulted sources 

SVHC 
notifications 
(ECHA  dissemination 
website) 

Trichloroethylene 

201-
167-4  

79-01-6 

Resilient, 
laminate floor coverings 

textile 

and 

Wood based panels 

 No registration 
information available 
relating to the use of the 
substance in articles. 
The reason may be that 
the substance is not 
registered, that no 
Article Category is 
provided in the 
registrations for the 
substance or that the 
identified uses of the 
registrations have been 
claimed confidential. 

94 

 
 
  
  
  
  
  
  
  
  
  
  
  
Substance 

EC-
number 

CAS-
number 

Use in construction 
articles 

Likelihood/widespreadness 
of occurrence in 
construction articles 

Concentration of 
SVHC in article 

Technical 
function 

in 
no  authorized  use 
domain  of  construction 
article 
date: 
(sunset 
21/04/2016) 

Construction articles as a 
source  of  TCE  are  not 
mentioned in the RAR  

Di-isobutyl phthalate 

201-
553-2  

84-69-5  wall covering  

moderate 
of 
occurrence  (6  materials  in 
BUMA database) 

number 

cat  8: 
PVC 
(cushion vinyl) 

floor 

floor  covering: 
covering 

 notification 

no  authorized  use 
in 
domain  of  construction 
date: 
(sunset 
article 
21/02/2015) 

95 

available data pertain to 
emission  strengths 
to 
indoor 
(0.1-0.5 
air 
µg/h/m²)  and  not  to 
content in the articles 

>  0.1  %  (threshold  for 
notification) 

plasticizer 

Information 
source(s) of 
presence of this 
CMR 1A/1B in 
construction 
article 

not  in  the  list  of 
granted 
auhorizations  (ECHA 
dissemination 
website)  

RAR  of  TCE  (EC, 
2008) 

Construction 
materials 
database BUMA; 

emission 

SVHC 
notifications 
(ECHA  dissemination 
website) 

not  in  the  list  of 
granted 
auhorizations  (ECHA 
dissemination 
website)  

 
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
Substance 

EC-
number 

CAS-
number 

Use in construction 
articles 

Likelihood/widespreadness 
of occurrence in 
construction articles 

Concentration of 
SVHC in article 

Technical 
function 

Di butylphthalate  

201-
557-4  

84-74-2  wall covering  

moderate 
of 
occurrence  (8  materials  in 
BUMA database) 

number 

cat 1: used in roll doors 

 notification 

available data pertain to 
emission  strengths 
to 
indoor 
(1-37 
air 
µg/h/m²)  and  not  to 
content in the articles 

>  0.1  %  (threshold  for 
notification) 

plasticizer 

 notification 

>  0.1  %  (threshold  for 
notification) 

plasticizer 

insulation  and 
other: 
sealing  materials  in  air-
conditioning  units  and 
pumps 
heat 
tarpaulin 
covers 
(roofing) 

no  authorized  use 
in 
domain  of  construction 
date: 
(sunset 
article 
21/02/2015) 

Benzylbutylphthalate 

 201-
622-7  

85-68-7  cat 8: flooring material 

unknown 

> 0.1 % 

plasticizer 

Information 
source(s) of 
presence of this 
CMR 1A/1B in 
construction 
article 

Construction 
materials 
database BUMA; 

emission 

SVHC 
notifications 
(ECHA  dissemination 
website) 

SVHC 
notifications 
(ECHA  dissemination 
website) 

not  in  the  list  of 
granted 
auhorizations  (ECHA 
dissemination 
website)  

information 
from 
manufacturer  upon 
Article 33 Request 

No  authorized  use 
in 
domain  of  construction 
articles 
(sunset  date: 
21/02/2015) 

96 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Substance 

EC-
number 

CAS-
number 

Use in construction 
articles 

Likelihood/widespreadness 
of occurrence in 
construction articles 

Concentration of 
SVHC in article 

Technical 
function 

Acrylonitrile 

203-
466-5  

107-13-
1 

SU  19:  building  and 
construction work; ERC 3 
in 
(formulation 
materials);  not 
further 
specified 

tonnage  band:  1,000,000  - 
10,000,000 tonnes/year 

unknown 

not  mentioned  in 
consulted sources 

small  number  of  occurrence 
BUMA 
(4  materials 
database) 

in 

available data pertain to 
emission  strengths 
to 
(0-7.7 
air 
indoor 
µg/h/m²)  and  not  to 
content in the articles 

Resilient, 
laminate floor coverings 

textile 

and 

wood based panels 

it 

from  the  information  in 
is 
the  EU  RAR, 
that 
deduced 
construction 
articles 
inks  or 
treated  with 
lacquers  may  contain  2 
ethoxy-ethanol 

a 

as 

formed 
degradation 
product  from  PVC 
flooring 
and 
water-based glue  

Resilient, 
laminate floor coverings 

textile 

and 

limited number of occurrence 
(10  materials 
in  BUMA 
database) 

available data pertain to 
to 
emission  strengths 
indoor 
(4-20 
air 
µg/h/m²)  and  not  to 
content in the articles 

solvent  

2-Ethoxyethanol 

 203-
804-1  

110-80-
5 

2-Ethoxy-ethylacetate  

203-
839-2  

111-15-
9 

97 

Information 
source(s) of 
presence of this 
CMR 1A/1B in 
construction 
article 

registration 
REACH 
dossiers:  substance 
used  in  building  and 
construction 
work 
(SU  19);  (ERC  3) 
(ECHA  dissemination 
website) 

Construction 
materials 
database BUMA; 

emission 

RAR 
ethoxyethanol 
2008) 

2-
(EC, 

Construction 
materials 
database BUMA; 

emission 

 
  
  
  
  
  
  
  
  
  
  
 
 
 
Substance 

EC-
number 

CAS-
number 

Use in construction 
articles 

Likelihood/widespreadness 
of occurrence in 
construction articles 

Concentration of 
SVHC in article 

Technical 
function 

registration 
No 
information 
available 
relating to the use of the 
substance 
in  articles. 
The  reason  may  be  that 
is  not 
the  substance 
no 
registered, 
is 
Article 
the 
provided 
the 
registrations 
substance  or  that  the 
identified  uses  of  the 
registrations  have  been 
claimed confidential. 

that 
Category 
in 

for 

the EU RAR dossier on 2-EEA 
mentions that production and 
import  of  2-EEA  has  ceased, 
and  presumably,  at  present 
(2008), there are no uses  

Tris(2-
chloroethyl)phosphate 

204-
118-5  

115-96-
8 

in  stone,  plaster, 
and 
glass 

use 
cement, 
ceramic articles 

>  0.1  %  (threshold  for 
notification) 

(cat.  1,  cat.  2,  cat.  5, 
cat. 7, cat. 10)  

Impurity 
formed 
as  a  reaction  by-
the 
product 
in 
manufacture 
of 
other  commercial 
flame retardants 

98 

Information 
source(s) of 
presence of this 
CMR 1A/1B in 
construction 
article 

SVHC 
notifications 
(ECHA  dissemination 
website) 

RAR 
ethoxyethylacetate 
(EC, 2008) 

2-

SVHC 
notifications 
(ECHA  dissemination 
website) 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Substance 

EC-
number 

CAS-
number 

Use in construction 
articles 

Likelihood/widespreadness 
of occurrence in 
construction articles 

Concentration of 
SVHC in article 

Technical 
function 

roof insulation 

SU  19:  building  and 
construction  work;  ERC 
(Wide  dispersive 
10a 
outdoor  use  of  long-life 
articles  and  materials 
with 
low  release;  not 
further specified 

No  authorized  use 
in 
domain  of  construction 
articles 
(sunset  date: 
21/08/2015) 

cat.  1:  doors,  windows, 
shutters, 
building 
hardware  and  curtain 
walling:  fence  roll  doors, 
seals for windows, doors, 
wooden doors 

Bis 
ethylhexyl)phthalate 
(DEHP) 

(2-

204-
211-0  

117-81-
7 

10 - 100 tonnes  

unknown 

not  mentioned  in 
consulted sources 

widespread use 

> 0.1 %  

plasticizer 

Information 
source(s) of 
presence of this 
CMR 1A/1B in 
construction 
article 

EU RAR of TCEP (EC, 
2008)  

REACH 
registration 
dossiers:  substance 
used  in  building  and 
construction 
work 
(SU  19);  (ERC  10a) 
(ECHA  dissemination 
website) 

of 

list 
granted 
auhorizations  (ECHA 
dissemination 
website)  

SVHC 
notifications 
(ECHA  dissemination 
website) and RAR on 
DEHP (EC, 2008) 

cat  8: 
floor  covering 
made  by  PVC,  flooring 
tiles 
plastic 
flooring 
plastic 
PVC 
coverings 
(cushion vinyl 

floor 

floor 

others:  tarpaulin  covers 
(as 
roofing) 
shower  hoses  (sanitary 
appliances 

99 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
  
  
  
  
  
  
  
  
Substance 

EC-
number 

CAS-
number 

Use in construction 
articles 

Likelihood/widespreadness 
of occurrence in 
construction articles 

Concentration of 
SVHC in article 

Technical 
function 

authorized  use  of  DEHP 
in  manufacturing  of  PVC 
articles,  of  which  several 
construction 
used 
(e.g. 
flooring, 
window  frames,  plastic 
pipes) 

in 
PVC 

Information 
source(s) of 
presence of this 
CMR 1A/1B in 
construction 
article 

of 

list 
granted 
auhorizations  (ECHA 
dissemination 
website)  

Chloroprene 

204-
818-0  

126-99-
8 

Resilient, 
laminate floor coverings 

textile 

and 

N,N-
Dimethylacetamide 

204-
826-4  

127-19-
5 

gypsum  and  gypsum 
based products 

none  of  the  uses  in  the 
notification  dossier  could 
be  related  construction 
articles 

small 

very 
of 
occurrence  (2  materials  in 
BUMA database) 

number 

available data pertain to 
emission  strengths 
to 
(2-120 
air 
indoor 
µg/h/m²)  and  not  to 
content in the articles 

not  mentioned  in 
consulted sources 

Construction 
materials 
database BUMA; 

emission 

small 

very 
occurrence  (1  material 
BUMA database) 

number 

of 
in 

available data pertain to 
to 
emission  strengths 
indoor 
(1-6 
µg/h/m²)  and  not  to 
content in the articles 

air 

not  mentioned  in 
consulted sources 

Construction 
materials 
database BUMA; 

emission 

Dipentylphthalate 

210-
088-4  

605-50-
5 

wall coverings 

limited number of occurrence 
(3  materials 
BUMA 
database) 

in 

available data pertain to 
emission  strengths 
to 
indoor 
(0.8-2 
air 
µg/h/m²)  and  not  to 
content in the articles 

plasticizer 

100 

SVHC 
notifications 
(ECHA  dissemination 
website) 

Construction 
materials 
database BUMA; 

emission 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
Substance 

EC-
number 

CAS-
number 

Use in construction 
articles 

Likelihood/widespreadness 
of occurrence in 
construction articles 

Concentration of 
SVHC in article 

Technical 
function 

Information 
source(s) of 
presence of this 
CMR 1A/1B in 
construction 
article 

1-Methyl-2-
pyrrolidone 

212-
828-1  

872-50-
4 

Diboron trioxide 

 215-
125-8  

1303-
86-2 

101 

Resilient, 
laminate floor coverings 

textile 

and 

moderate 
of 
occurrence  (10  materials  in 
BUMA database) 

number 

available data pertain to 
emission  strengths 
to 
indoor 
(0-82 
air 
µg/h/m²)  and  not  to 
content in the articles 

not  mentioned  in 
consulted sources 

Construction 
materials 
database BUMA; 

emission 

No registration 
information available 
relating to the use of the 
substance in articles. 
The reason may be that 
the substance is not 
registered, that no 
Article Category is 
provided in the 
registrations for the 
substance or that the 
identified uses of the 
registrations have been 
claimed confidential.) 

it 

from  the  information  in 
is 
the  EU  RAR, 
that 
deduced 
articles 
construction 
treated  with 
inks  or 
lacquers  may  contain  1-
vinyl-2-pyrrolidone 

in  stone,  plaster, 
and 
glass 

use 
cement, 
ceramic articles 

>  0.1  %  (threshold  for 
notification) 

SVHC 
notifications 
(ECHA  dissemination 
website) 

trace  amount  as  a 
products 
in 
residue 
containing PVP 

impurity 

RAR  on  1  methyl-2- 
pyrrolidone 

>  0.1  %  (threshold  for 
notification) 

not  mentioned  in 
consulted sources 

notifications 
SVHC 
(ECHA  dissemination 
website) 

 
  
  
  
  
  
  
  
  
  
  
Substance 

EC-
number 

CAS-
number 

Use in construction 
articles 

Likelihood/widespreadness 
of occurrence in 
construction articles 

Concentration of 
SVHC in article 

Technical 
function 

(cat.  1,  cat.  2,  cat.  5, 
cat. 7, cat. 10)  

service  life  of  cellulose 
insulation (cat. 3) 

SU  19:  building  and 
construction work; ERC 3 
in 
(formulation 
further 
materials);  not 
specified 

SU  19:  building  and 
construction work; ERC 3 
in 
(formulation 
materials);  not 
further 
specified 

use in ceramics, glasses, 
enamels and plastics 

yearly  tonnage  band:  100  - 
1,000 tonnes  

unknown 

not  mentioned  in 
consulted sources 

1,000 - 10,000 tonnes  

unknown 

and 
pigments 
stabilizers 
to 
retard degradation 
process in PVC 

Cadmium oxide  

215-
146-2  

1306-
19-0 

Orange 
tetroxide) 

lead 

(lead 

215-
235-6  

1314-
41-6 

consumer 
ceramics (cat 2) 

use 

of 

>  0.1  %  (threshold  for 
notification) 

pigment 

102 

Information 
source(s) of 
presence of this 
CMR 1A/1B in 
construction 
article 

registration 
REACH 
dossiers:  substance 
used  in  building  and 
construction 
work 
(SU  19);  (ERC  3) 
(ECHA  dissemination 
website) 

REACH 
registration 
dossiers:  substance 
used  in  building  and 
construction 
work 
(SU  19);  (ERC  3) 
(ECHA  dissemination 
website) 

RAR on Cd oxide and 
Cd metal (EC) 

SVHC 
notifications 
(ECHA  dissemination 
website) 

 
 
  
  
  
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
Substance 

EC-
number 

CAS-
number 

Use in construction 
articles 

Likelihood/widespreadness 
of occurrence in 
construction articles 

Concentration of 
SVHC in article 

Technical 
function 

sulfochromate 
Lead 
yellow  (C.I.  Pigment 
Yellow 34) 

215-
693-7  

1344-
37-2 

103 

>  0.1  %  (threshold  for 
notification) 

pigment 

yearly tonnage band: 1,000 - 
10,000 tonnes  

unknown 

cat 1: fences: roll doors 

service 
life  of  coated 
articles:  stone,  plaster, 
cement, 
and 
ceramic  articles  ((cat.  1, 
cat. 2, cat. 5, cat. 7, cat. 
10) ) 

glass 

cat  6:  pigments 
articles (wood) 

in 

other:  tarpaurin  covers 
(e.g. roofing) 

SU  19:  building  and 
construction work; ERC 3 
in 
(formulation 
materials);  not 
further 
specified 

authorized  use  which  is 
potentially 
indirectly 
relevant  for  construction 
article  (authorized  use: 
Distribution  and  mixing 
pigment  powder  in  an 
industrial 
environment 
into solvent-based paints 
for non-consumer )use 

Information 
source(s) of 
presence of this 
CMR 1A/1B in 
construction 
article 

notifications 
SVHC 
(ECHA  dissemination 
website) 

REACH 
registration 
dossiers:  substance 
used  in  building  and 
work 
construction 
(SU  19);  (ERC  3) 
(ECHA  dissemination 
website) 

of 

list 
granted 
auhorizations  (ECHA 
dissemination 
website)  

 
  
  
  
  
 
 
 
  
  
  
  
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
 
 
  
 
 
 
Substance 

EC-
number 

CAS-
number 

Use in construction 
articles 

Likelihood/widespreadness 
of occurrence in 
construction articles 

Concentration of 
SVHC in article 

Technical 
function 

Nickel 

231-
111-4  

7440-
02-0 

Beryllium 

231-
150-7  

7440-
41-7 

Cadmium 

231-
152-8  

7440-
43-9 

Nickel used in production 
of  stainless  steel  (with 
uses 
in 
steel 
of 
construction sector) 

SU  19:  building  and 
construction work; ERC 3 
in 
(formulation 
materials);  not 
further 
specified 

SU  19:  building  and 
construction work; ERC 3 
in 
(formulation 
materials);  not 
further 
specified 

10 - 100 tonnes  

unknown 

not  mentioned  in 
consulted sources 

1,000 - 10,000 tonnes  

unknown 

and 
pigments 
stabilizers 
to 
retard degradation 
process in PVC 

use  of 
restricted 
articles 
plastic materials 

cadmium 
for  use 
for 

is 
in 
several 

use in ceramics, glasses, 
enamels and plastics 

Lead chromate 

231-
846-0  

7758-
97-6 

cat 1: fences: roll doors 

>  0.1  %  (threshold  for 
notification) 

not  mentioned  in 
consulted sources 

104 

Information 
source(s) of 
presence of this 
CMR 1A/1B in 
construction 
article 

RAR Ni 

registration 
REACH 
dossiers:  substance 
used  in  building  and 
construction 
work 
(SU  19);  (ERC  3) 
(ECHA  dissemination 
website) 

REACH 
registration 
dossiers:  substance 
used  in  building  and 
construction 
work 
(SU  19);  (ERC  3) 
(ECHA  dissemination 
website) 

REACH restriction  

RAR on Cd oxide and 
Cd metal (EC) 

SVHC 
notifications 
(ECHA  dissemination 
website) 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Substance 

EC-
number 

CAS-
number 

Use in construction 
articles 

Likelihood/widespreadness 
of occurrence in 
construction articles 

Concentration of 
SVHC in article 

Technical 
function 

other: 
coverings (e.g. roofing) 

tarpaulin 

No  authorized  use 
in 
domain  of  construction 
(sunset  date: 
articles 
21/05/2015) 

Boric acid 

233-
139-2; 
234-
343-4  

10043-
35-3; 
11113-
50-1 

in  stone,  plaster, 
and 
glass 

use 
cement, 
ceramic articles 

unknown 

>  0.1  %  (threshold  for 
notification) 

not  mentioned  in 
consulted sources 

(cat.  1,  cat.  2,  cat.  5, 
cat. 7, cat. 10)  

SU  19:  building  and 
construction work; ERC 3 
in 
(formulation 
further 
materials);  not 
specified 

Disodium  tetraborate 
anhydrous 

233-
139-2; 
234-
343-4  

10043-
35-3; 
11113-
50-1 

in  stone,  plaster, 
and 
glass 

use 
cement, 
ceramic articles 

(cat.  1,  cat.  2,  cat.  5, 
cat. 7, cat. 10)  

service  life  of  cellulose 
insulation (cat. 3) 

105 

>  0.1  %  (threshold  for 
notification) 

creates 
glass fiberization 

optimal 

flame retardant 

Information 
source(s) of 
presence of this 
CMR 1A/1B in 
construction 
article 

of 

list 
granted 
auhorizations  (ECHA 
dissemination 
website)  

SVHC 
notifications 
(ECHA  dissemination 
website) 

REACH 
registration 
dossiers:  substance 
used  in  building  and 
construction 
work 
(SU  19);  (ERC  3) 
(ECHA  dissemination 
website) 

SVHC 
notifications 
(ECHA  dissemination 
website) and RAR on 
Disodium 
tetraborate 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
  
  
  
  
 
 
 
  
Substance 

EC-
number 

CAS-
number 

Use in construction 
articles 

Likelihood/widespreadness 
of occurrence in 
construction articles 

Concentration of 
SVHC in article 

Technical 
function 

natural  fibre  insulation 
product (cat 3) 

of 

borates 

use 
in 
plasterboards  and  wood 
(cat. 6, cat. 10)  

SU  19:  building  and 
construction work; ERC 3 
in 
(formulation 
materials);  not 
further 
specified 

SU  19:  building  and 
construction work; ERC 3 
in 
(formulation 
materials);  not 
further 
specified 

SU  19:  building  and 
construction work; ERC 3 
in 
(formulation 
materials);  not 
further 
specified 

yearly 
band: 
tonnage 
100,000 - 1,000,000 tonnes  

not  mentioned  in 
consulted sources 

intermediate use only 

unknown 

not  mentioned  in 
consulted sources 

10 - 100 tonnes  

unknown 

not  mentioned  in 
consulted sources 

Magnesium nitrate 

233-
826-7  

10377-
60-3 

Potassium 
pentaborate 

234-
371-7  

11128-
29-3 

106 

Information 
source(s) of 
presence of this 
CMR 1A/1B in 
construction 
article 

REACH 
registration 
dossiers:  substance 
used  in  building  and 
work 
construction 
(SU  19);  (ERC  3) 
(ECHA  dissemination 
website) 

registration 
REACH 
dossiers:  substance 
used  in  building  and 
construction 
work 
(SU  19);  (ERC  3) 
(ECHA  dissemination 
website) 

REACH 
registration 
dossiers:  substance 
used  in  building  and 
construction 
work 
(SU  19);  (ERC  3) 
(ECHA  dissemination 
website) 

 
 
  
  
  
 
 
 
  
  
  
  
 
 
 
  
  
  
  
  
Substance 

EC-
number 

CAS-
number 

Use in construction 
articles 

Likelihood/widespreadness 
of occurrence in 
construction articles 

Concentration of 
SVHC in article 

Technical 
function 

Trilead 
phosphonate 

dioxide 

235-
252-2  

12141-
20-7 

lead-stabilized 
 'use  of 
plastic  materials  as  an 
internal 
structural 
component of buildings  

>  0.1  %  (threshold  for 
notification) 

stabilizer 

chromate 
Lead 
molybdate 
sulphate 
red (C.I. Pigment Red 
104) 

235-
759-9  

12656-
85-8 

cat 1: fences: roll doors 

>  0.1  %  (threshold  for 
notification) 

pigment 

life  of  coated 
service 
articles:  stone,  plaster, 
cement, 
and 
ceramic  articles  ((cat.  1, 
cat. 2, cat. 5, cat. 7, cat. 
10) ) 

glass 

cat  6:  pigments 
articles (wood) 

in 

other:  tarpaurin  covers 
(e.g. roofing) 

SU  19:  building  and 
construction work; ERC 3 
in 
(formulation 
materials);  not 
further 
specified 

yearly tonnage band: 1,000 - 10,000 tonnes  

107 

Information 
source(s) of 
presence of this 
CMR 1A/1B in 
construction 
article 

notifications 
SVHC 
(ECHA  dissemination 
website) 

notifications 
SVHC 
(ECHA  dissemination 
website) 

REACH 
registration 
dossiers:  substance 
used  in  building  and 
construction 
work 
(SU  19);  (ERC  3) 
(ECHA  dissemination 
website) 

 
  
  
  
  
  
 
 
 
  
  
  
  
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
Substance 

EC-
number 

CAS-
number 

Use in construction 
articles 

Likelihood/widespreadness 
of occurrence in 
construction articles 

Concentration of 
SVHC in article 

Technical 
function 

authorized  use  which  is 
potentially 
indirectly 
relevant  for  construction 
article  (authorized  use: 
Distribution  and  mixing 
pigment  powder  in  an 
industrial 
environment 
into solvent-based paints 
for non-consumer )use 

Information 
source(s) of 
presence of this 
CMR 1A/1B in 
construction 
article 

of 

list 
granted 
auhorizations  (ECHA 
dissemination 
website)  

108 

 
 
  
  
  
  
  
  
 
 3.2 ACTIVITY  2.2:  COMPILATION  OF  EXISTING  NATIONAL,  EUROPEAN  AND 
THIRD  COUNTRIES  LEGISLATION  RESTRICTING  CMR  SUBSTANCES  IN 
CONSTRUCTION PRODUCTS 

In  this  chapter,  an  overview  was  made  of  existing  national,  European  and  third 
countries legislation restricting CMR substances in construction products. As a starting 
point,  we  took  benefit  of  existing  reviews  on  European,  and  national  legislation  and 
policy concerning content of dangerous substances in construction products and articles 
(RPA,  201377;  VITO,  200678)  and  the  so-called  CP-DS  (Construction  Products  - 
Dangerous Substances) database on European and national legislation on substances in 
construction  products  maintained  and  published  by  the  European  Commission79.  This 
CP-DS is designed to help all interested parties to identify all relevant regulations in the 
field of dangerous substances in construction products, laid down in relevant European 
legislation and national laws (i.e. building codes, specific requirements for construction 
products  or  materials).  The  database  developers  aim  to  keep  the  information  in  the 
database up to date.  

In  addition,  we  have  sent  queries  to  our  national  contact  persons  in  different  EU  MS 
enquiring  about  recent  legislation  restricting  CMR  substances  in  construction  articles. 
VITO  has  an  excellent  network  throughout  Europe  in  the  domain  of  emissions  from 
construction articles, via active participants in various working groups such as the EU-
LCI network and the CEN committee (TC/351). This channel of information gathering is 
an efficient method, especially for countries for which language barriers might hamper 
is 
the  understanding  of  the  country-specific 
complementary to the CP-DS databases since the latter lacks information for several EU 
MS. 

legislation.  This  search  method 

This chapter focuses on legislation, and does not cover other policy instruments such as 
voluntary labelling.  

3.2.1 EU LEGISLATION RESTRICTING CMR SUBSTANCES IN CONSTRUCTION ARTICLES.  

An overview of EU legislation restricting CMR substances in construction articles is given 
in Table 18.  

At EU level, the REACH Regulation and the Construction Product regulation are the two 
legal frameworks with provisions for CMR 1A/1B content in construction articles.  

It  is  noted  that  other  EU  legislation  containing  aspects  of  hazardous  substance  in 
construction  products  mentioned  in  the  PRA  report  (2013)  (i.e.  Drinking  Water 
Directive,  Groundwater  Directive  2006/118/EC;  Green  Public  Procurement  (EC,  2008), 
Regulation  1272/2008  on  Classification,  Labelling  and  Packaging  of  Substances  and 
Mixtures)  do not contain provisions for labelling or restrictions on content or release of 
CMR  substances  from  construction  articles  under  scope  of  this  study  (categories  listed 
in task 1.1) and are therefore not listed in Table 18.  

77 RPA. 2013. Study on specific needs for information on the content of dangerous substances in construction 
products. Report prepared for DG Enterprise & Industry  
78  VITO,  2006.  Product  Policy  in  the  Context  of  the  Indoor  Environment  Quality.  VITO  report  nr 
2006/MIM/R/021 
79 http://ec.europa.eu/enterprise/construction/cpd-ds/index.cfm 

109 

 
 
 
                                           
 
Table 18: EU Regulations and Directives restricting CMR substances (1A/1B) in construction products 

Regulation/Directive  Stipulations for CMR substances in construction articles  

REACH Regulation  

(No 1907/2006) 

•  Prohibition  to  use  substances  on  the  Authorization  list  of  REACH  (Annex  XIV)  in 
articles > 0.1 % (content) after the sunset date, unless an authorization for that 
use is granted.  

Some  substances  on  the  authorization  list  have  CMR  1A/1B  properties;  majority  of 
REACH  registered  substances  with  CMR  1A/1B  properties  are  not  included  in  Annex 
XIV, and thus the restriction of use in max. 0.1 % does not apply to majority of CMR 
substances  

•  A  supplier  of  a  product  with  a  concentration  above  0.1%  weight  by  weight  of  a 
SVHC  (and  thus  CMR  1A/1B)  must  provide  1)  the  recipient  of  the  article  with 
sufficient information,  which  as  minimum  will include  the  name  of  the  substance 
(Article 33 of REACH)  

Applicability domain  

•  All  type  of  articles 
(thus 
including  all 
types  of  construction 
articles)  

•  Producers  and  importers  have  to  notify  to  ECHA  the  substances  listed  on  the 
Candidate  list  if  the  substance  in  the  article  is  >  0.1  %  weight  and  present  in 
quantities totalling > 1 tonne/year 

•  Restrictions  on  use  of  specific  substances  in  specific  uses.  The  substances/uses 
relevant  for  construction  articles,  together  with  what  the  restrictions  are,  are 
listed on p 77 

•  Authorizations  apply  for  the  use  of  Annex  XIV  substance  in  the  EEA.  Articles 
produced  outside  the  EEA  and  imported  to  the  EEA  are  not  affected  by 
authorization procedure, and hence may contain Annex XIV substances (>0.1%).  

•  All  types  of  articles 
(thus 
including  all 
types  of  construction 
articles) 

•  All  types  of  articles 
(thus 
including  all 
types  of  construction 
articles) 

•  Specific  articles:  see 

p 77 (task 2.1) 

110 

 
 
 
 
 
 
 
 
 
 
 
Regulation/Directive  Stipulations for CMR substances in construction articles  

Applicability domain  

Construction 
Product 
Regulation 
(305/2011/EU),  

replacing 
Construction 
Product  Directive 
(89/106/EEC) 

Basic Requirement 3 seeks to protect hygiene, health and the environment:  

“The  construction  works  must  be  designed  and  built  in  such  a  way  that  they  will, 
throughout  their  life  cycle,  not  be  a  threat  to  the  hygiene  or  health  and  safety  of 
workers,  occupants  or  neighbours,  nor  have  an  exceedingly  high  impact,  over  their 
entire  life  cycle,  on  the  environmental  quality  or  on  the  climate  during  their 
construction,  use  and  demolition,  in  particular  as  a  result  of  any  of  the  following:     
(a) the giving-off of toxic gas;  
(b)  the  emissions  of  dangerous  substances,  volatile  organic  compounds  (VOC), 
greenhouse gases or dangerous particles into indoor or outdoor air;  
(c) the emission of dangerous radiation;  

M366  deals  with  the  emissions  of  dangerous  substances  (focused  on  harmonised 
European measurement/test standards)  

The CPD/CPR is focused on existing regulatory requirements for product declarations, 
linked  to  different  assessment/evaluation  schemes.  Harmonized  product  standards 
have to cover these requirements and have to provide in annex ZA references to test 
methods (developed in CEN TC 351). 

Notwithstanding  CPD  was  converted  into  a  Regulation  (CPR),  the  implementation  of 
Basic Requirement 3 is not covered into a harmonized maximum content or emission 
levels  of  toxic  substances.  For  CE  marking  horizontal  standardised  assessment 
methods  for  dangerous  substances  have  been  developed  in  CEN/TC  351.  The 
interpretation  into  limit  values  for  dangerous  substances  is  done  at  Member  State 
Level. Currently the Commission is looking into the possibility of a common reporting 
format for emissions into indoor air80. 

80 Draft Harmonized EU VOC-Classes – Classification System for VOC Emissions of Construction Products used in the Indoor Environment, CEN/TC/351 N0588 document 

111 

 
 
                                           
 
Regulation/Directive  Stipulations for CMR substances in construction articles  

Applicability domain  

On  the  EU  level,  several  regulations  and  directives  from  the  fields  of  chemical  and 
environmental policy have direct interfaces with construction products and have to be 
taken  into  consideration  when  drafting  standards  for  test  methods  and  /  or  for 
construction  products.  As  such  the  CPR  is  linked  with  other  legislation  dealing  with 
CMR substances: 

• 

second measure under Article 6 (5) of the CPR requires safety data sheets (as referred 
to under Article 31 of REACH, or where applicable information on substances in articles 
as stated under Article 33 of REACH) to accompany the Declaration of Performance 

•  Regulation (EC) No 850/2004 on Persistent Organic Pollutants266;  
•  Water Framework Directive 2008/105/EC267; and  
•  Groundwater Directive 2006/118/EC268.  
•  As noted in recital 25 of the CPR: 

Construction 
Product 
Regulation 
(305/2011/EU),  

replacing 
Construction 
Product  Directive 
(89/106/EEC) 

This  Regulation  is  without  prejudice  to  Member  States'  rights  and  obligations 
pursuant to other instruments of Union law that may apply to hazardous substances, 
in particular, Directive 98/8/EC of the  European Parliament and of the Council of 16 
February  1998  concerning  the  placing  of  biocidal  products  on  the  market,  Directive 
2000/60/EC  of  the  European  Parliament  and  of  the  Council  of  23  October  2000 
establishing a framework for Community action in the field of water policy, Regulation 
(EC)  No  1907/2006,  Directive  2008/98/EC  of  the  European  Parliament  and  of  the 
Council  of  19  November  2008  on  waste  and  Regulation  (EC)  No  1272/2008  of  the 
European  Parliament  and  of  the  Council  of  16  December  2008  on  classification, 
labelling and packaging of substances and mixtures. 

The  CMR  provisions  in  the  CPR  are  limited  to  recital  25  and  article  6(5).  Other 
provisions  are  the  notified  regulations  at  EU  and  national  level  (vide  infra)  dealing 
with  CMR  substances  that  have  to  be  taken  into  account  in  the  harmonized  product 
standards for obtaining CE marking81,82. 

81 EGDS document DS 214 (2011) “Notified Regulations Concerning ER 3 – Selection Criteria for Product Mandates under the CPD/CPR” 

82 Extract M366 “These works are subject to legislative, regulatory or administrative regulations of Member States covering such essential requirements specifically in the 
field of dangerous substances” 

112 

 
 
 
 
 
                                           
 
3.2.2 NATIONAL LEGISLATIONS IN EU MEMBER STATES 

An overview of national legislations in EU Member States restricting CMR substances in construction articles is given in Table 19.  

Table 19: National legislations in EU Member States restricting CMR substances (1A/1B) in construction products 

Member State  Legislation 

Restrictions CMR substances (1A/1B) in construction products? 

Applicable for 

to 

for 

The  Royal  Decree 
establishing  threshold 
the 
levels 
emissions 
the 
environment 
indoor 
construction 
from 
(Royal 
products 
8th  May 
Decree 
2014;  published 
in 
Belgian  Bulletin  of 
Decrees 18.08.2014) 

Annex  2:  CMR  substances  1A  &  1B  according  to  CLP  Regulation 
1272/2008 shall be below 1 µg/m³ (release) after 28 days testing 
(testing according to ISE 16000-11, CEN/TS 16516) 

Articles  not  meeting  this  requirement:  exempted  from  the  Belgian 
market.  

floor covering materials 

to  other 
(extensions 
categories 
indoor 
construction  articles  is 
foreseen) 

of 

At present, there are conflicting provisions for formaldehyde: on the 
one  hand,  there  is  the  above  emission  limit  of  1  µg/m³  for  CMR 
substances,  and  on  the  other  hand,  the  Royal  Decree  stipulates  a 
limit  of  100  µg/m³  after  28  days  testing  (testing  according  to  ISE 
16000-11, CEN/TS 16516). The Belgian authorities are in the phase 
of  resolving  this  conflicting  provision,  and  hereby  aiming  to  give 
priority to the limit of 100 µg/m³ for formaldehyde.  

Belgium 

113 

 
 
Member State  Legislation 

Restrictions CMR substances (1A/1B) in construction products? 

Applicable for 

Denmark 

Statutory  Order  from 
the  Ministry  of  the 
Environment  no.  857 
of  5  September  2009 
on  limitation  of  sale 
and  use  of  some 
chemical 
dangerous 
substances 
and 
products  for  specific 
purposes 

Products  (including  construction  articles)  must  not  contain  more 
than 0.0075 per cent by weight Cadmium (content)83 

All products and articles 

There  are  some  exceptions  from  the  ban  (e.g.  colour  pigment  for 
ceramic products, dental concrete, etc.) 

of 

the 

Ministry 
Environment 
Statutory  Order  no. 
289  of  22  June  1983 
on 
for 
limits 
formaldehyde  in  chip 
board,  plywood  and 
similar panels used in 
furniture 
and 
furnishings 

Chip board, plywood, and other wood-based panel containing 
formaldehyde-emitting glue may only be used in furniture and 
furnishings if they release no more than 0.15 milligrams of 
formaldehyde per cubic metre of air when tested in a climate 
chamber (release) 

All  chip  board,  plywood 
and similar panels made 
using  glue  that  emits 
formaldehyde. 

If an enterprise is unable to document fulfilment of this 
requirement, they are permitted to use panels with a maximum free 
formaldehyde level of 25 milligrams per 100 grams dry matter in 
the panel (content) 

No  specific  stipulations  regarding  CMR  substances  in  construction 
articles other than for above ones.  

83 http://www.mst.dk/English/Chemicals/legislation_on_chemicals/fact_sheets/Fact_Sheet_ 

114 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                           
 
Member State  Legislation 

Restrictions CMR substances (1A/1B) in construction products? 

Applicable for 

Since  1  January  2012,  new  building  and  decoration  products 
intended  for  indoor  use  (various  coverings,  panels,  insulation 
materials,  etc.)  can  only  be  marketed  if  they  bear  a  label  with 
information on the emission of volatile pollutants (Articles R221-22 
to R221-28). (release) 

The  emissions  of  10  substances  and  the  "total  volatile  organic 
compounds" parameter (TVOC) have to be measured and classified 
into four categories from A+ to C. 

Formaldehyde 
categorization of label 1A+ to C. 

is  the  only  CMR  substance 

in  this 

list 

for 

Construction 
decoration 
(indoor uses) 

and 
products 

In  addition,  the  Decree  prescribes  that  it  is  forbidden  to  use  CMR 
substances  in  the  manufacturing  of  construction  and  decoration 
products, 
substances: 
trichloroethylene, benzene, DEHP and dibutylphthalate 

following  CMR 

namely 

the 

for 

Décret  88
foams  in  buildings  intended  for  permanent  or  semi
human occupation 

683  of  06/05/1988  on  the  use  of  ureaformaldehyde 
permanent 

‐

Arrêté  of  06/05/1988  fixing  a  maximum  content  of  formaldehyde 
coming  from  urea
formaldehyde  foams  in  buildings  intended  for  a 
permanent or semipermanent human occupation 

‐

‐

Decree  no.  2011-321 
and  the  Order  of  19 
April 2011 concerning 
the 
of 
labelling 
building, 
wall 
coverings  or  flooring 
products 
of 
paints  and  varnishes 
with  respect  to  their 
emission  of  volatile 
pollutants. 

and 

notifications 
2009-
701-F  and  2009-702-
F 

1987-0125-F 

France  

115 

 
 
 
 
 
 
 
 
 
Member State  Legislation 

Restrictions CMR substances (1A/1B) in construction products? 

Applicable for 

Germany 

German  regulation  – 
Notification  number: 
009/167/D 
- 
Principles  of  health 
assessment 
of 
construction  products 
in 
indoor 
environments 

Lithuania 

Lithuanian 
Hygiene 
Norm  HN  105:2014 
"Polymer  construction 
products and polymer 
furniture materials 

(draft  amendment  of 
Order 
V-985) 
Notification  number 
2014/530/LT 

Testing criteria after 3 days emission in test room (release): total 
of detected carcinogenic substances:< 0.01 mg/m³ 

Testing criteria after 28 days emission in test room: AgBB Criteria : 
< 1 µg/m3 for all CMR 1A/1B 

Specific stipulations for formaldehyde: 100 µg/m³ (28 days test) 

Carcinogenic (T, R 45; T, R 49) and mutagenic (T, R 46) substances 
of  Categories  1  and  2  pursuant  to  the  European  Directive 
67/548/EEC may not be actively used84 unless it can be proven that 
they  do  not  present  a  risk  to  the  health  of  users,  buildings  or  the 
environment. 

Only  compliant  materials  have  admission  to  commercialization  in 
Germany 

Testing criteria after 28 days emission in test room (release) : < 1 
µg/m3 for all CMR 1A/1B 

Specific stipulations for formaldehyde: 124 µg/m³ (28 days test) for 
flooring  and  wood  based  panels  using  materials  containing 
formaldehyde 

Only  compliant  materials  have  admission  to  commercialization  in 
Lithuania 

coverings, 
Floor 
adhesives, 
underlays, 
coatings 
floor 
coverings  +  decorative 
wall 
(EN 
coverings 
15102) 

for 

All  polymer  construction 
products  and  polymer 
furniture  for  installation 
indoors 

84  
as contaminations and/or residual monomers. 

Active use is the targeted use of substances to achieve particular product properties. Non-"actively used" substances are those which are present in the product 

116 

 
 
 
 
                                           
 
Member State  Legislation 

Restrictions CMR substances (1A/1B) in construction products? 

Applicable for 

of 

Applies to particleboard, 
defined  as  a  plate 
consisting 
small 
particles  of  wood  or 
lignocellulosic 
other 
an 
materials 
organic 
binder. 
Specifically  those  that 
contain articles.  

with 

the 
Netherlands  

Chipboard 
Act) 
(Commodities 
Decree  (Decree  26 
August 
1986) 
(Spaanplaatbesluit 
Warenwet 85 

Chipboard/particleboard per 100g must contain no more than 10mg 
formaldehyde sheet.  

85 http://wetten.overheid.nl/BWBR0004021/geldigheidsdatum_17-04-2013 

117 

 
 
 
 
 
 
 
 
 
 
 
  
 
 
                                           
 
Member State  Legislation 

Restrictions CMR substances (1A/1B) in construction products? 

Applicable for 

Poland 

The  Polish  regulation 
defining  maximum 
values 
rooms 
for 
intended  for  human 
residence 
(“Monitor 
Polska  NR  19/1996, 
pos. 231”)  

Construction  materials, 
and 
facilities 
components  of  furniture 
used  in  rooms  intended 
for human residence 

Criteria  after  28  day  release  testing  for  35  individual  compounds, 
of which 5 CMR substances:  

• 

• 

• 

• 

• 

benzene:  <  10  µg/m3  for  category  A  premises  and  20  µg/m3  for 
category B premises 

formaldehyde:  50  µg/m3  for  category  A  premises  and    100  µg/m3 
for category B premises 

dibutylphthalate:  100  µg/m3  for  category  A  premises  and    150 
µg/m3 for category B premises 

trichloroethylene:  150  µg/m3  for  category  A  premises  and  200 
µg/m3 for category B premises 

vinylchloride:  5  µg/m3  for  category  A  premises  and  10  µg/m3  for 
category B premises 

The  Polish  regulation  is  a  not  notified  legislation.  The  Polish 
Regulation from 1996 is included on legal grounds although it is not 
notified as it derives from the time before Poland joined the EU and 
the regulation is not in contradiction with community law.  

Materials  not  compliant  with  the  regulation  are  not  allowed  on  the 
Polish market 

An  overview  of  EU  Member  States  for  which  national  legislation  specifically  addressing  CMR  substances  in  construction  products  is 
lacking is given in Table 20. 

118 

 
 
 
 
 
 
 
Table 20: Overview of countries for which national legislation specifically addressing CMR substances in construction products is lacking  

Country 

Legislation 

Restrictions CMR substances in construction products 

Application domain 

No  general  legislation  on  CMR  1A/1B  in  construction 
articles  

Finished products which 
contain formaldehyde 

Restrictions for some specific CMR substances and uses: 
restrictions  for  the  placing  on  the  Market  and  Labelling 
of  Substances,  Preparations  and  Finished  Products 
which contain formaldehyde 

Austria 

ORDINANCE  OF  THE  FEDERAL  MINISTER 
OF  THE  ENVIRONMENT,  YOUTH  AND  THE 
FAMILY  OF  FEBRUARY  12  1990 
CONCERNING  RESTRICTIONS  FOR  THE 
PLACING  ON 
AND 
SUBSTANCES, 
LABELLING 
FINISHED 
PREPARATIONS 
PRODUCTS 
CONTAIN 
FORMALDEHYDE;  

THE  MARKET 
OF 

WHICH 

AND 

REGULATION OF THE FEDERAL MINISTER 
FOR  THE  ENVIRONMENT  CONCERNING 
BANS  AND  RESTRICTIONS  OF  ORGANIC 
REGULATION 

(SOLVENT 

SOLVENTS 
LMVO 199  

QUALITY  REGULATIONS  FOR  ELASTIC 
FLOORING MATERIALS;  

ORDER  OF  THE  FEDERAL  MINISTER  FOR 
AGRICULTURE  AND  FORESTRY,  THE 
ENVIRONMENT 
WATER 
MANAGEMENT  CONCERNING  BANS  AND 
PARTIALLY 
RESTRICTIONS 

AND 

ON 

FLUORINATED  AND  FULLY  FLUORINATED 

HYDROCARBONS  AS  WELL  AS  SULPHUR 
HEXAFLUORIDE (HFC/FC/SF6 ORDER). 

Bulgaria 

No relevant national legislation 
found  

119 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country 

Legislation 

Restrictions CMR substances in construction products 

Application domain 

Decree 163/2002 86 This law requires that buildings 
should be safe for residents and neighbours, including 
the release of toxic/dangerous gases and particles. 
However, this Decree does not appear to contain any 
requirements on specific substances or CMR substances  

Only regulations for indoor air quality (Notification: 
2007-372-FIN) 

Cyprus 

Czech 
Republic  

Estonia 

Finland  

Greece 

Hungary  

Iceland 

Ireland  

No relevant national legislation 
found  
Decree 163/2002 

No relevant national legislation 
found 
No national legislation concerning 
CMR substances in construction 
articles are in force in Finland 
(voluntary M1-classification). 
No relevant national legislation 
found 
No relevant national legislation 
found 
No relevant national legislation 
found 
No relevant national legislation 
found 

86 http://www.vups.cz/download/Y1_NV-163_2002+312_2005_fin_AO227.pdf  

120 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                           
 
 
Country 

Legislation 

Restrictions CMR substances in construction products 

Application domain 

Italy  

Legislatura 16ª - 13ª 
Commissione permanente - 
Resoconto sommario n. 348 del 
29/05/2012).  

Latvia 

No relevant national legislation 
found 

Lichtenstein   No relevant national legislation 

found 

Luxembourg  No relevant national legislation 

Malta 

found 
No relevant national legislation 
found 

Norway  

No relevant national legislation 
found 

Portugal  

No relevant national legislation 
found 

121 

In the security part of the law, criteria related to 
migration of elements to water and on VOC emission 
from materials are also set. It also includes regulations 
on the reduction of toxic emissions and harmful 
materials, elements and components as one of the 
prerequisites of the UNI 11277, 2008 standard.  
This law does not have specific provisions for CMR 
substances in construction articles  

Technical standards/codes currently being used are 
those adopted in the UK (see UK). There is a new waste 
strategy but nothing related to the content of hazardous 
substances in construction products. 

Norway established The Product Register (PR) in 1981. 
PR operates the authorities’ central register of 
substances and chemical products (chemicals). The 
information is used as a tool for preventing damage to 
health and the environment caused by chemicals. PR 
currently holds information on more than 25 000 
products. 

In addition to this PR information tool, Norway has no 
specific legal enforceable provisions regarding CMR 
SUBSTANCESs in construction articles  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country 

Legislation 

Restrictions CMR substances in construction products 

Application domain 

Romania 

Slovakia 

No relevant national legislation 
found 
Act on construction products 
(69/2009) and Decree on 
construction products (Predpis č. 
558/2009) 

Slovenia  

Construction Act (Zakon o graditvi 
(ZGO-1))  

Spain  

Building Act (Ley 38/1999), 
modified in 2001 and 2002 

122 

The Act lays down conditions for the marketing of 
construction products while the Decree establishes a list 
of groups of construction products and systems for 
assessing the parameters thereof. However, as these 
laws appear not to deal with the regulation of specific 
substances in construction products, these were not 
considered further in the report of PRA (2013). 
Presumably, it has no provisions for CMR 
substances 
Article 38: “The project (construction works) 
documentation for the reconstruction or removal of 
works must also contain documentation on the 
measures to prevent the emission of dust and other 
dangerous substances and on the management of 
construction waste 

The Construction Act does not stipulate criteria for max. 
levels of content or release of CMR substances in 
construction articles, neither for criteria for labelling of 
CMR substances in construction articles  
Building Act (Ley 38/1999), modified in 2001 and 2002, 
which applies to new builds, refurbishments/extensions, 
urban infrastructure and building services.  
The Building act mentions in several cases hazardous 
substance content: for example when dealing with pipes 
and other materials in contact with water, and emission 
of substances (for example formaldehyde emission) are 
considered. 

From the context of the RPA report, it was derived that 
no mandatory criteria for CMR content or release were 
in place in Spain  

 
 
 
 
 
 
 
 
 
 
 
 
Country 

Legislation 

Restrictions CMR substances in construction products 

Application domain 

Wood based boards 

.  

All goods 

Sweden  

The swedish chemicals agency’s 
chemical products and 
biotechnical organisms 
Regulations (Kifs 2008:2)  
(Notification 2008-243-S) 

Anyone who manufactures or imports to Sweden wood-
based boards must ensure that the untreated boards do 
not give off more formaldehyde than 0.124 mg 
formaldehyde/m3 of air. This threshold corresponds to 
the emission class E1. 

Swedish ban on the use of Mercury  

Sweden established in 2010 a national action plan for a 
toxic-free everyday environment. This action plan 
should be regarded as a strategy or policy rather than a 
strict legislation but legislative measures can of course 
be used as tools in order to reach the goals in the 
action plan. 

Construction articles are one of the prioritized product 
groups in this Swedish plan.  
Building Regulations in the UK set functional 
requirements on the performance of controlled works. 
Building regulations and standards are not prescriptive 
about which products and articles may or may not be 
used, and they do not require declarations relating to 
dangerous substances (such as CMR substances) in 
construction articles.  

UK 

Building Act 1984, and 
amendments (e.g. regulation 
2015) 

123 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
For  EU  Member  States  having  implemented  the  compliance  to  prEN  16516  in  their  legal 
framework for maximum emissions of VOCs and SVOCs from construction articles (i.e. Belgium 
for  flooring  materials;  Germany  for  flooring  materials  and  decorative  wall  paper),  there  is  a 
maximum emission level of CMR substances  1A/B set at 1 µg/m³ (test chamber at 28 days). 
This rule applies to the CMR 1A/1B substances given in Table 21 and Table 22. 

It is remarked that the list of regulated carcinogenic VOC and SVOC substances  (Table 21 and 
Table 22) is much longer than the list of CMR  1A/1B substances identified as presented in or 
released  from  construction  articles  (from  task  2.1:  see  Table  17).  The  reason  for  the 
discrepancy relies in the fact that the list of regulated carcinogenic VOCs and SVOCs (Table 21 
and  Table  22)  is  based  on  analytical  capacity  to  identify  and  measure  these  substances 
according  to  the  methods  prEN  16516;  however,  no  considerations  regarding  whether  these 
substances  are  effectively  released  from  construction  articles  have  been  in  made  when 
constructing the list of regulated carcinogenic VOCs and SVOCs according to prEN 16516.  

This  European  Standard  “Construction  products  -  assessment  of  release  of  dangerous 
substances  -  determination  of  emissions  into  indoor  air”  (prEN16516)    was  developed  under 
the remit of Mandate M/366 "Development of horizontal standardized assessment methods for 
harmonised  approaches  relating  to  dangerous  substances  under  the  Construction  Products 
Regulation (CPR)" addressing the preparation of horizontal measurement/test methods for the 
determination of  emission of  regulated dangerous  substances from construction products into 
indoor air.  

Table 21: An overview of regulated carcinogenic VOCs (categories 1A/1B according to the prEN 
16516 emission testing protocol

) 

87

No. 

1.  

2.  

3.  

4.  

5.  

6.  

7.  

8.  

9.  

10.  

11.  

12.  

13.  

14.  

15.  

16.  

17.  

CAS-number 

Name 

79–06–1  

107–13–1  

106–92–3  

71–43–2  

Acrylamide  

Acrylonitrile  

Allyl glycidyl ether  

Benzene  

1464–53–5  

2,2'-Bioxirane  

542–88–1  

101–90–6  

106–47–8  

106–89–8  

Bis (chloromethyl) ether  

Resorcinol diglycidyl ether  

4-Chloroaniline  

Epichlorhydrine  

51594–55–9  

(R)-(-)-Epichlorohydrine  

95–69–2  

4-Chloro-2-methylaniline  

100–44–7  

Benzyl chloride  

14977–61–8  

Chromyl chloride  

96–12–8  

106–93–4  

764–41–0  

505–60–2  

1,2-Dibromo-3-chloropropane  

1,2-Dibromoethane  

1,4-Dichlorobut-2-ene  

Bis(2-chloroethyl) sulfide  

87  DRAFT  prEN  16516,  May  2015,  Construction  products  -  Assessment  of  release  of  dangerous  substances  - 
Determination of emissions into indoor air 

124 

 
 
 
                                           
 
CAS-number 

Name 

107–06–2  

Ethylene dichloride  

96–23–1  

1,3-Dichloro-2-propanol  

542–75–6  

1,3-Dichloropropene, isomers  

79–44–7  

540–73–8  

106–87–6  

680–31–9  

90–04–0  

120–71–8  

592–62–1  

51–75–2  

Dimethylcarbamoyl chloride  

N,N'-Dimethylhydrazine; 1,2-Dimethylhydrazine  

Vinylcyclohexane diepoxide  

Hexamethylphosphoric triamide  

2-Methoxyaniline  

6-Methoxy-m-toluidine  

Methyl azoxy methyl acetate  

N-Methylbis(2-chloroethyl)amine  

838–88–0  

4,4-Methylenedi-o-toluidine  

15159–40–7  

Morpholine-4-carbonyl chloride  

79–46–9  

2-Nitropropane  

924–16–3  

N-Nitrosodibutylamine  

55–18–5  

621–64–7  

601–77–4  

612–64–6  

N-Nitrosodiethylamine  

Nitrosodipropylamine  

N-Nitrosodiisopropylamine  

N-Ethyl-N-nitrosoaniline  

1116–54–7  

2,2'-(Nitrosoimino)bisethanol  

10595–95–6  

N-Methyl-N-nitroso-ethylamine  

59–89–2  

100–75–4  

930–55–2  

88–72–2  

N-Nitrosomorpholine  

N-Nitrosopiperidine  

N-Nitrosopyrrolidine  

2-Nitrotoluene  

122–60–1  

Phenyl glycidyl ether  

1120–71–4  

1,3-Propansulton  

91

22

5  

94–59–7  
‐
96–09–3  

‐

95–06–7  

Quinoline  

5-Allyl-1,3-benzodioxole  

Styrene oxide  

Sulfallate  

5216–25–1  

4-Chlorobenzotrichloride  

509–14–8  

Tetranitromethane  

95–53–4  

o-Toluidine  

2431–50–7  

2,3,4-Trichlorobut-1-ene  

79–01–6  

96–18–4  

98–07–7  

Trichloroethylene  

1,2,3-Trichloropropane  

Benzotrichloride  

137–17–7  

2,4,5-Trimethylanilin  

51–79–6  

Urethane  

No. 

18.  

19.  

20.  

21.  

22.  

23.  

24.  

25.  

26.  

27.  

28.  

29.  

30.  

31.  

32.  

33.  

34.  

35.  

36.  

37.  

38.  

39.  

40.  

41.  

42.  

43.  

44.  

45.  

46.  

47.  

48.  

49.  

50.  

51.  

52.  

53.  

54.  

55.  

56.  

57.  

125 

 
 
Table 22: An overview of regulated carcinogenic SVOCs (categories 1A/1B)

88

No. 

1.  

2.  

3.  

4.  

5.  

6.  

7.  

8.  

9.  

10.  

11.  

12.  

13.  

CAS-number 

Name 

60

09

3 

92

67

1 

‐

‐

103
‐

33
‐

3 

119

93

7 

‐

‐

101

77

9 

‐

‐

95

80
‐

7 
‐

118
‐

74
‐

1 

95

80
‐

7 
‐

91

59

8 

‐

‐

91

‐

23

‐

6  

92

93

3 

‐

‐

581
‐

89
‐

5 

101

1  

61

‐

‐

‐

‐

4

Aminoazobenzene  

4

‐

Aminobiphenyl 

Azobenzene 

‐

4,4'

Bi

o

toluidine  

4,4'
‐

Diaminodiphenylmethane (MDA) 

‐

‐

4

Methyl

‐

m

phenylenediamine 

Hexachlorobenzene 

‐

4

Methyl

m

phenylenediamine 

‐

‐

‐

‐

2

‐

2

‐

4

‐

2

‐

Naphthylamine  

Nitroanisole  

Nitrobiphenyle 

Nitronaphtalene 

Methylenebisdimethylaniline 

‐

88  Indicative  List  of  Regulated  Dangerous  Substances  possibly  associated  with  construction  products  under  the  CPD, 
EGDS document DS 041/051 rev.12 

126 

 
 
 
 
 
                                           
 
3.2.3 THIRD COUNTRIES REGULATION CMR SUBSTANCES IN CONSTRUCTION ARTICLES  

United States of America (US) 

In the US, the authority of taking consumer product policy measures is scattered over 
different  governmental  bodies  from  the  federal  government  and  state  government.  In 
general,  product  policy  in  the  US  puts  stress  on  voluntary  labelling  schemes.  In  this 
section  of  the  report,  voluntary  labelling  and  testing  schemes  are  not  further 
considered. 

A  horizontal  mandatory  legislation  restricting  or  limiting  content  or  release  of  CMR 
(1A/1B) substances in articles (such as construction articles) is not in place in the US. 
Instead, there are bans and restrictions in place for specific (combinations of) consumer 
products and substances. The website of U.S. Consumer Product Safety 89 provides a list 
of  substances/uses  for  which  restrictions  or  ban  is  in  place.  The  majority  of  the 
restrictions  and  bans  refer  to  substances  in  (household)  products  and  less  to  articles. 
The  articles  for  which  some  restrictions  or  bans  apply  are  toys,  garments,  etc. 
However,  upon  Consultation  of  the  Product  Safety  (listing  the  Regulations,  Mandatory 
Standard  and  Bans  in  US)  during  this  project  (May  2015)  no  construction  articles 
(covered  in  list  1.1)  are  present  on  the  ban/restriction  list  of  the  U.S.  Consumer 
Product Safety.  

California  is  the  US  Member  State  with  a  long  history  and  policy  on  safe  use  of 
chemicals.  

In  California,  testing  methods  and  performance  criteria  for  construction  products  and 
articles are based on California Department of Public Health Standard Method (Section 
01350), “Standard Method for the Testing and Evaluation of Volatile Organic Chemical 
Emissions  from  Indoor  Sources  Using  Environmental  Chambers.”  The  standard  is 
gaining  nationwide  acceptance  as  the  benchmark.  It  was  first  established  for 
commercial  buildings  such  as  offices  and  schools;  a  section  for  new  single-family 
residences was added later. 

Section 01350 of this standard specifies maximum allowable concentrations of 35 VOCs 
in model rooms; two of these substances have CMR 1A/1B properties:  

Benzene: max. allowable concentration: 30 µg/m³; trichloroethylene: 300 µg/m³  

California  testing  method  and  performance  criteria  are  used  as  a  benchmark,  and 
materials  used  in  public  buildings  in  California  mandatory  need  to  comply  with  these 
criteria. In other context (outside California, materials for private residential use), there 
are no legal obligations to comply with these criteria. 

California  Air  Resources  Board  (CARB)  released  in  2007  a  regulation  on  formaldehyde 
emissions  from  wood-based  panels  and  from  composite  wood  products,  the  Airborne 
Toxic Control Measure (ATCM) 9312090 for: 

•  Hardwood Plywood (Veneer or Composite core) (HWPW) 
•  Particleboard (PB) 
•  Medium Density Fiberboard (MDF) 

89 http://www.cpsc.gov/en/Regulations-Laws--Standards/Regulations-Mandatory-Standards-Bans/ 
90 http://www.arb.ca.gov/toxics/compwood/compwood.htm 

127 

 
 
 
 
                                           
 
 
Both  composite  wood  panels  and  down-stream  products  containing  such  panels  are 
involved, such as wooden flooring, furniture and more. Most of HWPW, PB and MDF is 
used  to  make  furniture,  cabinets,  shelving,  countertops,  flooring  and  moldings  in 
homes. Certification covers the manufacturing process and the products. 

The  ATCM  applies  to  panel  producers,  third  party  certifiers,  distributors,  importers, 
fabricators,  and  retailers  of  HWPW,  PB,  MDF,  and  finished  goods  containing  those 
products, sold or delivered to California. 

Japan 

In  Japan  the  following  “Basic  Technical  Criteria  for  Countermeasures  Regarding  Sick 
House  Issues”  are  listed  in  the  Building  Standard  Law  Enforcement  Order  and 
Notifications91. 

1. Chemical substances subjected to regulations 

The chemical substances stipulated in the Order are chlorpyrifos and formaldehyde. 

2. Regulations on building materials in relation to chlorpyrifos 

The use of building materials containing chlorpyrifos in buildings is prohibited. 

*  Building  materials  containing  chlorpyrifos  is  exempted  if  they  have  been  used  as 
building parts for five years or more. 

3.  Regulations  concerning  building  materials  and  ventilation  equipment  in  relation  to 
formaldehyde 

3.1 Restrictions on interior finishing materials 

(1) Categories of building materials 

Building  materials  which  are  now  subject  to  formaldehyde-emission  controls  are 
classified under 4 categories according to their formaldehyde emission rates (Table 23). 

91 http://www.mlit.go.jp/english/housing_bureau/law/ 

128 

 
 
 
 
 
 
 
 
                                           
 
Table 23: Japanese restrictions for interior finishing materials 

*1 Measurement conditions 
Temperature: 28ºC, relative humidity: 50%, formaldehyde density: 0.1 mg/m3 
(= guideline value announced by Ministry of Health, Labour and Welfare) 
*2  There  are  no  restrictions  on  materials  which  have  been  used  as  parts  of  buildings  for  five 
years or more. 

Building  materials  which  are  now  subject  to  formaldehyde-emission  controls  are  listed 
exclusively  in  Notification  No.  1113-1115.  Materials  not  listed  are  not  subject  to  such 
controls.  Even  building  materials  listed  in  the  Notification  are  exempted  from  controls 
when they are F ****  of JIS  or JAS  or  equivalent to them. A list of building materials 
with formaldehyde emission control is presented in Table 24. 

129 

 
 
 
 
Table 24: Categories of formaldehyde emitting building materials 

130 

 
 
 
131 

 
 
132 

 
 
 
 
 
 
(2) Prohibition on use of type 1 formaldehyde-emitting building materials 

The  use  of  type  1  formaldehyde-emitting  building  materials  as  interior  finishing 
materials in habitable rooms is prohibited. 

* Habitable rooms also  include other areas of  buildings, such as corridors, which have 
permanent  openings  (such  as  door  undercuts)  and  which  are  ventilated  together  with 
the habitable rooms according to ventilation planning. (The same applies below.) 

*  Interior  finishing  materials  are  materials  applied  to  the  surfaces  of  walls,  floors  and 
ceilings (excluding picture rails, windowsills and similar parts). Pillars and other framing 
lumber,  baseboards,  handrails,  head  jambs,  lintel  joist,  and  other  finishing  trim, 
window/door trim and paints adhesives, etc. used in small quantities are excluded. (The 
same applies below.) 

(3) Restrictions on use of type 2 and type 3 formaldehyde-emitting building materials 

The  use  of  type  2  and  type  3  formaldehyde-emitting  building  materials  as  interior 
finishing materials in habitable rooms is limited to a certain area size. 

(4) Exemptions 

The  following  types  of  habitable  rooms  are  covered  by  other  criteria,  etc.,  and  are 
therefore  exempted  from  the  restrictions  concerning  interior  finishing  materials 
specified herein. 

•  Habitable  rooms  equipped  with  centrally  controlled  air  conditioning  equipment 
which  complies  with  specific  criteria  (Article  20-6,  paragraph  1  item  (1)  (c)  of 
the Order) 

•  Habitable rooms approved by the Minister of Land, Infrastructure and Transport 
as rooms in which it is possible to maintain the concentration of formaldehyde at 
no  more  than  0.1  mg/m3  throughout  the  year  in  areas  where  people  can  be 
expected to engage in normal activities.  

In  Japan  there  is  also  the  ”Chemical  Substances  Control  Law”  (2011)  issued  by  the 
Ministry of  Economy,  Trade and  Industry; Ministry  of  Health, Labour and Welfare, and 
Ministry of the Environment 92,93. 

Manufacturers and importers (M/I’s) of a chemical substance in Japan have obligations 
depending  on  the  status  of  the  substance.  Basically,  there  are  two  types  of 
requirements.  One  is  a  notification  of  a  new  substance,  as  with  registration  under 
REACH, and another is annual reporting for general substances  or Priority Assessment 
Chemicals (PAC’s): 

•  notification for new substances is required before manufacture or import (M/I) of 

the substance; 

•  annual  reporting  for  general  substances,  PACs  (priority  assessment  chemicals) 
and  monitoring  chemicals  is  required  after  manufacturing  or  importing  of  the 
substance; 
restrictions  for  certain  type  of  substance  (Class  1/Class  2  specified  chemicals 
substances); and 

• 

92 http://www.meti.go.jp/policy/chemical_management/english/cscl/about.html 

93 http://www.safe.nite.go.jp/jcheck/top.action 

133 

 
 
 
                                           
 
• 

the  government  assesses  the  risk  of  selected  substances  based  on  the  hazards 
and volume of M/I. 

Korea  

In  Korea  the  Act  regarding  the  Registration  and  Evaluation  of  Chemicals  (AREC,  also 
known as K-REACH) was adopted by the National Assembly of South Korea on 30 April 
2013  and  came  into  force  on  1  January  2015.  From  1  January  2015  on,  the  current 
Toxic Chemical Control Act (TCCA) is divided into Korea REACH and Chemicals Control 
Act  (CCA).  K-REACH  focuses  on  registration  and  evaluation  of  substance  while  CCA 
focuses on the control of hazardous substance and response to  chemical accidents. K-
REACH requires manufacturers and importers to register new chemical substances prior 
to  manufacture  or  import)  and  designated  existing  substances,  imported  or  sold  more 
than  1  ton  per  year.  Polymers  are  not  exempt.  Registrants  have  to  share  information 
on  chemical  substances.  A  stepwise  registration  approach  is  used,  based  on  tonnage 
bands.  Non-Korean  manufacturers  can  appoint  an  Only  Representative  (OR)  to 
complete  registration.  Summary:  Legislation  on  CMR  substances  in  construction 
articles. 

In  Korea  and  China  REACH-like  regulations  are  in  force  via  K-REACH  and  China-
REACH 94,95,96.  These  regulations  have  some  similarities  but  also  may  differences 
compared  to  European  REACH  such  as  timing  for  notifications  and  registrations, 
thresholds, exemptions available or not, data requirements (local ecotox, acceptance of 
QSAR,  defining  product  composition/  impurities,  etc.),  communication  in  the  supply 
chain etc. 
Some of the key differences are shown in Table 2597. 

94 http://www.cirs-
reach.com/KoreaTCCA/Korea_REACH_The_Act_on_the_Registration_and_Evaluation_of_Chemicals.html 
95 http://www.law.go.kr/main.html 
96 http://www.cefic.org/Documents/IndustrySupport/REACH-Implementation/Workshops/RIEF-II-18-
December-2013/Chemical%20legislation%20around%20the%20world%20(A.Jalba%20-%20Cefic).pdf 
97 file:///D:/K-REACH-questions.pdf 

134 

 
 
 
                                           
 
Table 25: Key differences between EU-REACH, K-REACH and China REACH 

3.2.4 SUMMARY: LEGISLATION ON CMR SUBSTANCES IN CONSTRUCTION ARTICLES 

Within the EU, the REACH regulation is the most relevant law concerning CMR (1A/1B) 
in construction articles. Some specific CMR substances uses are addressed by bans and 
restrictions  (cfr.  Restrictions  and  Authorization  list),  but  the  use  of  CMR  1A/1B  in 
construction articles is not generally prohibited. Substances listed in Annex XIV – some 
of  these  substances  are  CMR  1A/1B  -  are  prohibited  to  be  used  in  the  EEA  after  the 
respective sunset date. However, articles produced outside the EEA and imported to the 
EEA are not automatically affected by authorization procedure, and hence may contain 
Annex XIV substances (>0.1%).  

In  addition,  producers  and  importers  of  substances  on  the  Candidate  list  (SVHC 
substances; among which several are CMR 1A/1B) have the duty to notify this to ECHA 
for substances prevailing in concentrations above 0.1%, and any supplier of an article 
containing such substances has to communicate this to the recipient. 

Bans and restrictions of CMR substances under REACH, and duty to notify use of SVHC 
in construction articles to ECHA are based on “presence or content” criteria, and not 
on release criteria.   

The  majority  of  EU  Member  States  rely  evidently  heavily  on  EU  legislation  concerning 
CMR  substances  in  construction  articles  (via  REACH  and  the  CPR),  and  have  no  or 
limited additional national legislation concerning CMR substances in articles. 

135 

 
 
 
 
 
 
 
 
 
In addition to EU legislation, some countries (Belgium, Germany, Poland, Lithuania, and 
France)  have  additional  national  legislation  concerning  construction  articles,  including 
the  aspect  of  CMR  1A1/B.  Some  national  legislations  apply  for  specific  groups  of 
construction articles (e.g. Belgium: flooring materials; Germany: flooring materials and 
decorative  wall  paper),  while  other  national  legislations  apply  for  a  broad  group  of 
construction  articles  (e.g.  Lithuania:  “All  polymer  construction  products  and  polymer 
furniture  for  installation  indoors;  Poland:  ‘Construction  materials,  facilities  and 
components of furniture used in rooms intended for human residence).  

In  contrast  to  above  EU  legislation,  these  national  legislations  are  in  general 
release-oriented.  For  example,  the  German,  Belgian  and  Lithuanian legislation limits 
the release of CMR 1A/1B substances to maximum model room levels of 1 µg/m³ after 
28 days emission testing.  

In  addition,  some  countries  have  specific  legislation  for  specific  CMR  compounds  in 
specific  applications.  For  example,  Denmark  restricts  the  use  of  Cd  in  construction 
articles  (max.  0.0075  %  Cd)  and  the  use  of  formaldehyde  in  wood  based  panels; 
interestingly,  Denmark  gives  priority  to  release  criteria  for  formaldehyde  from  wood 
based panels (max. 0.15 mg/m³ in a test room); however, if an enterprise is unable to 
document  fulfilment  of  this  requirement,  they  are  permitted  to  use  panels  with  a 
maximum  free  formaldehyde  level  of  25  milligrams  per  100  grams  dry  matter  in  the 
panel (content criteria).  

In  France  it  is  forbidden  to  use  some  CMR  substances  in  the  manufacturing  of 
construction  and  decoration  products,  namely  for  the  following  CMR  substances: 
trichlorethylene, benzene, DEHP and dibutylphthalate.  

Outside  the  EU,  regulations  for  construction  articles  are  mostly  focussed  on 
formaldehyde such as the Californian Airborne Toxic Control Measure ATCM 93120 and the 
Japanese Building Standard Law Enforcement Order and Notifications. 

136 

 
 
 
 
 
CHAPTER 4 

IDENTIFICATION  OF  CASES  FOR  WHICH  CONSUMER 
EXPOSURE TO SELECTED CMR SUBSTANCES IS POSSIBLE  

 4.1 OBJECTIVES AND APPROACH  

The main objective of task 3 was to assess for the CMR substances identified under 
task 2 whether their  presence in construction  articles can effectively provoke 
exposure  to  these  substances  upon  use  of  these  construction  materials,  and  hereby 
covering various use scenario’s for the consumer and the professional.  

The second objective of task 3 was to provide information on methods for assessing 
exposure  to  CMR  1A/1B  substances  in  construction  articles  (and  other  articles,  e.g. 
textile),  and  hereby  to  give  an  overview  on  which  information  is  readily  available  to 
assess  the  exposure,  and  which  information  is  currently  lacking  and  needs  be 
investigated (case by case) to quantify the exposure to CMR substances in construction 
articles.  

In  section  4.2,  considerations  of  relevant  exposure  scenarios  are  described,  in 
relation  to  the  selection  of  the  appropriate  methods  to  assess  the  exposure.  Exposure 
scenarios for three groups of construction articles were addressed, namely 1) resilient 
flooring coverings (PVC flooring, vinyl flooring, laminate flooring), 2) wall coverings 
(wall  papers  and  synthetic  wall  panels),  and  3)  surface  for  playgrounds  and  sport 
arenas; the first two categories have been selected because of the high loading factors 
(surfaces  to  volume),  and  thus  likely  high  exposures  to  the  indoor  air.  The  third 
category  was  included  in  order  to  cover  also  dermal  exposure  scenarios,  including 
scenarios with vulnerable populations (children);   

In  section  4.3.  existing    methods  for  assessing  exposure  to  substances  in 
construction articles are described, and focused on the group of CMR  1A/1B substances 
and  the  groups  of  resilient  flooring  coverings,  wall  coverings,  and  surfaces  for 
playgrounds and sport arenas;  

In  section  4.4  examples  of  literature  data  demonstrating  exposure  to  CMR 
1A/1B  substances  released  from  construction  articles  are  given.  The  examples 
are  focused  on  the  groups  of  resilient  flooring  coverings,  wall  coverings,  and  surfaces 
for  playgrounds  and  sport  arenas.  Exposures  are  demonstrated  via  exposure  scenario 
studies on emissions from construction products, monitoring information demonstrating 
release  from  the  articles  of  substances  and  via  residential  monitoring/emission  data. 
Also, some of the assessment methods from section 4.3 are demonstrated in practice in 
some of these literature data. 

In  section  4.5.  the  results  of  task  3  are  discussed  on  connection  with  the  outcome  of 
task 2 in chapter 3. Herein, it is described for which substances present in construction 
articles  exposure  is  likely,  and  for  which  cases  information  is  currently  lacking,  or  for 
which  cases  it  is  unlikely  that  content  of  CMR  substances  in  construction  articles 
provokes  exposure  of  consumers.  Hereto,  each  substance  from  task  2  was  evaluated 
for  5  criteria,  reflecting  the  likelihood  of  exposure  from  construction  articles.  The  5 
criteria  are:  criterion  1:  presence  of  CMR  1A/1B  in  construction  articles;  criterion  2: 
emission of CMR 1A/1B from construction articles (from monitoring programs); criterion 
3:  estimated  exposure  (modelling),  taking  into  account  release,  article  loading, 
exchange  rate  in  indoor  environments;  criterion  4:  measured  indoor  exposure 
(monitoring  Indoor  Air  Quality  (IAQ)  in  buildings);  criterion  5:  source  apportioning 
support that construction articles are the main source of indoor exposure. Moving from 
criterion 1 to 5 gives increasing evidence for exposure to CMR 1A/1B substances from 
construction articles. 

137 

 
 4.2 EXPOSURE SCENARIOS 

In  order  to  select  the  appropriate  exposure  assessment  method(s)  for  describing 
exposure  during  all  relevant  exposure  scenarios,  in  a  preliminary  step  the  following  2 
aspects should be considered (ECHA, 2015):  

1)  Release  mechanism  related  to  substance  properties,  article  matrix/design  and 

use conditions 

2)  Behavioural  aspects  of  the  exposed  population  related  to  the  article  type(s) 

covered by the assessment. 

The  first  element  is  crucial  to  define  the  expected  release  pathways  of  the  substance 
from the article.  

Taking  the  example  of  a  SVOC  (e.g.  DEHP)  in  wall  paper,  the  properties  of  the 
substance  (i.e.  a  relatively  low  but  not  negligible  volatility)  and  its  technical  function 
(plasticizer  –  DEHP  is  loosely  bound  to  the  matrix  of  the  construction  article)  support 
the  likelihood  of  releases  to  air  during  the  service  life.  The  large  surface  areas  of  the 
installed wall paper onsite could enhance releases to the indoor air to a certain extent. 
Therefore,  the  migration  into  air  and  subsequent  inhalation  exposure  should  be 
considered  by  the  assessment.  Another  potential  mechanism  of  exposure  to  the 
substance from articles is through its adsorption onto house dust (Wensing et al.2005); 
the re-deposited dust can then be ingested through hand to mouth contact, which is a 
significant exposure scenario for small children.  

The second element relates to the foreseeable behaviour of consumers in relation to the 
article  type  covered  by  the  assessment.  It  includes  the  potential  route  of  exposure, 
target population and duration/frequency of the exposure. The article type covered by 
the above example triggers the following considerations: 

•  Direct oral exposure can be excluded  
•  Dermal  exposure,  while  still  possible,  is  expected  to  be  not  significant  during 
article  service  lifetime.  It  is  not  very  likely  that  people  touch  wall  paper  with 
bare skin for a significant period when being in a room covered with wall paper. 
However, this cannot be excluded during installation phase (DIY scenarios where 
intensive hand contact with wall paper occurs).  

A different situation can be expected when the substance was used for PVC flooring. For 
this type of article, exposure might occur when walking barefoot on the floor; also due 
to  the  crawling  behaviour  of  an  infant,  dermal  exposure  is  relevant;  in  such  a  case, 
dermal  exposure  is  relevant  as  well  during  article  service  life  (beyond  DIY  installation 
phase). 

In  conclusion,  based  on  this  preliminary  step  combining  potential  release  and 
behavioural  aspects  in  relation  to  the  article  type,  the  relevant  exposure  scenarios 
should be selected. This should than further trigger the appropriate tools for estimating 
exposure.  

 4.3 METHODS 

FOR  ASSESSING 

EXPOSURE 

TO 

SUBSTANCES 

IN 

CONSTRUCTION ARTICLES  

Documents from  scientific sources and (inter)national authorities covering exposure to 
(CMR) substances in articles have been screened.  While screening these documents, it 
was  investigated  which  exposure  scenarios  they  covered,  which  exposure  pathways 
were taken into account, which type of parameters are needed to assess the exposure, 
and  how  values  for  these  parameters  were  quantified.    In  addition,  it  has  been 
investigated  to  what  extent  the  exposure  scenarios  are  embedded  in  procedures 
covered by the Construction Product Regulation.  

138 

 
 
It is important to note that none of the methods was specifically tailored towards CMR 
substances;  instead,  methods  for  chemicals  in  general  (irrespective  of  their  hazards) 
have been found.  

Table 26 gives an  overview of generic methods for assessing exposure to  substances 
in  (construction)  articles;  together  with  the  exposure  scenarios  covered  by  these 
methods. The methods  are generic in a way that they  cover not  only the construction 
article  selected  in  this  study  (floor  coverings,  wall  covering  and  surfaces  for  sport 
areas).  Some  methods  (e.g.  ECETOC  TRA)  cover  a  broad  range  of  other  consumer 
articles,  not  falling  under  the  umbrella  of  construction  articles.  Therefore,  exposure 
scenarios  underpinning  these  models  are  not  specifically  elaborated  or  parameterized 
for  floor  coverings,  wall  covering  and  surfaces  for  sport  areas.    The  relation  with  the 
exposure scenarios covered is discussed further below in the text.  

Table  26:  Overview  of  existing  methods  for  assessing  exposure  to  substances  present 
in (construction) articles  

Method 

Consumer -
dermal 

Consumer – 
inhalation 

Professional 
- dermal 

Professional 
– inhalation 

ECETOC TRA model: content 
based method (Tier 1)  

Delmaar et al. (2013): 
diffusion based model for 
dermal exposure  

RIVM emission tool 
(model)   diffusion based 
inhalation model  

CEN/TS 16516: 
experimental (emission 
testing) based method  

covered 

covered 

Not covered  Not covered 

covered 

Not covered  Not covered  Not covered 

Not covered 

covered 

Not covered  Not covered 

Not covered 

Covered 

Not covered  Not covered 

E04 

DIN EN ISO 105
(2013): experimental 
(artificial sweat based) 
method  

‐

covered 

Not covered  Not covered  Not covered 

Further,  the  various  methods  available  to  assess  exposure  to  substances  in  articles 
(Table 26) cover a wide stretch in conservatism.  

The  so  called  ‘Tier  1’  models  (e.g.  ECETOC  TRA)  should  be  regarded  as  a  screening 
tool,  as  they  are  designed  to  be  conservative,  and  may  (strongly)  overestimate  true 
exposure.  

If  an  assessment  based  on  Tier  1  models  demonstrates  that  exposure  is  below  the 
thresholds  established  from  toxicological  studies  (DNEL  or  DMEL),  then  it  can  be 
concluded that there is “no concern” and the risks from the substance in the article are 
deemed to be controlled. Otherwise, the estimate has to be refined using Tier 2 models 
or  Tier  3  methods  (using  measured  migration/release  data)  until  the  risk 
characterization indicates that the risks identified are adequately controlled. 

It  is  noted  that  the  ECHA  guidance  ‘Exposure  Scenario  for  CSR:  an  example  of 
consumer  exposure  to  Substances  in  Articles  (ECHA,  2015)  follows  such  a  tiered 
approach,  starting  from  ECETOC  TRA,  towards  tier  2  tools,  and  finally  experimentally 
based approaches. 

139 

 
 
In  the  paragraph  below,  these  methods  to  assess  consumer  exposure  to  substance  in 
articles  are  described,  and  consideration  of  relevant  exposure  scenarios  for  flooring 
materials, wall covering and sport areas are discussed.   

4.3.1 ECETOC TRA METHOD 

4.3.1.1  ECETOC TRA MODEL: EXPOSURE SCENARIOS  

The ECETOC TRA method is considered as a Tier 1 screening method.  

The model provides equations for quantifying the consumer exposure via inhalation and 
dermal routes of exposure.  

The model does not explicitly mention which exposure scenarios underpin the model; in 
addition,  no  separate  calculations  or  parameters  are  foreseen  to  differentiate  between 
distinct  exposure  scenarios  (e.g.  no  separate  exposure  scenarios  for  ‘walking  barefoot 
on  PVC  flooring  or  ‘babies  crawling  on  PVC  flooring).  Neither  does  the  model 
differentiate between article service lifetime exposure versus do-it-yourself exposure. 

We  derived  from  the  equations  and  the  description  in  the  ECETOC  guide  (Technical 
Report  107)  that  the  model  is  more  tailored  towards  article  service  lifetime  exposure 
and less to do-it-yourself exposure.  

For  example,  the  frequency  of  consumer  exposure  to  walls  (AC  11)  is  set  on  1 
event/day,  lasting  for  8  hours/day  (for  addressing  inhalation  exposure).    For  dermal 
exposure  to  substances  in  wall  paper  (TRA  Article  category  (AC)  11:  walls),  the 
frequency  is  set  at  1  event/day  and  the  exposure  surfaces  is  set  on  428  cm²  (hand 
palm);  which  probably  represents  a  hand  contact  with  a  wall  paper  during  article 
service  life  and  not  during  installation  (the  contacted  wall  paper  during  installation  is 
higher than the surface of a hand). 

Thus,  the  exposure  scenarios  covered  under  the  ECETOC  TRA  model  are  indirectly 
included  in  the  model  embedded  parameter  values  of  the  ECETOC  TRA  model.  For 
example,  if  for  an  article  category  (walls)  the  values  of  surface  area  (S)  is  set  to  428 
cm², the underlying exposure scenario is hand contact for adults.  

The ECETOC TRA model for articles is focused on consumers, and not on professionals.  

ECETOC  TRA  does  include  a  worker  module;  however,  within  the  worker  module, 
activities  such  as  professional  installation  of  construction  articles  are  not  covered,  nor 
could they be extrapolated from other workers exposure scenarios covered in ECETOC.  

4.3.2 ECETOC TRA DERMAL EXPOSURE MODEL (CONSUMERS) 

The  algorithm  used  for  calculating  dermal  exposure  estimates  in  ECETOC  TRA  (v3)  is 
presented in Table 27.  

140 

 
 
 
 
Table  27:  Algorithm  for  dermal  consumer  exposure  to  products  and  articles  (ECETOC 
TRA v3) 

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(PI    x  CA    x  FQ       x 

TL     x  D    x 

TF    x  1000)  /  BW  = 

The  mechanism  behind  the  ECETOC  TRAv3  dermal  exposure  module  is  not  explicitly 
mentioned  in  the  ECETOC  TRA  v3  user  guide,  though  it  can  be  derived  from  the 
equations  underpinning  the  ECETOC  TRA  dermal  consumer  module  that  the  (only) 
assumed mass transport process is instantaneous emission of substances from products 
or articles into the skin contamination layer.  

A  ‘given  amount  of  substances’  is  assumed  to  be  transferable  from  the  article  or 
product to the skin (= exposure mass), which is approximated in ECETOC TRAv3 as the 
amount of the substance present in the upper layer of the article or product in contact 
with  the  skin.  The  volume  of  this  upper  layer  is  in  ECETOC  TRAv3  addressed  as  the 
multiplication of two factors: 1) Thickness of layer, 2) Skin contact area and the weight 
of this upper layer is calculated by taking account of the third factor: Density. Basically, 
it  assumes  a  given  amount  of  substances  present  in  the  product/article  is  transferred 
immediately  to  the  skin  upon  contact,  so  that  duration  of  release  from  article  and 
transfer to the skin exposure does not play a role.  

Moreover, the model does not take into account the influence of other physico-chemical 
properties  (besides  density)  of  substances  and  articles  on  release  and  subsequent 
dermal exposure.  

The  Thickness  of  layer  is  a  parameter  that  is  used  as  a  surrogate  for  the  fact  that  a 
substance in a matrix should be migrated towards the surface of the matrix before it is 
available for transfer to the skin. The combination of the parameters Thickness of layer 
and  Transfer  factor  can  thus  be  considered  to  represent  respectively  the  release  and 
transfer processes in and from the article matrix. 

In  addition,  the  Transfer  factor  is  expressed  as  a  unitless  parameter  in  the  ECETOC 
TRAv3  model,  and,  in  line  with  the  ECETOC  TRAv3  equations,  assumes  an 
instantaneous  transfer  of  the  transferable  fraction  to  the  skin  surface.  This  is  a  worst 
case  assumption,  as  release  and  transfer  from  articles  to  skin  depend  in  general  on 
duration of the contact between article/product and the skin.  

4.3.2.1  PARAMETERIZATION  OF  ECETOC  TRA  DERMAL  EXPOSURE  MODEL  FOR  PVC  FLOORING,  WALL 

PAPER AND SPORT AREAS  

ECETOC TRA uses a number of pre-defined product/article categories and subcategories 
for  which  defaults  for  all  parameters  are  provided.  Some  of  these  defaults  can  be 
changed,  others  are  fixed  values.  When  using  the  pre-defined  categories  and 
subcategories,  only  the  parameters  Product  Ingredient  and  skin  Contact  area  can  be 
changed.  However,  the  user  can  also  define  new  subcategories,  for  which  also  the 
Transfer factor and the Frequency of use should be provided, and thus the values can 
deviate from the defaults. The parameter Thickness of layer is always provided by the 
tool and the values vary from 0.01 to 0.001cm (usually 0.001cm in case of articles).  

141 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The predefined ECETOC TRA values for PVC flooring and wall paper are listed in Table 
28 (surfaces for playgrounds and sport arenas are not covered by ECETOC TRA). 

Table  28:  ECETOC  TRA  values  for  the  consumer  dermal  exposure  model  for  PVC 
flooring and wall paper 

r
e
t
e
m
a
r
a
P

Walls 
11: 
(AC 
wood  articles*  – 
also  applicable  for 
non-wood 
materials) 

PVC  flooring  (AC 
13 plastic articles)  

i

t
n
e
d
e
r
g
n

i

t
c
u
d
o
r
P

)
g
/
g
(

a
e
r
A

t
c
a
t
n
o
C

)
²
m
c
(

f
o

y
c
n
e
u
q
e
r
F

e
s
u

)
y
a
d
/
s
t
n
e
v
e
(

f
o

s
s
e
n
k
c
i
h
T

)
²
m
c
(

r
e
y
a

l

y
t
i
s
n
e
D

)
²
m
c
/
g
(

r
e
f
s
n
a
r
T

r
o
t
c
a
f

)

-

(

i

t
h
g
e
w
y
d
o
B

)
)
g
k
(

0.5 

428 cm² 

1 

0.001 cm  1 

1 

60 

(inside 
hands) 

0.43 

8750 cm² 

1 

0.001 cm  1 

1 

60 

(upper  part 
of body) 

*AC 11 wood articles is the relevant category for wall paper. This category includes subcategory 
‘walls and flooring (also applicable for non-wood material’ 
*  AC13  plastic  articles  is  the  relevant  category  for  PVC  flooring.  AC  13  includes  a  subcategory 
‘plastic, large articles (plastic chair, PVC flooring, lawn mower, PC) 

In  summary,  for  PVC  flooring,  ECETOC  TRA  approximates  the  consumer  dermal 
exposure  to  substance  as  in  the  PVC  floor  as  the  full  content  of  this  substance  in  the 
PVC flooring volume in the upper 0.001 cm layer of a PVC flooring piece having the size 
of 8750 cm² (= concentration x 0.001 cm x 8750 cm³).   

Therefore,  it  is  a  content-based  method  for  addressing  exposure  and  ignores  factors 
affecting release (e.g. solubility, strength of bounding between substance and matrix).   

4.3.2.2  ECETOC TRA INHALATION EXPOSURE MODEL (CONSUMERS) 

The  algorithm  used  for  calculating  consumer  inhalation  exposure  in  ECETOC  TRA  is 
shown in Table 29.  

142 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table  29:  Algorithm  for  dermal  consumer  exposure  to  products  and  articles  (ECETOC 
TRA v3) 

n
o
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p
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n
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A

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e
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f
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F

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l

)
g
/
g
1
r
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a

n
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m
T

i

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p
x
E

)
h
(

e
t
a
R
n
o
i
t
a
a
h
n
I

l

)

-

(

h
/
³
m

(

l

e
m
u
o
V
m
o
o
R

i

t
n
e
d
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r
g
n

i

t
c
u
d
o
r
P

)
g
/
g
(

)
³
m

(

F
C

i

t
h
g
e
w
y
d
o
B

)
)
g
k
(

)
d
/
g
k
/
g
m

(

e
r
u
s
o
p
x
E

r
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t
e
m
a
r
a
P

Algorithm  (PI    x 

A    x 

FQ     x  F     x  ET  x 

IR   x  V    x  1000) /  BW  = 

The fraction released to air (F) is based on the vapour pressure of the substance. Four 
bands  (A  to  D)  of  vapour  pressure  values  are  considered.  Each  one  is  assigned  a 
different value of fraction released to air. The values and the corresponding substance’s 
vapour pressure are indicated in Table 30. 

Table  30:  Fraction  released  to  air  according  to  vapour  pressure  bands  in  ECETOC  TRA 
(source: ECETOC, 2009) 

Any  substance  with  a  vapour  pressure  higher  than  10  Pa  is  assigned  a  transfer  to  air 
factor  of  1,  the  substances  is  considered  to  be  completely  released  into  air  instantly. 
This is of course a very conservative estimate. 

The ECETOC TRA parameter values for PVC flooring, wall paper are mentioned in Table 
31. 

143 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table  31:  ECETOC  TRA  values  for  the  consumer  inhalation  exposure  model  for  PVC 
flooring and wall paper 

i

t
n
e
d
e
r
g
n

i

t
c
u
d
o
r
P

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(

d
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p

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m
A

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a

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F

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l

)
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1

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F

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E

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(

e
m
T

i

n
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i
t
a
a
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I

l

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t
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R

)

-

(

h
/
³
m

(

l

e
m
u
o
V
m
o
o
R

)
³
m

(

i

t
h
g
e
w
y
d
o
B

)
)
g
k
(

0.5 

3000 g 

1 

~ VP 

8 

1.37 

20 m³ 

60 kg 

0.43 

8000 g 

1 

~ VP 

8 

1.37 

20 m³ 

60 kg 

r
e
t
e
m
a
r
a
P

Walls  (AC 
11:  wood 
articles) 

PVC 
flooring 
(AC 
plastic 
articles)  

13 

In  summary,  the  ECETOC  TRA  approach  for  inhalation  exposure  uses  the  mass  of  the 
(construction  product)  as  an  indicator;  this  is  in  contrast  to  the  surface  loading 
approach from the CEN/TS 16516 standard (see further). 

It  is  noted  that  the  CEN/TS  16516  loading  factors  (1  m²/m³  for  walls  and  0.4  m²/m³ 
for  flooring)  have  an  opposite  trend  compared  to  ECETOC  TRA  (higher  factor  for 
flooring: 8 kg compared to walls: 3 kg for walls). 

4.3.3 DIFFUSION BASED CONSUMER EXPOSURE MODEL (RIVM, 2010 AND DELMAAR ET AL., 

2013) 

According to ECHA (2015), the most appropriate tool to refine the inhalation exposure 
from construction articles estimation is the RIVM emission tool 98
 . Specifically developed 
to  estimate  the  inhalation  exposure  for  the  release  of  chemicals  from  building 
materials,  the  model  takes  into  account  the  diffusion  of  a  substance  in  a  solid  matrix 
(or  material),  the  mass  transfer  from  the  material  into  air  and  the  removal  of  the 
substance from residential air by natural ventilation.  

4.3.3.1  DIFFUSION BASED CONSUMER EXPOSURE MODELS: EXPOSURE SCENARIOS 

Analogously to ECETOC TRA, the RIVM & Delmaar diffusion based models for inhalation 
and  dermal  exposure  do  not  explicitly  mention  which  consumer  exposure 
scenarios are covered. 

98 
http://www.rivm.nl/en/Documents_and_publications/Scientific/Models/Download_page_for_ConsExpo_softwa
re 

144 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                           
 
Based on the technical description of the tool and model, it was derived from the model 
parameterization described in the reports that the models are probably more tailored 
towards  article  service  lifetime  exposure  and  less  to  do-it-yourself  exposure. 
Article  service  lifetime  consumer  exposure  scenarios  covered  by  the  RIVM  models  are 
passive  inhalation  exposure  to  (S)VOCs  release  from  the  construction  material  to  the 
indoor  air  (release  driven  by  diffusion)  (RIVM  emission  tool),  and  dermal  exposure  to 
construction  material  upon  hand  contact  with  construction  article  (during  the  hand 
contact with the construction material, a diffusion process occurs, substances released 
from the construction material end up into the skin layer) (Delmaar et al.,2013). 

4.3.3.2  DIFFUSION BASED INHALATION EXPOSURE MODEL (RIVM, 2010) 

The RIVM emission tool simulates a time profile for the air concentration and mean air 
concentrations  in  a  selected  range  arising  from  emission.  The  model  assumes  a 
homogenous matrix from which the emission to air occurs.  

Figure  1:  Transport  processes  and  coefficients  of  the  RIVM  emission  model  for 
assessing inhalation exposure to substances released from construction articles 

Some  of  the  input  parameters  that  are  needed  to  run  the  exposure  assessment  using 
the  RIVM  tools  are  related  to  the  article  (thickness  of  panels,  surface  from  which 
exposure  could  occur,  concentration  of  substance  in  panels)    and  the  room 
characteristics (volume and ventilation).  

Crucial parameters to run the RIVM emission model include the diffusion coefficient D of 
substance A in the article (particleboard panel), the partition coefficient K of substance 
A between material (wood) and air, and the mass transfer rate hm (Figure 1). 

The  diffusion  coefficient  (D)  describes  the  diffusion  of  a  substance  within  a  material 
(e.g.  wood).  The  diffusion  is  assumed  to  be  homogeneous  and  independent  of  the 
concentration of the substance in the material and can thus be described by a constant. 
This constant is expressed in m2/s. 

145 

 
 
 
K,  the  partitioning  coefficient,  represents  the  tendency  of  the  substance  to  distribute 
between the material and air in the vicinity of the separation layer (boundary layer). It 
is dimensionless. It is the analogue of the partition coefficient used for environment to 
describe  the  tendency  of  a  substance  to  distribute  between  different  phases 
(water/solid, water/air, etc.). 

hm, the mass transfer coefficient, describes the transport velocity of the substance from 
the material surface to the bulk indoor air; it is in fact expressed as a velocity in m/s. 

The  mechanism  that  the  model  assumes  for  the  substance  removal  from  the  room  is 
the ventilation expressed in number of exchange per hour. 

In the description of the emission model (Delmaar, 2010), several data and estimation 
methods  for  D,  K  and  hm  are  discussed.  Bodalal  et  al.  (2000)  and  Cox  et  al.  (2001) 
(referenced  in  Delmaar,  2010)  suggest  an  empirical  method  to  estimate  the  diffusion 
coefficient. 

Figure 2 shows the profile of the indoor air concentration over the year, together with 
the  input  parameters  and  the  reference  air  concentration  calculated  after  one  month 
from the article’s (particleboard’s) production according to the RIVM emission tool.  

The resulting concentration at time x (e.g. 1 month) can then be used as estimate for 
the inhalation exposure during article service lifetime. 

Figure  2:  Input  parameter  and  air  concentration  during  exposure:  RIVM  emission  tool 
(source:  ECHA, 2015) 

146 

 
 
 
 
 
 
The selection of appropriate values for input parameters in the RIVM emission tool is up 
to  the  user  of  the  model.  The  model  does  not  include  defaults  for  input  parameters. 
Thus, no predefined model parameterization for PVC flooring and wall paper embedded 
in the RIVM emission tool can be given. 

4.3.3.3  DIFFUSION BASED DERMAL EXPOSURE MODEL (DELMAAR ET AL., 2013) 

Delmaar  et  al.  (2013)  also  applied  the  diffusion  based  exposure  concept  to  estimate 
dermal exposure to substances in articles. 

Whereas the inhalation model is available in software tool, the dermal exposure model 
of  Delmaar  is  published  in  a  scientific  paper  (Delmaar  et  al.,  2013);  no  practical 
exposure tool is available yet.  

The diffusion model based release is based on the idea that substances move from the 
article to the surface of the article; and that, once present at the surface of the article, 
this amount may be transferred to the skin.  

This  diffusion-based  approach  is  based  on  the  well-established  theory  of  diffusion  of 
substances in materials. Diffusion expresses the mobility of substances within articles. 
These  physics-based  emission  models  have  been  successfully  applied  in  the  field  of 
emissions from building materials to the indoor air (Huang and Haghighat, 2002; Xu et 
al.,  2009),  as  well  as  in  the  field  of  migration  of  substances  from  packaging  material 
into  food  stuff  (Brandsch,  2002;  Begley  et  al.,  2005).  Delmaar  et  al.  (2013)  recently 
promoted a simplified diffusion model, as an alternative approach for the ECETOC TRA 
dermal exposure equation.  
The mathematical equation of the diffusion model, based on the Fick’s 2nd law, can be 
expressed as (Delmaar et al., 2013; Piringer, 1994):  

surface    

[Equation 1] 

𝑑𝑑
𝑑𝑑 = 𝑆  × 𝐷𝑑𝑑𝑑𝑑   ×  

𝜕𝜕
𝜕𝑥�

Where:   A = amount of substance released per article (g)  

C = concentration of the substance in the article (g/m³) 

S = surface area of the article (m²) 
Ddiff = diffusion coefficient (m2/s) 
x = position in the material (m) 

t = time (s) 

To  apply  the  complete  diffusion  model  in  a  specific  situation,  appropriate  initial  and 
boundary  conditions  on  the  concentrations  of  the  substance  in  the  material,  C(x,t), 
must be specified.  

To  approximate  the  diffusion  in  a  material  a  simple  diffusion  layer  model  may  be 
applied  based  on  a  finite  difference  approach  instead  of  the  complete  diffusion  model. 
) over 
This simplified diffusion model considers an average distance ‘l’ (
which a diffusing molecule will travel during time t, and therefore the original diffusion 
model  can  be  simplified  to  the  following  analytical  expression  for  slab-like  articles 
(Delmaar et al, 2013; Piringer, 1994):  

=   �2  × 𝐷𝑑𝑑𝑑𝑑 × 𝑡

147 

 
 
 
 
 
A(t) = 

𝐶0  × 𝑆  ×   �2  × 𝐷𝑑𝑑𝑑𝑑 × 𝑡

Or per unit surface area of the article As (t): 

As(t) = 

𝐶0  ×   �2  × 𝐷𝑑𝑑𝑑𝑑 × 𝑡

[Equation 2] 

This  simplified  diffusion  model  assumes  that  all  substance  that  is  able  to  reach  the 
material surface within duration time t will be emitted and available for transfer to the 
skin  at  duration  t.  In  other  words,  this  simplified  model  assumes  diffusion  within  the 
matrix to be the limiting factor for the availability of substances for skin exposure. 

4.3.3.4  DIFFUSION BASED DERMAL CONSUMER EXPOSURE  MODEL:   MODEL PARAMETERIZATION  FOR PVC 

FLOORING AND WALLS (DELMAAR ET AL., 2013) 

Duration of exposure 

Parameterization  of  duration  of  exposure  for  floorings  as  used  by  Delmaar  is  0.5h  per 
day  (personal  estimate  by  Delmaar  et  al.,  2013).  This  reflects  implicitly  the  exposure 
scenario that duration between skin and flooring is 0.5 h/day. 

Diffusion coefficients 

Diffusion coefficients depend on physical-chemical properties of both the substance and 
the article matrix. Diffusion coefficients may be determined in laboratory experimental 
settings.  Two  types  of  experiments  are  commonly  used  to  determine  the  diffusion 
coefficient:  1)  based  on  sorption  and  desorption  curves  in  test  chambers  (air)  using  a 
forced air stream and measuring the concentration of the substance in the air (e.g. Cox 
et al., 2001); or 2) based on extractions in a liquid solvent (Piringer, 2008).  

Mechanistic  models  to  estimate  diffusion  coefficients  do  exist  (Piringer,  2008,  Mercea, 
2000),  and  can  be  used  instead  of  experimental  testing.  However,  these  are  complex 
models  and  their  utility  in  lower  tier  exposure  modelling  is  considered  to  be  limited 
(Delmaar  et  al.,  2013).  Empirical  models  to  estimate  diffusion  coefficients  have  been 
published  for  some  groups  of  compounds,  but  their  applicability  domain  is  limited  to 
these  groups.  For  example,  Cox  et  al.  (2001)  found  a  correlation  between  D  and 
Molecular Weight for four alkanes, which can be used to estimate diffusion coefficients 
for other alkane VOCs.  

Recently, Holmgren et al. (2012) published the following empirical model for prediction 
of  diffusion  coefficients,  based  on  the  Piringer  equation,  which  is  an  empirical  worst 
case  calculation  developed  for  predicting  diffusion  rates  of  additives  from  food 
packaging to food (Begley et al., 2005; Piringer and Baner, 2008): 

𝐷𝑑𝑑𝑑𝑑 = 𝑒𝑒𝑒 �𝐴𝑝 − 0.1351(𝑀𝑀)
Where 

2 3 ⁄

+ 0.003𝑀𝑀 −  

10450
𝑇 �

[Equation 3] 

Ddiff = diffusion coefficient 
Ap = material specific coefficient 

Mw = molecular weight 

T = Temperature (in Kelvin) 

148 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Article thickness  

The personal estimate by Delmaar et al. (2013) is 2 mm for plastic flooring and 25 mm 
for rubber flooring. The paper of Delmaar et al. (2013) does not describe a case for wall 
coverings.  

Contact area:  

Estimated values are taken by Delmaar et al. (2013) from ECETOC TRA defaults for contact 
area S: 428 cm² (wood flooring) - 8750 cm² (plastic flooring) 

Model predictions by Delmaar et al. (2013) 

Delmaar  et  al.  (2013)  predicted  dermal  exposure  to  about  50  S(V)OC  substances  (no 
CMR substances), using the above mentioned parameters for article thickness, contact 
area, diffusion coefficients, and assuming an initial concentration of 0.1 – 0.5 g/g of the 
article (ECETOC TRA defaults used). 

Based on this, dermal exposure according to the diffusion based model amounted up to 
100 – 1000 g/event per person for flooring (not specified for which substance). 

These  values  have  not  been  verified  against  experimentally  measured  skin  loadings, 
and based on the level of these predictions, it is anticipated that these predictions are 
very  high  compared  to  reality  (a  physical  loading  of  skin  100  -1000  gram  is  rather 
unlikely);  moreover,  other  transfer  limiting  factors  have  been  ignored  in  the  diffusion 
based model of Delmaar et al. (2013); hence it can be assumed that model predictions 
overestimate reality. 

4.3.4 EXPERIMENTAL  METHODS  FOR  ASSESSING  RELEASE  TO  INDOOR  AIR:  CEN/TS  16516 

EMISSION TESTING 

Notwithstanding    that  model  based  estimates  (Tier  1  and  Tier  2)  are  adequate  and 
efficient  tools  to  demonstrate  that  risks  are  under  control  for  (non  CMR)  substances 
with rather high DNEL values, they will probably fail to demonstrate safe us for several 
CMR  substances,  having  very  often    low  consumer  DNEL  or  DMEL  values  compared  to 
non CMR substances. 

In  such  cases,  it  is  important  to  have  as  realistic  as  possible  estimates  for  exposure. 
Herein, experimental testing serve as a basis for a sound exposure estimates.  

In  this  paragraph,  the  experimental  method  to  assess  consumers  exposure  to 
substances released from construction articles to the indoor air is described.  

The CEN/TS 16516 emission testing is the gold standard for testing emission of (S)VOC 
substances from construction materials. The testing method also includes measurement 
of  57  regulated  VOCs  with  CMR  properties  and  12  SVOCs  with  CMR  properties  (see 
Table 21 and Table 22). 

The CEN/TS 16516 is implemented in the Construction Product Regulation, and is used 
as a basis of CE marking of construction articles.  

The technical specification CEN/TS 16516 specifies the horizontal reference method for 
testing  the  emissions  of  dangerous  substances  from  construction  products  into  indoor 
air (Table 32). 

The CEN/TS 16516 test method is based on the ISO 16000 series and the German DIBt 
method,  but  with  more  precise  specifications  of  some  details  for  better  harmonization 
between testing labs. 

149 

 
 
Table 32: Key technical aspects of CEN/TS 16516 (2013)  

Technical aspect 

Legal status 
Based on 
Product types covered 
Sampling and test 
specimen preparation 
Test chamber size 
Test chamber conditions 
- T 
- RH 
- air exchange 

Loading factor 
- Flooring 
- Walls 
- Small surfaces 
- Very small surfaces 
Sample size 
Substances tested 

CEN/TS 16516 (2013) 

TS (EN in 2016) 
ISO 16000 series 
All relevant to indoor air 
Based on ISO 16000-11 with additional specifications 

Min 20L 

23 ± 1 °C 
50 ± 5 % 
0,5 h-1 (range: unlimited if area specific air flow rate is 
kept constant) 
Range: 50% with max of 2 
0,4 m2/m3 
1,4 m2/m3 
0,05 m2/m3 
0,007 m2/m3 
According to loading factor 
VOCs, SVOCs and volatile aldehydes (including 57 CMR 
VOCs and 12 CMR SVOC substances) 

4.3.4.1  EXPOSURE SCENARIOS UNDER CEN/TS 16516 EMISSION TESTING 

The  exposure  scenario  covered  by  CEN/TS  16516  emission  testing  is  the  exposure  to 
is 
emissions 
approximated by a 28 days testing procedure.  

from  construction  materials  during  article  service 

lifetime.  This 

The  results  of  the  tests  performed  according  to  CEN/TS  16516  have  been  converted 
to  reference  room  concentrations  (Creference  room)  for  evaluating  for  TVOC  and  R  value 
criteria, following this equation:  

Where 

𝐶𝑟𝑟𝑑𝑟𝑟𝑟𝑟𝑟𝑟 𝑟𝑟𝑟𝑟,𝑑  =  

𝑆𝑆𝑆𝑡  × 𝐿
𝑛

Creference room, t= concentration in reference room at time t (expressed in µg/m³) 
SERt= Specific Emission Rate at time t (expressed in µg/m².h) 
L = Loading Factor (expressed in m²/m³) 

n = ventilation rate (expressed in 1/h) 

A value of 0.5 for ventilation rate (n) was applied (CEN/TS 16516). 

For  loading  factor  L,  four  normative  loading  factors  are  in  place  (CEN/TS  16516), 
namely 

•  1,0 m2/m3: walls 
•  0,4 m2/m3: floor, ceilings 
•  0,05 m2/m3: small surfaces e.g. door 
•  0,007 m2/m3:small surfaces e.g. sealants 

These loading factors and ventilation rates represent the exposure scenario of a ‘normal 
use and quantities’ of construction materials in daily life exposure situations.  

150 

 
 
 
 
 
4.3.5 DERMAL  EXPOSURE:  EXTRACTION  WITH  ARTIFICIAL  SWEAT  (DS/EN  ISO  105-E04;  DIN 

54020) 

Extraction  of  articles  with  artificial  sweat  is  a  widely  used  approach  to  assess  dermal 
exposure  to  substances  in  articles  (Meinke  et  al.,  2009;  Danish  EPA,  2007).  It  is  an 
operationally defined approach, mimicking the release of substances from articles when 
being in contact with a skin relevant medium (sweat) for a given duration. The amount 
of substance released from the article to (artificial) sweat is assumed to be the result of 
a  combined  effect  of  intrinsic  processes  of  the  material  (diffusion)  and  external 
processes  such  as  mass  transfer  from  one  medium  to  another  (transfer  of  substance 
from  article  into  the  artificial  sweat  extracting  medium),  and  hence  is  affected  by  the 
solubility of the substance in sweat. 

The  amount  of  substances  released  to  the  skin  at  a  given  time  t  [A(t)]  using  this 
approach can be expressed as:  

A(t) = 

As(t) = 

𝐶 (𝑡)𝑎𝑟𝑑𝑑𝑑𝑑𝑟𝑑𝑎𝑎 𝑠𝑠𝑟𝑎𝑑  × 𝑊 
𝑊 

As(t) = 

𝐶 (𝑡)𝑎𝑟𝑑𝑑𝑑𝑑𝑟𝑑𝑎𝑎 𝑠𝑠𝑟𝑎𝑑  ×

𝑆

Where  

𝑋 (𝑡)𝑎𝑟𝑑𝑑𝑑𝑑𝑟𝑑𝑎𝑎 𝑠𝑠𝑟𝑎𝑑  ×

𝑊 
𝑆   × 𝐶0

or 

or 

[Equation 4] 

C(t)artificial  sweat  =  artificial  sweat  extractable  concentration  of  substance  per  mass 
unit of article at time t (g/g);  

t = the extraction time (minutes or hours) 

W = weight of the article (g) 

S = surface area of the article (cm²) 

X  =  fraction  of  artificial  sweat  extractable  concentration  of  the  total  (initial) 
concentration of substance in the article (%).  

Standard  defined  compositions  of  artificial  sweat  are  commonly  used  (e.g.  DS/EN  ISO 
105-E04;  DIN  54020).The  sweat  simulant  in  DS/EN  ISO  105-E04  consists  of  1-
histidine-monohydrochlorid-1-hydrate,  sodium  chloride,  sodium  dihydrogen  phosphate 
and sodium hydroxide for adjustment of pH to pH 5.5. This composition may, however, 
be a too simplified simulation of sweat (Stefaniak & Harvey 2006).  

The  basic  assumption  underlying  this  artificial  sweat  extraction  approach  is  that 
artificial  sweat  is  an  adequate  medium  to  simulate  mass  transfer  from  material  to  the 
skin.  This  is  probably  a  correct  assumption  for  substances  with  a  relative  high  water 
solubility, which will have a high tendency to be transferred from article to the artificial 
sweat. However, for hydrophobic substances, their low water solubility will hamper the 
transfer to artificial sweat.  

However,  hydrophobic  substances  might  be  transferred  from  the  article  to  the  (outer) 
lipids  layer  of  the  skin  (a  thin  layer  of  lipids  covering  the  skin  (Nicolaides,  1974), 
irrespective  of  the  presence  of  sweat.  Therefore,  artificial  sweat  extractions  might 
underestimate  the  transfer  and  thus  dermal  exposure  for  hydrophobic  substances. 
However, no adequate extraction procedures mimicking this skin lipid layer exists.  

The  influence  of  hydrophobic  components  on  the  release  of  substances  from  articles 
was also supported by a case where extractable amounts of DEHP from plastic sandals 
in  artificial  sweat  were  shown  to  be  up  to  150  higher  for  sandals  in  combination  with 
sun  lotion  and  a  dynamic  (shaking)  extraction  procedure  compared  to  a  static 
extraction of sandals with artificial sweat in absence of sun lotion (Danish EPA, 2007).  

151 

 
 
   
 
   
 
    
 
 
 
 
 
 
However,  the  use  of  sun  lotion  cannot  be  generalized  as  a  good  proxy  for  skin  lipid 
layer  (the  example  of  plastic  sandals  is  given  because  it  might  be  considered  to  be 
comparable to PVC floorings).  

Overall, the artificial sweat extraction procedure is thus not considered an appropriate 
method  for  assessing  release  of  hydrophobic  substances  from  articles.  Therefore, 
suitable extraction procedures taking into account the effect of skin lipids layers need to 
be developed. Directions towards such an approach are for example the use of lanoline 
impregnated cotton (mimic oils in skin) (used in the RAR of DEHP (EC, 2008)). 

Thus, when performing artificial sweat based experiments to assess dermal exposure to 
CMR substances in construction articles, attention should be paid to the composition of 
the sweat matching the solubility of the substances of interest.  

4.3.5.1  EXPOSURE SCENARIOS EXTRACTION WITH ARTIFICIAL SWEAT 

The  artificial  sweat  extraction  procedures  DS/EN  ISO  105-E04  and  DIN  54020  are 
limited  to  stipulations  regarding  the  extraction  procedures;  however,  they  do  not 
prescribe values for duration of exposure and surface of contacted material or exposed 
skin  area.    No  defaults  for  these  factors  have  been  set;  parameter  values  for  these 
factors are set case by case, based on expert judgement.  

The consideration of dermal exposure in the field of construction articles has up till now 
received  much  less  attention  compared  to  inhalation  exposure;    to  our  knowledge, 
dermal  exposure  to  substances  is  not  considered  in  the  Construction  Products 
Regulation,  nor  in  national  legislative  frameworks  in  the  EU.    For  dermal  exposure, 
there is up till now no standard comparable to CEN/TS 16516 for indoor air emissions. 

Dermal exposure to substances in construction has been touched upon as an exposure 
route  in  some  scientific  papers  (Delmaar  et  al.,  2013;  Clausen  et  al.,  2015),  and  in 
some  EU  RAR  reports.  For  example,  some  exposure  scenarios  for  dermal  exposure  to 
flooring materials are mentioned in the EU RAR of DEHP; in this report,  it is mentioned 
qualitatively  that  'dermal  exposure  to  DEHP    caused  by  dermal  contact  with  building 
materials  such  as  flooring  can  be  a  significant  route  for  children'  ‘  the  example  of 
'babies crawling on the floor" is considered as a relevant exposure scenario - however: 
this  exposure  scenario  is  not  further    elaborated  (no  equations,  exposure  data  given) 
nor quantified in the EU RAR on DEHP.  

4.3.6 INDOOR AIR CONSUMER ASSESSMENT BASED ON ECETOC, RIVM EMISSION MODEL OR 
EXPERIMENTALLY  DETERMINED  EMISSION  RATES:  SIMPLIFICATIONS  COMPARED  TO 
REAL WORLD EXPOSURE  

Emissions  rates  (obtained  via  modelling  or  experimentally  testing)  are  used  to  predict 
concentrations  in  a  reference  room;  these  reference  room  concentrations  are  used  as 
proxy of real world exposure; however, a reference room is a simplification of the real, 
more complex indoor environment.  

Compared  with  the  test  chamber  scenario,  the  real  indoor  environment  situation  is 
more  complex  and  dynamic  in  nature.  The  increasing  complexity  involves  several 
aspects  that  can  lead  to  higher  or  lower  concentration  in  real  indoor  environments 
compared to test chambers.  

4.3.6.1  AIR EXCHANGE RATE 

Firstly,  air  exchange  rates  (AER)  in  real  indoor  environments  might  be  lower  than  the 
defaults  for  ‘ventilation  rate  (n)’  used  for  model  rooms  (Dimitroulopoulou  C,  2012)  – 

152 

 
 
 
leading to increased indoor air levels in real environments. Whereas ventilation rate (n) 
is set constant in time in a test room, in reality, it is a dynamic parameter, depending 
on weather conditions, occupants behavior, type of ventilation system installed, and is 
likely to be variable across different rooms in a building.  

4.3.6.2  MULTIPLE SOURCES 

Indoor-air  concentrations  of  a  substance  will  depend  upon  the  amounts  emitted  from 
that  product  (e.g.  single  wall  or  ceiling  covering  material),    as  well  as  on  amounts 
present because of all other possible sources of that compound, such as other building 
materials  (floor  covering,  etc.),  furniture  and  other  consumer  product  (e.g.  cleaning 
products) (European Collaborative Action, ECA report 29, 2013) 

4.3.6.3  TIME TRENDS IN EMISSIONS  

Whereas test chamber experiments use a 28 days period to reflect chronic exposure, it 
is likely  that  emission in  test  chambers  and  in  real  indoor environments  might  further 
decrease  beyond  this  testing  period.  For  example,  Jarnstrom  et  al.  (2008) 
demonstrated  that  emissions  of  VOCs  in  newly  established  buildings  decreased  clearly 
between  6  months  and  12  after  installation,  while  emissions  of  ammonia  and 
formaldehyde remained the same. Examples of time trends for some CMR substances: 
levels  of  2-ethoxyethanol  decreased  from  5  µg/h/m²  at  day  28  towards  0  µg/h/m²  at 
182  days  testing.  For  ethoxyethyl  acetate,  there  was  a  drop  from  20  to  6  µg/m²/h 
between  28  and  182  days  (see  further  in  Table  33).  In  contrast,  for  dibutylphthalate 
emissions from a PVC flooring, a slight increase between day 28 and day 182 was noted 
(from 32 to 37 µg/m²/h).  

4.3.6.4  LOADING FACTOR  

Loading factors in real environments might deviate from loading factors from a CEN/TS 
16516.  Whereas  loading  factors  for  some  materials  are  in  practice  lower  in  real 
environments  than  in  test  rooms  (e.g.  in  a  room  where  wall  A  is  painted,  wall  B  is 
covered with wall paper, etc.), some multipurpose materials (e.g. OSB panels) might be 
used as both wall, ceiling and flooring material, and as furniture and hereby the default 
loading  factor  underestimating  emission  in  real  indoor  environments  (Wilke  et  al, 
2013). 

4.3.6.5  ADSORPTION, DESORPTION AND INDOOR CHEMISTRY  

Once  chemicals  are  released  from  building  materials,  they  might  be  subjected  to 
adsorption  and  desorption  processes  with  other  indoor  surfaces  (Jorgensen  et  al., 
2000; Lee et al., 2005), and might interact with other chemicals present in the indoor 
environment (Carslaw et al. 2009). These aspects are not accounted for test chambers 
given the use of inert materials and clean air streams in test chambers.  

4.3.7 METHODS  FOR,  AND  EXAMPLES  OF  PROFESSIONAL  EXPOSURE  TO  SUBSTANCES  IN 

CONSTRUCTION ARTICLES  

Methods  and  tools  to  address  inhalation  and  dermal  exposure  to  substances  in 
construction articles described in sections 4.3.1 to 4.3.5 are tailored  toward  consumer 
exposure scenarios, and not to exposure scenarios relevant for professional installation 
of construction articles.  

153 

 
 
Widely  used  workers  exposure  tools  for  addressing  dermal  and  inhalation  exposure 
(e.g.  RiskOfDerm,  EASE,  StoffenManager,  etc.)  are  not  applicable  for  professional 
installation  of  construction  articles.  Above  mentioned  worker  exposure  models  mainly 
deal  with  exposure  scenarios  relevant  in  production  of  chemicals  and  products 
(involving  activities  such  as  mixing,  loading  of  bulk  chemicals,  spraying,  etc.;  see 
PROCs  under  REACH  ),  and  do  not  include  exposure  scenarios  for  installation  of 
construction articles. Notwithstanding the REACH guidance on information requirements 
and  chemical  safety  assessment  (ECHA,  2012)  mentions  as  well  ‘service  life  stage, 
article use by industrial and professional workers” as a relevant exposure scenario, we 
are not aware of tools or standard exposure scenarios describing these uses.  

We have no insight whether and how professional installation of construction articles is 
dealt  with  in  REACH  dossiers  as  chemical  safety  reports  (CSRs)  are  not  publicly 
available. 

In the Risk Assessment Report (EU RAR)  of DEHP (2008), a generic  section 'industrial 
end-use  of  products  containing  DEHP'  is  included  in  the  RAR.  However,  it  has  no 
specific  data  or  mentioning  of  'construction  articles'.  It  states  that  there  is  insufficient 
data to estimate the inhalation and dermal exposure with the EASE model. In addition, 
it  makes  a  vague  statement  that  'end  products  are  assumed  to  emit  relative  little 
vapour,  since  they  are  generally  used  at  room  temperatures,  so  exposure  is  assumed 
to be low.  

Notwithstanding  that  exposure  tools  for  professional  exposure  are  not  applicable  for 
exposure  during    installation  of  construction  articles,  and  that  exposure  tools  for 
consumers  exposure  are  not  adequately  parameterized  to  mimic  exposure  to 
professionals installing construction materials, the processes through which consumers 
and professionals are exposed to substances in construction articles are (partly) similar, 
and thus consumer exposure models could be adapted toward professional exposure by 
modifying  exposure  scenario  parameters  (e.g.  exposure  duration,  surface)  for 
inhalation  exposure  (from  passive  emissions)  and  dermal  exposure  (when  contacting 
construction  articles  during installation).  However,  there  stays  the  gap  that  exposures 
upon  mechanical  manipulations  (drilling,  sawing)  releasing  dust,  which  might  be 
relevant for professionals and do-it-yourself scenarios are ignored in this way. 

4.3.8 GAPS IN CLASSICAL METHODS – UNCOVERED EXPOSURE SCENARIOS  

As  mentioned  above,  the  ‘classical  tools’  (ECETOC  TRA,  diffusion  based  modelling, 
CEN/TS  16516)  do  not  account  for  indirect  exposure  to  substances  via  sorption  on 
settled  dust.  Once  released  to  the  indoor  air,  SVOCs  might  get  adsorbed  onto  house 
dust;  the  re-deposited  dust  can  then  be  ingested  through  hand  to  mouth  contact,  or 
might contribute to dermal exposure.  This route of potential exposure is not covered in 
the current available and widely used exposure tools.   

However,  models  are  under  development  (e.g.  CEFIC  LRI  project  DustEx)  and 
discussions taking place at OECD level on how to produce relevant information for the 
concentration  of  a  specific  substance  in  house  dust  related  to  a  single  article  (ECHA, 
2015).  

An  example  of  DEHP  release  from  PVC  flooring,  sorption  to  dust  and  relevance  for 
exposure is elaborated in section 4.4.1.3. In that section, also some scientific equations 
for prediction levels in dust are given. These equations are  currently not embedded in 
software tools or models.  

Also,  abrasion  of  small  particles  from  construction  materials  is  not  covered  so  far. 
Abrased particles from flooring can also be ingested through hand to mouth contact, or 
might contribute to dermal exposure.  

154 

 
 
 
These  indirect  pathways  and  exposure  scenarios  have  been  described  in  conceptual 
models  (e.g.  Schneider  et  al.,  1999);  however,  they  have  not  been  fully implemented 
in exposure modelling tools generating quantitative estimates of exposure.    

 4.4 SPECIFIC  STUDIES  AND  EXAMPLES  OF  EXPOSURE  TO  CMR  SUBSTANCES 

IN CONSTRUCTION ARTICLES  

The previous sections described generic methods for addressing exposure to substances 
in construction articles (not specifically tailored towards CMR substances).  

The  following  sections  look  more  specifically  at  demonstrated  exposure  to  CMR 
substances in PVC flooring, wall paper and surfaces for sport areas and playgrounds.  

Examples  of  exposure  scenarios  and  quantified  exposures  have  been  searched  for  in 
literature. Some of the  data rely on the above described methods, while other reports 
are based on ad hoc developed exposure scenarios and parameterization. 

4.4.1 EXPOSURE TO CMR SUBSTANCES EMITTED TO INDOOR AIR FROM PVC FLOORINGS AND 

WALL COVERINGS  

4.4.1.1  EMISSION STRENGTHS AND REFERENCE ROOM CONCENTRATIONS  

The  inventory  of  emissions  from  the  BUMA  database  (see  task  2;  paragraph  3.1.2.1) 
has  identified  13  CMR  1A/1B  substances  released  by  at  least  one  of  the  tested 
construction materials. The BUMA database is based on measured emissions, tested in 
test  chambers,  according  to  methods  comparable  to  the  CEN/TS  16516  emission 
testing method.  

The  reported  Specific  Emission  Rates  (‘SER’;  expressed  as  µg/h/m²)  for  materials 
belonging to the groups of ‘resilient flooring coverings99’ (PVC, vinyl, linoleum and other 
resilient types), and wall coverings (wall paper and coverings) from the BUMA database 
have  been  investigated  in  more  detail,  by  listing  the  investigated  materials,  and 
emission strengths reported at day 3 and/or 28 days testing.  

It  is  noted  that  the  BUMA  database  does  not  include  emission  strength  factors  for 
construction materials used as surfaces from playgrounds and sport arenas. 

99 Excluding carpets 

155 

 
 
 
 
                                           
 
The  emission  strengths  (SER)  have  been  converted  to  exposures  in  a  reference  room 
(thus  expressed  as  indoor  air  concentration),  by  accounting  for  appropriate  material 
loading factors (L) and ventilation rates (n), according to:   

Where 

𝐶𝑟𝑟𝑑𝑟𝑟𝑟𝑟𝑟𝑟 𝑟𝑟𝑟𝑟,𝑑  =  

𝑆𝑆𝑆𝑡  × 𝐿
𝑛

Creference room, t= concentration in reference room at time t (expressed in µg/m³) 
SERt= Specific Emission Rate at time t (expressed in µg/m².h) 
L = Loading Factor (expressed in m²/m³) 

n = ventilation rate (expressed in 1/h) 

The  resulting  calculated  reference  room  concentrations  (as  an  expression  of  the 
inhalation  exposure  to  individuals  present  in  rooms  where  these  materials  are  present 
or being installed) is given in the 2 righter end columns in Table 33. 

156 

 
 
 
 
 
 
 
 
Table  33:  Emission  strengths  of  CMR  1A/1B  substances  released  from  resilient  flooring  materials  (e.g.  PVC,  vinyl  and  linoleum),  and 
wall covering (wall paper) in the BUMA database. Calculated reference room concentration at 28 days reflects the estimated indoor air 
concentration  for  the  consumer  scenario  ‘article  service  lifetime  exposure’.  Calculated  reference  room  concentration  at3  days  reflects 
the estimated indoor air concentration for the professional and DIY exposure scenario ‘exposure during installation of materials’*  

Substance 

Material(s) 

Emission rate 

Emission rate 

Measured at 28 days 

Measured at +/-3 days 

Reference 
room 
concentration  at 
28 days 

Reference 
room 
concentration  at  +/-  3 
days 

2-
Ethoxyethanol 

PVC 
flooring  (median 
value  of  19  materials 
produced in 1994) 

5 µg/h/m³ 
(0 at µg/h/m³182 days)  

No data for PVC flooring 

4 µg/m³ 

2-Ethoxy-
ethylacetate 

PVC 
flooring  (median 
value  of  19  materials 
produced in 1994) 

20 µg/h/m² 
(6 at µg/h/m³182 days) 

No data for PVC flooring 

16 µg/m³ 

4  Resilient 
floorings 
(rubber  and  non-rubber 
based)  
Plastic 
assembly (2 materials) 
Vinyl  wall  coverings  (3 
materials) 

laminate 

resilient 

Tire  derived 
flooring material  
(1 material) 
2 Linoleum floorings 

Chloroprene 

Dipentyl-
phthalate 

Dimethyl 
formamide 

Benzene 

No data  

9-18 µg/h/m² 

7-14 µg/m³ 

No data 

No data 

2-120 µg/h/m² 

1.6 – 96 µg/m³ 

0.8- 2 µg/h/m² 
(tested at 8 days) 

1.6 – 4 µg/m³ 

No data  

11 µg/h/m² 

8.8 µg/m³ 

1.5 - 2 µg/h/m² 

0 – 2 µg/h/m² 

1.2 – 1.6 µg/m³ 

0 – 1.6 µg/m³ 

Resilient 
materials) 

flooring 

(4 

No data 

6 µg/h/m² 

4.8 µg/m³ 

Wall paper (2 materials) 

0-2 µg/h/m² 

0 - 2µg/h/m² 

0 – 4 µg/m³ 

0 – 4 µg/m³ 

157 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Substance 

Material(s) 

Emission rate 

Emission rate 

Measured at 28 days 

Measured at +/-3 days 

Reference 
room 
concentration  at 
28 days 

Reference 
room 
concentration  at  +/-  3 
days 

Trichloroethyle
ne 

Di-isobutyl 
phthalate 

based 

Non-rubber 
resilient flooring  
(2 materials) 
Vinyl wall covering  
(6 materials) 

Di 
butylphthalate  

PVC flooring  
(1 material) 

Vinyl wall covering  
(6 materials) 

1-Methyl 
pyrrolidone 

-2- 

Linoleum flooring  
(1 material) 
PVC flooring  
(4 materials) 

No data 

3 µg/h/m² 

2.4 µg/m³ 

0.15-0.46 µg/h/m² 
(at  10  days)  –  no  28 
days reported) 
32 µg/h/m² 
(at  day  182  days:  37 
µg:m³)  

0.8-5 µg/h/m² 
(at  9  days)  –  no  28 
days reported) 

3.8 µg/h/m² 

19 – 69 µg/h/m² 
(at day 182: 8 µg/h/m² 

0.3 µg/h/m² 

0.3 – 0.9 µg/m³ 

0.6 µg/m³ 

No data 

26 µg/m³ 

1-3 µg/h/m² 

1.6 – 10 µg/m³ 

2 -6 µg/m³ 

No data 

No data 

3 µg/m³ 

15 – 55 µg/m³ 

Formaldehyde 

Resilient 
(rubber based)  
(4 materials) 
PVC flooring  
(2 materials) 

Vinyl flooring  
(2 materials) 

flooring 

No data 

1.5 -5 µg/h/m² 

1.2 – 4 µg/m³ 

0-3 µg/h/m² 

2.4 - 8 µg/h/m² 

0-2.4 µg/m³ 

1.9 -6.4 µg/m³ 

19-45 µg/h/m² 

14-16 µg/h/m² 

15 – 36 µg/m³ 

11-13 µg/m³ 

Resilient flooring 
(rubber and non-rubber 
based) (6 materials) 

No data 

1-79 µg/h/m² 

0.8 – 63 µg/m³  

*in absence of manipulations releasing dust. The 3 days test emission chamber only reflect ‘passive’ emissions, without manipulations 

158 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
4.4.1.2  RELEVANT EXPOSURE SCENARIOS 

The  loading  factors  express  the  extent  to  which  a  material  covers  the  indoor  environment 
surface.  Hereto, the loading factor (L) and ventilation rates as laid down in the CEN/TS 16516 
have been applied (for  L = 0,4 m2/m3 for floor & ceiling materials; and 1 m²/m³ for walls; and 
n = 0.5).  

The testing duration of 28 days as prescribed by CEN/TS 16516 is applied as an approximation 
of (long term) article service lifetime exposure. Hereby, it is assumed that emissions tested at 
28 days represent a reasonable worst simulation of the entire service lifetime.  

Therefore, the emissions tested under CEN/TS 16516 at day 28 in a test chamber are to 
be used for assessing indoor concentrations (reference room) under the exposure scenario: 
‘consumer exposure to substances emitted during article service lifetime’  

Some  test  results in  the  BUMA  database  also  include  results  from  testing  at  3  days  stay  of  a 
material  in  test  chamber.  The  three  days  emission  period  originates  from  the  AgBB  protocol 
where emission levels at day 3 are performed as screening, in order to reject/pass samples in 
an early phase; no further meaning of the 3 days period in relation to the exposure duration is 
given. 

However,  the  results  of  the  3  days  testing  might  be  considered  for  use  in  the  professional 
exposure  scenario.  A  three  days  period  seems  a  reasonable  period  reflecting  conditions  and 
exposure  durations  between  unpacking  the  materials  and  finishing  the  installation  of  the 
materials by professionals and consumers in a do-it-yourself scenario.  

Therefore, the emissions tested at day 3 in a test chamber could be considered for use in 
assessing  exposure  (indoor  concentrations)  under  the  exposure  scenario:  ‘professional 
exposure  to  substances  emitted  during  installation  of  construction  materials’  and 
consumer  do-it-yourself  exposure  to  substances  emitted  during  installation  of 
construction materials’.  

The difference between the two groups (professional versus consumer DIY scenario) lies in the 
frequency of the exposure. For a professional, exposures to indoor concentrations derived from 
3  days  testing  during  the  entire  professional  carrier  (8  hours/day;  5  days/week;  during  40 
years) is reasonable, while frequency of exposure to such levels of indoor concentrations in a 
consumer DIY is much lower (no data have been found to parameterize the DIY scenario; we 
estimated a frequency of 8 hours/day; 5 day/year).  

It  should  be  noted  that  the  calculated  exposures  to  CMR  substances  in  Table  33  do  not 
represent  an  EU  representative  picture  of  CMR  substances  exposure  to  consumers  and 
professional in contact PVC flooring and wall paper.  The data should be regarded with the set-
up and extent of the BUMA database: 

the  BUMA  database  is  the  result  of  a  scientific  research  programme,  and  therefore  does  not 
represent  a  systemically  inventory  of  CMR  releases  from  construction  articles  on  the  market 
(which  would  be  the  case  in  a  monitoring  campaign  from  authorities/inspections)  –  so,  the 
BUMA  database  gives  rather  a  snapshot  of  materials  present  on  the  EU  market,  and  no  an 
overall picture of emissions of (CMR) substances from construction articles on the market 

The  BUMA  database  does  not  provide  details  on  the  brand  of  materials,  where  and  how  the 
materials  have  been  purchased  (randomly  or  in  case  of  concern),  and  neither  product 
ingredient or labelling information. However, it gives a general statement saying that materials 
in BUMA Database present building materials commonly used in Europe.  

Given  the  age  of  the  studies  included  in  the  BUMA  database  (namely  before  2008),  it  is 
questionable  whether  the  BUMA  database  reflects  adequately  the  nowadays  market  of 
construction materials in the EU. Nevertheless, since no other more recent database exists, it 
serves as the best available source of information of (CMR) VOC emissions.  

159 

 
 
Nevertheless,  data  in  Table  33  give  an indication  of  (inhalation)  exposure  to CMR  substances 
from  construction  articles.  From  these  data,  it  could  be  derived  that  exposure  to  2 
ethoxyethanol,  2-ethoxy-ethylacetate,  chloroprene,  dipentylphthalate,  Dimethyl  formamide, 
benzene,  trichloroethylene,  Di-isobutyl  phthalate,  Di  butylphthalate,  1  methyl  -2-  pyrrolidone 
and  formaldehyde  might  occur  in  buildings  with  resilient  flooring.  The  estimated  exposure 
levels in Table 33 can be taken forward to the risk assessment of the emissions, by referencing 
against health based criteria (e.g. EU LCI values).  

4.4.1.3  INDIRECT  EXPOSURE  SCENARIOS  RELEVANT  FOR  CONSUMER  EXPOSURE  TO  SUBSTANCES  IN  RESILIENT 

FLOORING AND WALL COVERINGS 

Exposure  assessment  based  on  results  from  emission  studies  in  test  chambers  (or  modelling 
based  on  vapour  pressure/diffusion)  ignore  the  potential  sorption  of  on  settled  dust  and  its 
related  exposure.  However,  this  is  likely  to  be  an  important  exposure  scenario  for  SVOCs 
released  from  PVC  flooring.  Liu  et  al.  (2010)  demonstrated  that  airborne  DEHP  consisted 
mainly  of  particle  phase  bound  DEHP.  This  illustrated  the  need  to  take  into  account  the 
transfer  from  the  gaseous  phase  to  particulate  matter  (PM)  and  settled  dust  in  a  risk 
assessment of SVOC substances. 

Emissions  of  DEHP  from  vinyl  flooring  are  largely  controlled  by  equilibrium  between  the 
material and the gas phase, external convective mass transfer, and also by strong partitioning 
to interior surfaces, including airborne and settled dust.  

Although  needed  for  risk  assessment  and  to  develop  control  strategies,  the  mechanisms 
governing  emissions  and  distribution  of  phthalates  (and  other  SVOCs)  in  the  indoor 
environment  are  still  not  fully  understood  (Clausen  et  al.,  2010).  However,  recent  studies 
attempted  to  tackle  this  issue.  For  example,  Xu  et  al.  (2009)  developed  a  (semi)mechanistic 
model for the release of DEHP from vinyl flooring and the subsequent interactions with interior 
surfaces,  airborne  particles,  dust,  and  human  skin.  Subsequently,  the  oral,  dermal  and 
inhalation  exposure  to  DEHP  released  for  vinyl  flooring  was  assessed.  Xu  et  al.  (2009) 
concluded that ingestion of dust was the dominant pathway in DEHP exposure related to vinyl 
flooring.    This  study  was  limited  to  one  source  (vinyl  flooring)  and  one  phthalate  (DEHP); 
though,  it  consists  of  a  promising  approach  that  could  perhaps  be  extended  to  other  sources 
and other SVOCs, and it demonstrates the importance  of looking beyond emission testing (in 
absence of PM) when performing a risk assessment of SVOCs in construction articles. 

The  study  of  Xu  et  al.  (2010)  demonstrated  the  sensitivity  of  vinyl  source  characteristics 
(surface  area,  material-phase  concentration  of  DEHP),  of  mass-transfer  coefficients  and 
ventilation  rates  on  DEHP  concentrations  and  resulting  exposure.  In  addition,  phthalates  are 
adsorbed strongly to surfaces, including airborne particles and settled dust.  Hence, higher TSP 
(total  suspended  particles)  levels  in  the  indoor  environment  leads  to  increased  sorption  on 
particles,  resulting  in  reduced  gas  concentration;  consequently,  inhalation  exposure  is  lower 
than under conditions of low TSP levels, while oral and dermal exposure increase. 

In their review paper, Weschler and Nazaroff (2010) gathered data on dust borne and airborne 
SVOC contents in thousand dwellings covering 66 SVOCs and used these data to test a simple 
equilibrium  model  for  estimating  the  partitioning  of  an  SVOC  between  the  gas  phase  and  the 
settled dust indoors. They demonstrated that, in central tendency, that a compound’s octanol-
air  partitioning  coefficient  is  a  strong  predictor  of  its  abundance  in  settled  dust  relative  to  its 
gas phase concentration. However, the authors Weschler and Nazaroff (2010) emphasize that 
their approach should be used for median values  from a collection of  measurements made in 
multiple  residences,  and  they  anticipate  that  their  approach  would  not  be  successful  for 
predicting partitioning between the gas phase and settled dust in individual residences. 

In  the  RARs  of  DEHP,  BBzP,  DINP  and  DIDP,  the  contribution  of  PM  was  addressed  as  ‘likely 
significant’.  However,  in  absence  of  a  model,  a  pragmatic  approach  was  used  to  estimate 
phthalate levels in PM in the RARs of these four phthalates: the phthalate concentrations in the 
PM phase were calculated as the 3-fold of the gaseous concentration. This factor 3 was based 
on a study Oie et al. (1997) who found that the exposure via the particulate air phase was 1-3 

160 

 
 
times  greater  than  the  vapour  phase.  This  was  also  supported  by  the  study  of  Wams  (1987) 
who  reported  total  air  concentrations  for  phthalates  exceeding  the  saturated  vapour  pressure 
by 100-fold. 

In  conclusion,  the  relevance  of  gaseous  emission  rates  determined  in  test  chambers  forms  a 
bottleneck  in  indoor  exposure  assessment  since  test  chamber  result  reflect  only  gas  phase 
concentrations  and  do  not  account  for  sorption  to  dust,  which  is  of  significant importance  for 
phthalates.  

Once levels in settled dust are known, one can easily calculate the exposure by multiplying the 
content with typical dust ingestion rates for children (e.g. using the defaults from the US EPA 
Children Exposure factors Handbook). 

Weschler  et  al.  (2006)  estimated  that  ingestion  of  dust  has  a  significant  contribution  to  the 
aggregate  exposure  of  DIBP,  DnPB,  BBzP  and  DEHP  for  infants  and  toddlers  (25  –  70  %). 
Emissions  from  construction  articles  may  have  a  significant  contribution  to  these  phthalate 
levels in indoor dust.  These figures also demonstrate the importance of the indirect consumer 
exposure  ‘ingestion  of  dust’  when  performing  a  consumer  exposure  assessment  of  SVOC 
substances in construction articles.  

4.4.1.4  MONITORING CMR SUBSTANCES IN INDOOR AIR AND DUST IN EUROPEAN BUILDINGS  

Indoor air  

The above paragraphs involve forward prediction of  emissions from wall and ceiling materials 
to  assess  the  (inhalation)  exposure  to  CMR  substances  released  from  these  construction 
materials.  In  addition  to  this  forward  modelling  approach,  one  can  also  perform  a  reverse 
analysis, by evaluating indoor air quality (IAQ- monitoring data of (European) buildings.  

Such an evaluation might help us gives us also insight in how widespread the emission of CMR 
substances    from  the  wall  and  ceiling  materials  are  –  in  terms  of  %  dwellings  in  which  the 
substances occur, and IAQ levels.  

Ideally,  a  coupled  database  of  IAQ  monitoring  data  and  materials  used  in  these  monitored 
environments  (and  related  emission  levels)  should  be  available;  however,  the  link  with 
emission sources is not available in the majority of the cases. Hence the monitoring database 
can only give some general trends, and not point to specific sources.  Thus important limitation 
of the use of IAQ monitoring data is that they seldom enable to identify whether construction 
articles are (main) source or not.  

Recent reviews on IAQ in Europe report levels of some CMR substances in EU buildings: in one 
of these recent reviews, average indoor concentrations of formaldehyde in the EU range from 
15 to 40 µg /m³ Average indoor concentrations of benzene in the EU ranging from 2 to 30 µg 
/m³ have been reported (See Figure 3; Karakitsios et al., 2015). 

161 

 
Figure  3:  Indoor  formaldehyde  and  benzene  concentrations  and  related  cancer  risk  in  EU 
indoor environments (source: Karakitsios et al., 2015) 

For formaldehyde, these data match rather well with the indoor levels measured in the Airmex 
study,  involving  VOC  measurements  in  nearly  300  environments  (public  buildings,  schools, 
kindergartens; private homes) in 11 European cities (Geiss et al. 2011). Average concentration 
of  formaldehyde  in  public  buildings,  schools  and  private  houses  are  16.7  µg/m³  (public 
buildings  and  schools)  and  21.5  µg/m²  (private  houses)  (max.  values:  respectively  49.7  and 
57.2 µg/m³).   

Interestingly,  Geiss  et  al.  (2011)  measured  also  coupled  outdoor  levels,  which  for 
formaldehyde  are  much  lower  compared  to  indoor  concentrations  (average  outdoor  levels  in 
2.6 µg/m³).  

Average concentration of benzene in public buildings, schools and private houses were 4.4 and 
2.8  µg/m²  respectively  in  the  Airmex  study  (max.  values:  respectively  32  and  26  µg/m³).  
Coupled  outdoor  levels  (average  3.2  µg/m³)  were  the  same  order  of  magnitude  as  indoor 
levels.  

In the EXPOLIS study (Edwards et al., 2001), trichloroethylene was measured in several indoor 
environments in Helsinki. In 97 % of the samples, trichloroethylene was not detected (limit of 
detection: 1.33 µg/m³).  The maximum level in the indoor environments was 41 µg/m³.  

In  the  same  study  1-methyl-2-pyrrolidinone  was  also  measured.  In  99  %  of  the  samples,  1-
methyl-2-pyrrolidinone was not detected  (limit of detection: 3.5 µg/m³).  The maximum level 
in the indoor environments was 90 µg/m³.  

The group of the CMR phthalates is also a widely monitored group of compounds in the indoor 
environment. An overview of levels of DiPB, DnPB, BBzP and DEHP in the indoor air (gaseous 
phase + suspended dust fraction) is given in Table 34. 

Indoor settled dust (house dust) 

Fan  et  al.  (2014)  reported  that  in  seven  studies,  levels  of  TCEP  in  settled  dust  have  been 
analysed,  covering  in  total  about  60  samples.  The  average  assigned  value  is  0.79  µg  TCEP/g 
settled dust.  

Data on levels of DiPB, DiPB, BBzP and DEHP in settled house dust is given in Table 35.  

Relevance of indoor settled dust as exposure scenario for SVOC is demonstrated in 4.4.1.5. 

The  monitoring  data  of  CMR  substances  in  house  dust  also  confirm  that  indoor  sources 
containing  CMR  substances  (such  as  construction  articles)  effectively  contribute  to  release  of 
these CMR substances and to accumulation in house dust.   

162 

 
 
 
 
 
 
Table  34:  Measured  concentration  of  phthalates  (CMR  substances)  in  indoor  air  (gaseous  phase  and  suspended  dust)  in  indoor 
environments in the EU  

Phthalate 

Phase 

Concentra-
tion 

Unit 

Residence type 

Statistic 

# 
samples 

Country  Reference 

total airborne 
conc (gas + 
particle phase) 
total airborne 
conc (gas + 
particle phase) 
total airborne 
conc (gas + 
particle phase) 
total airborne 
conc (gas + 
particle phase) 

DEHP 

DEHP 

BBzP 

BBzP 

BBzP 

BBzP 

DIDP 

19 

57 

1 

20 

126 

ng/m³  apartment 

median 

30 

Germany  Fromme et al., 2008 

368 

ng/m³  apartment 

P95 

30 

Germany  Fromme et al., 2008 

ng/m³  apartment 

median 

30 

Germany  Fromme et al., 2008 

ng/m³  apartment 

P95 

30 

Germany  Fromme et al., 2008 

ng/m³  office 

ng/m³  office 

1 

1 

US 

US 

sport hall, kindergarten, 
home carpet and flooring 
store, laboratory, 
greenhouse, 
underground park 
sport hall, kindergarten, 
home carpet and flooring 
store, laboratory, 
greenhouse, 
underground park 

range 

23 

Belgium 

range 

Belgium 

Weschler et al.,1984, 
cited in RAR BBzP 
Weschler et al.,1984, 
cited in RAR BBzP 

Research Institute for 
Chromatography, 2000 
(cited in RAR DIDP) 

Research Institute for 
Chromatography, 2000 
(cited in RAR DIDP) 

5-20 

ng/m³ 

DINP 

7-36 

ng/m³ 

BBzP 

gaseous phase 

35 

ng/m³  homes 

gaseous phase 

90 

75 

ng/m³  homes 

ng/m³  apartment 

BBzP 

BBzP 

163 

median, night-
time sampling 
P90, daytime 
sampling 
P95 

California 

California 

California EPA, 1992, 
cited in RAR BBzP 
California EPA, 1992, 
cited in RAR BBzP 

59 

Germany  Fromme et al., 2004 

 
 
 
 
 
 
 
 
 
 
 
Phthalate 

Phase 

Concentra-
tion 

Unit 

Residence type 

Statistic 

# 
samples 

Country  Reference 

26 

ng/m³  kindergarten 

P95 

18 

Germany  Fromme et al., 2004 

470 

110 
280 

195 

1050 
160 

605 

300 

ng/m³ 

car interior 
homes; based on calculations from 
emissions 
ng/m³  classroom, winter 
ng/m³  classroom, spring 

single value 
single value 

ng/m³ 

classroom, average 
winter-spring 

ng/m³  daycare, winter 
ng/m³  daycare, spring 

ng/m³ 

daycare, average winter-
spring 
ng/m³  offices 

single value 

single value 
single value 

single value 

average 

Muller et al,2003 

Denmark  Clausen et al. 1999 
Denmark  Clausen et al. 1999 

Denmark  Clausen et al. 1999 

Denmark  Clausen et al. 1999 
Denmark  Clausen et al. 1999 

Denmark  Clausen et al. 1999 

Denmark  Clausen et al. 1999 

1 
1 

1 

1 

4 

BBzP 

DEHP 

DEHP 
DEHP 

DEHP 

DEHP 
DEHP 

DEHP 

DEHP 

164 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 35: Phthalate concentrations in indoor settled dust in the EU  

Phthalate 

Conc (mg/kg) 

Value for 

No of samples 
in database 

Location 

Country 

Reference 

970 

703 

600 

480 

604 

28 

29,7 

19 

13 

15,2 

31 

60 

33,6 

72 

80 

129 

210 

500 

4,2 

16,4 

340 

1050 

770 

135 

858 

3214 

515 

median of db 

median of db 

median of db 

29 

30 

65 

median of db 

278 

median of db 

median of db 

median of db 

median of db 

30 

29 

30 

65 

median of db 

278 

median of db 

median of db 

30 

65 

median of db 

278 

median of db 

median of db 

median of db 

median of db 

median of db 

median of db 

median of db 

median of db 

median of db 

median of db 

30 

65 

278 

30 

497 

498 

151 

151 

177 

177 

23 

15 

252 

Germany 

Germany 

Germany 

Germany 

Germany 

Germany 

Germany 

Germany 

Germany 

Germany 

Germany 

Germany 

Germany 

Germany 

Germany 

Germany 

Denmark 

Denmark 

Denmark 

Denmark 

Bulgaria 

Bulgaria 

Sweden 

Sweden 

Denmark 

Denmark 

Germany 

Butte et al., 2008 

Fromme et al., 2008 

Kersten and Reich, 2003 

Nagorka et al,.2005 

Abb et al., 2009 

Butte et al., 2008 

Fromme et al., 2008 

Kersten and Reich, 2003 

Nagorka et al,.2005 

Abb et al., 2009 

Kersten and Reich, 2003 

Nagorka et al,.2005 

Abb et al., 2009 

Kersten and Reich, 2003 

Nagorka et al,.2005 

Abb et al., 2009 

Langer et al. 2010 

Langer et al. 2010 

Langer et al. 2010 

Langer et al. 2010 

Kolarik et al,2008 

Kolarik et al,2008 

Bornehag et al.2005 

Bornehag et al.2005 

Clausen et al. 2003 

Clausen et al. 2003 

Becker et al.2004 

households 

households 

households 

households 

homes 

daycare 

homes 

daycare 

homes 

schools 

DEHP 

DEHP 

DEHP 

DEHP 

DEHP 

BBzP 

BBzP 

BBzP 

BBzP 

BBzP 

DIDP 

DIDP 

DIDP 

DINP 

DINP 

DINP 

DEHP 

DEHP 

BBzP 

BBzP 

BBzP 

DEHP 

DEHP 

BBzP 

DEHP 

DEHP 

DEHP 

165 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
4.4.1.5  LINK BETWEEN INDOOR SOURCES AND INDOOR AIR LEVELS OF CMR SUBSTANCES 

An important limitation of the use of IAQ monitoring data is that they seldom allow to 
identify whether construction articles are the (main) source or not.  

Based  on  the  indoor  -  outdoor  air  ratios  of  CMR  substances  (e.g.  determined  in  the 
study  of  Geiss  et  al.,  2011),  it  can  be  derived  that  for  formaldehyde,    indoor  sources 
(such  as  construction  articles)  are  the  main  source  of  indoor  levels  of  formaldehyde; 
while  for  benzene  outdoor  air,  and  not  indoor  sources,  are  main  factors  explaining 
benzene indoor levels. 

Some  studies  have  made  the  linkage  between  VOC  concentrations  to  their  indoor 
sources  in  a  selected  set  of  indoor  environments.    Missia  et  al.  (2010)  measured 
simultaneously  IAQ,  ventilation  rates  and  emissions  from  materials  present  in  these 
premises,  using  the  Field  and  Laboratory  Emission  Cell  (FLEC)  cell.  These  coupled 
experiments  allowed  the  researchers  to  calculate  the  relative  contribution  of  building 
materials  to  IAQ.  Depending  on  type  of  material,  environment  and  considered 
substance, the contribution of building materials to total (monitored) IAQ was from 0 % 
up to 30 % (Figure 4). For example, emissions from paints are responsible for 30 % of 
the indoor levels of benzene, o-xylene and m&p- xylene in a residential setting in Milan, 
while  paints  do  not  contribute  to  indoor  levels  of  a-pinene  and  d-limonene  in  that 
setting. In a residential setting in Nicosia, paints contribute to 20 % of indoor levels of 
formaldehyde  and  o-xylene  and  m&p-  xylene.  Laminate  floorings  contributed  to  12  % 
of the formaldehyde indoor levels in Nicosia.  

The relevance of the Missia et al. (2012) for this study is limited to two measured CMR 
substances, namely benzene and formaldehyde.  Other CMR  substances have not been 
assessed by Missia et al. (2012). 

Figure  4:  Building  material  contribution  to  IAQ  in  indoor  environments  in  premises  in 
Milan and Nocosia (from the BUMA project, Missia et al., 2010) 

4.4.2 CMR  SUBSTANCES  PRESENT  IN  SURFACES  FROM  SPORT  AREAS  AND  PLAYGROUNDS 

RECYCLED TIRES 

Synthetic turf or granulates from recycled rubber tyres are used as ground coverings on 
playgrounds and outdoor and indoor sport fields, in the form of unbound granulates or 
embedded in rubber mats  (BfR, 2010;  KEMI, 2006).  

Several substances used in the manufacturing of tyres – and thus also in the recycled 
materials  -  have  CMR  properties.  Examples  of  relevant  substances  are  polyaromatic 
hydrocarbons  (present  in  high  aromatic  oils)  including  CMR  substances  such  as 

166 

 
 
 
 
 
benzo(a)pyrene,  phthalates,  phenols  (such  as  alkyl  phenols),  and  metals  (zinc,  lead, 
copper, chromium and cadmium). 

Potential exposure due to the use of, and contact with, these playgrounds and surfaces 
for sport fields and have been investigated by authorities in the EU (BfR, KEMI, 2006; ) 
and outside the EU (Californian OEHHA, 2007). 

OEHHA  found  46  studies  in  the  scientific  literature  that  measured  the  release  of 
chemicals  by  recycled  tires  in  laboratory  settings  and  in  field  studies  where  recycled 
tires were used in civil engineering applications: 49 chemicals were identified.  Seven of 
the chemicals leaching from tire shreds in published studies were carcinogens (OEHHA, 
2007). 

In Sweden, synthetic turf is mainly used for football pitches, but it is used also for other 
sporting  surfaces,  golfing  greens,  gardens,  indoor  gardens,  school  playgrounds  and 
trade  fairs.  NILU  estimated  that  in  Sweden,  approximately  150  football  pitches  are 
made  of  synthetic  turf  (NILU,  2005).  These  include  both  large  pitches  used  for  elite 
football and small pitches that are used mainly by children and young people.  

Most  pitches  are  located  outdoors,  although  a  few  are  located  indoors.      It  has  been 
estimated  that  90%  of  the  existing  synthetic  turf  surfaces  in  Sweden  contain  rubber 
from recycled tyres (NILU, 2005).  

4.4.2.1  EXPOSURE SCENARIOS 

Data for three exposure scenarios relevant for exposure to substances in surfaces from 
sport areas and playgrounds have been found in the literature:  

•  consumer  exposure  to  substances  released  to  the  skin  during  article  service 

lifetime; exposure pathway: dermal exposure  (skin contact exposure scenario) 

•  consumer  exposure  to  substances  released  to  the  indoor  air  during  article 

service lifetime; exposure pathway: inhalation exposure  

•  consumer exposure following accidental ingestion during article service lifetime; 

exposure pathway: inhalation exposure  

4.4.2.2  EXPOSURE ASSESSMENT FOR SKIN CONTACT EXPOSURE SCENARIO  

In a Risk assessment report of BfR report in the context of a restriction proposal under 
REACH  (BfR,  2010),  a  case  of  PAHs  in  sport  field  surfaces  and/or  rubber  mats  and 
granules from recycled crumb rubber has been investigated.  

BfR  calculated  dermal  exposure  according  to  the  ECHA  guidance  for  exposure 
estimating (ECHA, 2008)   

Two exposure scenarios for dermal exposure have been elaborated:  

•  Granules  put  under  a  playing  slide  or  a  swing.  It  may  happen  that  a  playing 
child  falls  down  on  this  ground  (which  is  normal  for  slides)  (referred  as  ‘slide 
scenario’) 

•  walking or standing on  granules or rubber mats  (referred as ‘walk scenario’) 

167 

 
 
 
 
Hereto, information regarding the following exposure factors had been gathered:  

  Concentration of PAHs in rubber granulates:  

-  Total PAH content:  45 and 76 mg/kg, that of 
-  Content of BaP:  0.06 and 8.58 mg/kg. 

•  Thickness of the granulates, or rubber mat layer: 0.1 cm  

•  Migration  rates  of  BaP  for  the  tested  materials  varied  for  10  %/h  (worst  case, 
dynamic  migration  with  friction)  to  0.2  %  (mean  of  dynamic  migration  without 
friction).  

Note  that  the  term  ‘migration  rate’  here  reflects  migration  from  material  to  a 
skin  simulant  solution.    Since  no  standardized  test  procedures  are  in  place  for 
dermal  exposure,  different  testing  conditions  have  been  performed,  and  worst-
case results (10%/h) have been taken forward in calculations 

•  Body weight: 60 kg (adult) and 10 kg (child) (ECHA default values for BW)  

•  Exposed  skin  area,  contact  time,  frequency  of  contact  between  skin  and 

playground or sport area:  

Exposure factors 

Exposed skin area 

Contact time 
Frequency  

Slide scenario 

Walk scenario 

5000 cm²  (= half of the 
body surface of a 6 to 10 
year-old child) 
less than 30 seconds 
50 times sliding 

bare feet area of 340 cm 

2 hours 
Once  

Is  it  not  explicitly  mentioned  in  the  BfR  report  how  these  numbers  for  contact  time, 
frequency  and  contact  area  have  been  chosen.  Probably,  these  are  based  on 
assumptions and personal estimates by the authors. 

The  resulting  exposure  calculated  by  BfR  based  on  these  exposure  parameters  are 
summarized in Table 36. In conclusion, exposure under the slide scenario is estimated 
as 105 µg PaB/kg bw for a child, while exposure under the walk scenario is 34 BaP/kg 
bw.  

168 

 
 
 
 
 
 
 
 
 
Table  36:  Estimation  of  PAH  exposure  of  consumers  from  rubber  granulates  using  an 
approach which considered experimentally determined migration (source: BfR, 2010) 

In  parallel  to  the  method  starting  from  measured  migration  rates  (cfr.  Method  in 
section  4.3.6),  the  ECETOC  approach  for  assessing  dermal  exposure  to  substances  in 
articles has been applied in the annex XV dossier of BfR (cfr. method in section 4.3.1). 
The outcome of the ECETOC predictions is listed in Table 37.  

Table  37:  Estimation  of  PAH  exposure  of  consumers  from  rubber  granulates  using  the 
ECETOC TRA approach (source: BfR, 2010) 

Interestingly,  the  ECETOC  TRA  approach  did  not  calculate  estimates  that  are  higher 
than  values  calculated  using  the  experimentally  determined  migration.  According  the 

169 

 
 
 
 
 
BfR,  the  range(s)  estimated  by  different  approaches  (ECETOC  TRA  or  experimentally 
and taking different migration rate data) demonstrate that there are high uncertainties 
of the  evaluation of consumer  exposure to  PAHs in rubber mats, which are due to the 
defaults  values  chosen,  and  the  model  approach,  in  particular  the  default  for  layer 
thickness  and  the  extrapolation  of  released  amounts  to  the  contact  area.  In  addition, 
the  behaviour  data  may  be  criticised  as  too  conservative  and  unrealistic.  It  is  obvious 
that the basis for migration data is very heterogeneous and inappropriate to prepare a 
sound exposure estimate (BfR, 2010).  

In  conclusion,  methods  and  examples  for  assessing  dermale  exposure  to  substances 
released  from  construction  articles  do  exists;  however,  due  to  several  shortcomings 
(e.g.  adequate  extraction  procedures  for  realistic  release  from  material  to  skin)  the 
current methods are still inappropriate to generate sound exposure estimate.  

4.4.2.3  EXPOSURE SCENARIOS:  INHALATION EXPOSURE SCENARIO 

Exposure  to  substances  released  from  synthetic  turf  to  the  indoor  air  has  been 
investigated  by  the  Norwegian  Institute  for  Air  Research  (NILU)  in  2005.  NILU 
investigated several assessments carried out at the Luleå University of Technology, and 
IVL The Swedish Environmental Research Institute, and at various research institutions 
in  Norway.  A  few  measurements  and  assessments  of  synthetic  turf  have  been  carried 
out in Norway in the period 2004 - 2005. 

The  report  mentions  that  air  measurements  of  PAHs  (BaP)  and  in  2  indoor  Norwegian 
halls with tyre recycled synthetic turf (BaP in PM 10 was 1.15 ng/m³ in hall 1 and 0.56 
ng/m³  in  hall  2)  were  higher  than  the  indoor  levels  in  a  hall  with  granulate  of 
thermoplastics  (0.38  ng/m³).  There  was  no  difference  in  phthalate  indoor  levels 
between halls with and without tyre recycled synthetic turf as ground covering. 

Whereas emission tests in test chambers reflect the passive emission from substances 
to the indoor air, irrespective of activities, or mechanical stress exerted on the material, 
the  IAQ  monitoring  data  in  real  sport  arenas  (including  monitoring  in  PM  fractions) 
reflect  the  overall  sources  and  pathways  of  release  from  materials.  For  the  case  of 
surface  used  as  sport  arenas,  mechanical  friction  and  abrasion  from  the  floor  might 
form  an  additional  important  route  of  exposure,  especially  for  SVOC  or  nonvolatile 
substances. However, it should be mentioned that contribution from other sources than 
tyre recycled ground coverings might also contribute to the measured levels of BaP and 
phthalates in the sport halls. 

Given  the  small  number  of  measurements  in  few  halls  and  occasions,  it  is  difficult  to 
make a reliable assessment of health risk according to NILU (2005). 

The report concludes that the use of granulate from recycled rubber involves significant 
negative effects on the indoor climate (NILU, 2005). However, the levels in sport halls 
with recycled rubber lie under the established guidelines for occupational exposure and 
indoor  air  limit  values  in  Sweden;  therefore  it  was  concluded  that  the  health  risk  for 
players is probably low (KEMI, 2006). 

4.4.2.4  EXPOSURE SCENARIOS:  ORAL EXPOSURE SCENARIO 

Potential  toxicity  from  chemical  exposure  to  substances  in  playground  and  track 
surfaces, manufactured from recycled tyre waste was also the subject of a report of the 
California Office of Environmental Health Hazard Assessment (OEHHA, 2007).  

The  report  is  mainly  focused  on  the  toxicity  point  of  view;  and  less  from  an  exposure 
point of view.  Notwithstanding, 2 oral exposure scenarios have been investigated:  

170 

 
 
•  Pica  behaviour:  one  time  ingestion  of  10  gram  of  tire-shreds  by  a  three-years 

old child 

•  Chronic hand-mouth contact  (children in contact with playground surfaces) 

Pica-behaviour:  

Based  on  leachable  amounts  of  the  7  carcinogenic  substances  found  the  tyre-shred, 
and    an  ingestion  amount  of  10  gram  shred  (typical  value  for  pica-behaviour),  it  was 
estimated  by  OEHHA  that  resulting  increased  cancer  risk    was    1.2  x  10-7  (1.2  in  ten 
million).  According  to  OEHHA,  this  risk  is  well  below  the  de  minimis  level  of  1  x  10-7 
(one  in  one  million),  generally  considered  an  acceptable  cancer  risk  due  to  its  small 
magnitude compared to the overall cancer rate (OEHHA, 2007). 

In addition to the data from literature for ‘leachable amounts’, the OEHHA conducted a 
gastric  digestion  experiment  in  which  22  chemicals  were  found  to  be  released  by  tire 
shreds incubated for 21 hours at 37°C in a solution mimicking the gastric environment.  
If  the  released  chemicals  were  ingested  as  a  onetime  event  and  averaged  over  a 
lifetime,  the  cancer  risk  would  be  3.7  x  10-8  (3.7  in  one  hundred  million).  This  risk  is 
considerably  below  the  di  minimis  risk  level  of 1  x  10-6  (one in  one  million),  generally 
considered  an  acceptable  cancer  risk  due  to  its  small  magnitude  compared  to  the 
overall cancer rate (OEHHA, 2007). 

The assumption that the risk from a onetime exposure is equivalent to the risk from the 
same dose spread over a lifetime is uncertain, and may overestimate or underestimate 
the true risk (OEHHA, 2007).  

171 

 
 
 
 
Chronic hand-mouth contact (children in contact with playground surfaces) 

OEHHA performed wipe sampling of in-use playground surfaces containing recycled tire 
rubber.  From among the five chemicals identified by wipe sampling, the PAH chrysene 
is a carcinogen. Assuming playground use from 1 through 12 years of age, an increased 
cancer risk of 2.9 x 10-6 (2.9 in one million) was calculated due to the chronic ingestion 
of chrysene. This risk is slightly higher than the di minimis risk level of 1 x 10-6 (one in 
one million), generally considered an acceptable cancer risk due to its small magnitude 
compared  to  the  overall  cancer  rate.  Calculation  of  the  2.9  x  10-6  (2.9  in  one  million) 
value does not account for many uncertainties, some of which would decrease the risk 
while others would increase the risk (OEHHA, 2007). 

 4.5 LIKELYHOOD  OF  EXPOSURE  FROM  CONSTRUCTION  ARTICLES  TO  CMR 

SUBSTANCES FROM TASK 2 

On  the  basis  of  identified  pairs  of  CMR  1A/1B  substances  and  construction  articles 
gathered  in  task  2  (Table  17),  in  this  task,  an  assessment  was  made  for  which 
materials/substance combinations the exposure for consumers is possible or likely.  

Hereto,  the  matrix  of  CMR  1A/1B  substance  –  article  category  pairs  from  task  2  (, 
started as a basis was complemented with five criteria providing evidence for consumer 
exposure  arising  from  construction  articles.    These  five  additional  criteria  (and  data 
sources used to find relevant information) are listed in the table below:  

Data supporting likelihood of 
presence/absence of consumer 
exposure 

From task 2 (e.g. manufacturing 
declarations based on article 33 of REACH; 
information notifications and registration 
dossiers)   

Note: for several substances/construction 
article pairs there is a lack of monitoring 
data (content measurements); however, 
based on the information from registration 
and SVHC notifications it is as default 
assumed that substances is present in levels 
> 0.1% .  

From task 2 (e.g. emission records of 
substances for various construction articles) 

Note:  data from test chamber experiments 
according to method CEN/TS 16516 (or 
similar method) used. Note that only 
substances within the spectrum of this 
method (see Table 21: 57 VOCs; and Table 
22: 13 SVOCs) are identified using this 
criterion.   

From existing exposure scenario studies 
(e.g. EU RAR reports) 

Criterion 

Criterion 1: presence of CMR in 
construction articles 

Criterion 2: emission of CMR in 
construction articles (from 
monitoring programs) 

Criterion 3: estimated exposure 
(modelling), taking into account 
release, article loading,  exchange 
rate in indoor environments 

172 

 
 
 
Criterion 

Data supporting likelihood of 
presence/absence of consumer 
exposure 

Criterion 4: measured indoor 
exposure (monitoring Indoor Air 
Quality (IAQ) in buildings) 

From (European) indoor air quality 
monitoring studies on indoor air and indoor 
dust  

Criterion 5: source apportioning 
supporting that construction articles 
are main source of indoor exposure    

From literature on indoor air and source 
apportioning  

Moving  from  criterion  1  to  5  gives  increasing  evidence  for  exposure  to  CMR  1A/1B 
substances in relation to their presence in construction articles.  

A case by case assessment (pairs of substances and uses in construction applications) 
of  these  5  criteria  (and  references  to  data  supporting  these  criteria)  can  be  found  in 
Annex 3.  

Based  on  the  scoring  for  these  5  criteria,  the  pairs  of  construction  articles  (CA)  and 
CMR substances were organized into groups. Pairs of CA/CMR substances belonging to 
the  same  group,  have  a  similar  likelihood  of  consumer  exposure  to  CMR  substances 
present in construction articles.  

It should be noted that the scoring of the criteria was used in a qualitative manner to 
allocate  pairs  of  CA/substances  into  one  of  the  groups.  It  was  neither  feasible  nor 
appropriate  to  use  the  scoring  of  the  criteria  in  a  (semi)quantitative  way.  This 
qualitative  way  of  using  the  criteria  is  explained  by  group  here  below  (see  4.5.1  - 
4.5.8) and applied in Annex 3. 

The following groups have been identified:  

Group no. 

Group name 

Group 1: 

Group 2: 

Group 3 

CMR substances for which there is evidence of presence in CA, and with 
a high likelihood of consumer exposure, and widespread exposure in the 
EU   

CMR substances for which there is evidence of presence in CA and with 
moderate  likelihood  of  consumer  exposure,  exposure  in  limited  fraction 
of buildings in EU 

CMR substances for which there is no evidence that the substances are  
present in CA ; though these substances have been demonstrated to be 
released  from  CA,  (e.g.  as  a  result  of  secondary  reactions,  or  from 
impurities)  
Subdivided into:  

     Group 3A 

high likelihood of consumer exposure (widespread exposure) 

Group 3B 

possible  likelihood  of  consumer  exposure  (CA  minor  source  of 
exposure) 

Group 3C 

not possible to assess the extent of exposure 

173 

 
 
 
 
 
 
 
       
 
 
 
 
Group no. 

Group name 

Group 4 

CMR substances for which there is evidence of presence in CA; available 
information  indicates  that  exposure  is  possible;  more  data  needed  for 
confirmation and to assess the extent of exposure 

Group 5: 

CMR substances for which there is evidence of presence in CA for which 
no assessment is possible 

Group 6 

Group 7 

CMR  substances  for  which  there  is  evidence  of  presence  in  CA  with 
indirect evidence for low likelihood of consumer exposure 

CMR  substances  for  which  there  is  evidence  of  presence  in  CA  with 
(very) low likelihood of consumer exposure 

The allocation of substance/construction article pairs into these groups is summarized 
in Table 38 and further explained in the text below.

174 

 
 
 
Table  38:  Allocation  of  substance/construction  article  pairs  into  groups  of  likelihood  of  exposure  to  CMR  substances  in  construction 
articles (identification of substance and construction articles: see Chapter 3. 

Group 

Substance 

EC-number 

Use in construction articles 

Group 1: CMR substances for which there is evidence of presence  in CA  and  with high likelihood of consumer exposure, and widespread exposure 

Formaldehyde 

200-001-8 

Resilient, textile and laminate floor coverings 

Gypsum and gypsum based products 

Round and sawn timber 

Wood based panels 

Wall covering 

Thermal insulation materials 

Di-isobutyl phthalate* 

201-553-2  

wall covering  

SU 19: building and construction work;  ERC 3 (formulation in materials); not further specified 

cat 8: floor covering: PVC floor covering (cushion vinyl) 

no authorized use in domain of construction article (sunset date: 21/02/2015) 

Dibutylphthalate* 

201-557-4  

wall covering  

Benzylbutylphthalate* 

 201-622-7   

cat 8: flooring material 

cat 1: used in roll doors 

other: insulation and sealing materials in air conditioning units and heat pumps 
tarpaulin covers (roofing) 

no authorized use in domain of construction article (sunset date: 21/02/2015) 

Bis-(2-ethylhexyl)phthalate (DEHP) 

204-211-0  

No authorized use in domain of construction articles (sunset date: 21/02/2015) 

cat. 1: doors, windows, shutters, building hardware and curtain walling: fence roll doors, seals for windows, 
doors, wooden doors 
cat 8: floor covering made by PVC, flooring 
plastic floor tiles 
plastic flooring 
PVC floor coverings (cushion vinyl 
others: tarpaulin covers (as roofing) 
shower hoses (sanitary appliances 
authorized use of DEHP in manufacturing of PVC articles, of which several used in construction (e.g. PVC 
flooring, window frames, plastic pipes) 

175 

 
 
  
  
 
 
  
 
 
  
 
 
  
 
 
  
 
 
  
 
 
  
  
 
 
  
 
 
  
  
 
 
  
 
 
  
 
 
  
  
 
 
  
  
 
 
  
 
 
  
  
  
Group 

Substance 

EC-number 

Use in construction articles 

Group 2: CMR substances for which there is evidence of presence  in CA  and with moderate likelihood of consumer exposure, exposure in limited 
fraction of buildings in EU; 

Group 3: CMR substances for which there is no evidence that the substances are present in CA ; though these substances have been demonstrated to be 
released from CA (e.g. as a result of secondary reactions, or from impurities)  

group 3A: high likelihood of consumer exposure (widespread exposure) 

group 3B: possible likelihood of consumer exposure (CA minor source of exposure) 

Benzene 

200-753-7  

Resilient, textile and laminate floor coverings 

Gypsum and gypsum based products 

Round and sawn timber 

Wood based panels 

Wall covering 

painted articles 

Trichloroethylene* 

201-167-4  

Resilient, textile and laminate floor coverings 

Wood based panels 

not possible to identify type of construction article in which it is used 

no authorized use in domain of construction article (sunset date: 21/04/2016) 

Construction articles as a source of TCE are not mentioned in the RAR  

group 3C: not possible to assess the extent of exposure 

Chloroprene 

204-818-0  

Resilient, textile and laminate floor coverings 

N,N-dimethyl acetamide 

204-826-4  

gypsum and gypsum based products 

none of the uses in the notification dossier  could be related construction articles 

Dipentylphthalate 

Dimethyl formamide 

2-Ethoxyethanol 

210-088-4  

wall coverings 

200-679-5  

Resilient, textile and laminate floor coverings 

 203-804-1   

Resilient, textile and laminate floor coverings 

wood based panels 

176 

from the information in the EU RAR, it is deduced that construction articles treated with inks or lacquers may  
contain 2 ethoxy-ethanol 

 
 
 
 
 
 
 
 
 
 
 
  
  
 
 
  
 
 
  
 
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
 
 
  
  
  
  
 
 
  
  
  
Group 

Substance 

EC-number 

Use in construction articles 

Group 4: CMR substances for which there is evidence of presence in CA ; available information indicates that exposure is possible; more data needed for 
confirmation and to assess the extent of exposure 

2-Ethoxy-ethylacetate  

203-839-2  

Resilient, textile and laminate floor coverings 

Tris(2-chloroethyl)phosphate* 

204-118-5  

use in stone, plaster, cement, glass and ceramic articles 

not possible to identify : no information on identified uses related to article categories is mentioned in the 
notification dossier 

roof insulation 

SU 19: building and construction work;  ERC 10a (Wide dispersive outdoor use of long-life articles and 
materials with low release; not further specified 

No authorized use in domain of construction articles (sunset date: 21/08/2015) 

1-Methyl -2- pyrrolidone 

212-828-1  

Resilient, textile and laminate floor coverings 

maybe there are some additional uses not mentioned in notification dossier (confidential uses) 

from the information in the EU RAR, it is deduced that construction articles treated with inks or lacquers may  
contain 1-vinyl-2-pyrrolidone 

Beryllium 

231-150-7  

SU 19: building and construction work;  ERC 3 (formulation in materials); not further specified 

Group 5 : CMR substances for which there is evidence of presence in CA  for which no assessment is possible 

Diboron trioxide 

 215-125-8   

use in stone, plaster, cement, glass and ceramic articles 

Boric acid 

Disodium tetraborate  anhydrous 

177 

service life of cellulose insulation (cat. 3) 

SU 19: building and construction work;  ERC 3 (formulation in materials); not further specified 

use in stone, plaster, cement, glass and ceramic articles 

SU 19: building and construction work;  ERC 3 (formulation in materials); not further specified 

use in stone, plaster, cement, glass and ceramic articles 

233-139-2; 
234-343-4   

233-139-2; 
234-343-4   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
  
 
 
 
  
 
 
 
  
  
 
 
  
 
 
  
  
 
 
  
Group 

Substance 

EC-number 

Use in construction articles 

service life of cellulose insulation  

natural fibre insulation product 

use of borates in plasterboards and wood (cat. 6, cat. 10)  

SU 19: building and construction work;  ERC 3 (formulation in materials); not further specified 

Magnesium nitrate 

Potassium pentaborate 

233-826-7  

SU 19: building and construction work;  ERC 3 (formulation in materials); not further specified 

234-371-7  

SU 19: building and construction work;  ERC 3 (formulation in materials); not further specified 

Aluminosilicate Refractory Ceramic Fibres are 
fibres covered by index number 650-017-00-8 in 
Annex VI 

use in stone, plaster, cement, glass and ceramic articles 

Group 6: CMR substances for which there is evidence of presence in CA  with indirect evidence for low likelihood of consumer exposure 

Cadmium oxide  

215-146-2  

SU 19: building and construction work;  ERC 3 (formulation in materials); not further specified 

Orange lead (lead tetroxide) 

215-235-6  

consumer use of ceramics (cat 2) 

use in ceramics, glasses, enamels and  plastics 

Lead sulfochromate yellow (C.I. Pigment 
Yellow 34) 

215-693-7  

cat 1: fences: roll doors 

service life of coated articles: stone, plaster, cement, glass and ceramic articles ((cat. 1, cat. 2, cat. 5, cat. 7, 
cat. 10) ) 

cat 6: pigments in articles (wood) 

other: tarpaurin covers (e.g. roofing) 

SU 19: building and construction work;  ERC 3 (formulation in materials); not further specified 

authorized use which is potentially indirectly relevant for construction article (authorized use: Distribution 
and mixing pigment powder in an industrial environment into solvent-based paints for non-consumer )use 

231-111-4  

Nickel used in production of stainless steel (with uses of steel in construction sector) 

231-152-8  

SU 19: building and construction work;  ERC 3 (formulation in materials); not further specified 

use of cadmium is restricted for use in articles for several plastic materials 

use in ceramics, glasses, enamels and  plastics 

Nickel 

Cadmium 

178 

 
 
  
 
 
  
 
 
  
 
 
  
 
 
  
  
  
 
  
 
 
 
  
 
 
 
 
 
 
 
  
  
 
 
  
  
 
 
 
  
  
 
 
  
 
 
  
 
 
  
 
 
  
  
 
 
  
 
 
  
  
 
 
  
  
  
 
 
  
 
 
Group 

Substance 

EC-number 

Use in construction articles 

Lead chromate* 

231-846-0  

cat 1: fences: roll doors 

Trilead dioxide phosphonate 

235-252-2   

 'use of lead-stabilized plastic materials as an internal structural component of buildings  

other: tarpaulin coverings (e.g. roofing) 

No authorized use in domain of construction articles (sunset date: 21/05/2015) 

Lead chromate molybdate sulphate red (C.I. 
Pigment Red 104) 

235-759-9  

 fences: roll doors 

service life of coated articles: stone, plaster, cement, glass and ceramic articles  

 pigments in articles (wood) 

other: tarpaurin covers (e.g. roofing) 

SU 19: building and construction work;  ERC 3 (formulation in materials); not further specified 

authorized use which is potentially indirectly relevant for construction article (authorized use: Distribution 
and mixing pigment powder in an industrial environment into solvent-based paints for non-consumer )use 

Group 7: CMR substances for which there is evidence of presence in CA  with (very) low likelihood of consumer exposure 

Acrylonitrile 

203-466-5  

SU 19: building and construction work;  ERC 3 (formulation in materials); not further specified 

bold underlined: substances included in Annex XIV of REACH (“Authorization List”)  

*: Substances included in Annex XIV of REACH and anticipated not to be present in CA after sunset date; and therefore no longer to 
lead to consumer exposure after that date 

179 

 
  
  
 
 
  
 
 
  
  
 
 
 
  
  
 
 
  
 
 
  
 
 
  
 
 
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
4.5.1 GROUP 1: “CMR SUBSTANCES FOR WHICH THERE IS EVIDENCE OF PRESENCE IN CA AND WITH 

HIGH LIKELIHOOD OF CONSUMER EXPOSURE, AND WIDESPREAD EXPOSURE IN EU”   

For this group of substances/construction articles: the evidence from all criteria (criteria 1 – 5) 
support  the  likelihood  of  widespread  consumer  exposure  to  these  CMR  substances,  with 
construction articles demonstrated to be an important source.  

For  example:  for  formaldehyde  and  DEHP:  1)  substances  are  suspected  to  be  present  in 
construction  articles  (from  notification  dossiers  or  registration  dossiers  ,  2)  emissions  from 
construction articles demonstrate release, 3) exposure estimates have been previously made, 
4)  monitoring  data  in  indoor  air  and  indoor  dust  demonstrate  the  ubiquitous  presence  in  EU 
indoor  environments,  and  5)  source  apportionment  studies  have  demonstrated  that 
construction articles are an important source of these indoor levels.  

o  Restrictions  regarding  these  substances/article  pairs  would  probably  be  an  efficient 

measure to reduce consumer exposure to these CMR substances  

The  detailed  evidence  for  criteria  1-5  for  each  substance  (in  relation  to  Construction  Article) 
categorized into group 1 can be found in Annex 3.  

4.5.2 GROUP 2: “CMR SUBSTANCES FOR WHICH THERE IS EVIDENCE OF PRESENCE IN CA AND WITH 
MODERATE  LIKELIHOOD  OF  CONSUMER  EXPOSURE,  EXPOSURE  IN  LIMITED  FRACTION  OF 
BUILDINGS IN EU” 

   For  this  second  (limited)  set  of  substances/construction  articles:  the  substance  is 
suspected  to  be  present  in  construction  articles,  however,  the  release  is  (very)  low,  and 
monitoring  data  in  indoor  air  demonstrate  that  these  substances  rarely  occur  in  indoor 
environments.  So,  consumer  exposure  is  very  low  (except  in  some  rare  cases  (e.g.  99th 
percentiles of indoor levels) 

4.5.3 GROUP  3:  SUBSTANCES  FOR  WHICH  THERE  IS  NO  EVIDENCE  THAT  THE  SUBSTANCES  ARE 
PRESENT IN CA IN LEVELS > 0.1 %; THOUGH THESE SUBSTANCES HAVE BEEN DEMONSTRATED 
TO  BE  RELEASED  FROM  CA  (E.G.  AS  A  RESULT  OF  SECONDARY  REACTIONS,  OR  FROM 
IMPURITIES)  

For  a  third  set  of  substances/construction  article  pairs,  there  is  no  indications  that  the 
substances  are  present  in  construction  articles  (no  notifications,  no  registrations);  however, 
release  of  these  substances  from  construction  articles  has  been  measured  (data  described  in 
literature), and some of these substances are also widely present in indoor environments.  The 
release might either be due to impurities or the generation of degradation products (not added 
as ingredient in manufacturing), or the SVHC substance and its use have (wrongly) not been 
notified  as  present  in  article  to  ECHA.    If  the  first  reason  is  valid  (impurity,  secondary 
reaction),  Restrictions  on  the  use  of  the  substances  may  not  be  an  efficient  tool  to  reduce 
exposure, unless they include specific measures related to presence in articles. 

For  example:  trichloroethylene  (TCE)  1)  substance  is  assumed  not  to  be  present  in 
construction articles (from notification dossiers or registration dossiers, however,  2) emissions 
from  construction  articles  demonstrate  very  low  release  in  only  some  materials  from  the 
available emission records, 4) monitoring data in indoor air and indoor dust demonstrate that 

180 

 
 
 
 
 
 
 
 
 
presence in EU indoor environments is only rare situations (e.g. in 97 % dwellings in Finland, 
no TCE was found. 

This group of articles is further subdivided, according to extent of exposure, and likelihood of 
CA being an important source of exposure to this CMR or not  

  Group 3A: high likelihood of consumer exposure (widespread exposure) 
  Group 3B: possible likelihood of consumer exposure (CA minor source of exposure) 
  Group 3C: not possible to assess the extent of exposure 

The  detailed  evidence  for  criteria  1-5  for  each  substance  (in  relation  to  Construction  Article) 
categorized into group 3 can be found in Annex 3.  

4.5.4 GROUP 4: CMR SUBSTANCES FOR WHICH THERE IS EVIDENCE OF PRESENCE IN CA AVAILABLE 
INFORMATION  INDICATES  THAT  EXPOSURE  IS  POSSIBLE;  MORE  DATA  NEEDED  FOR 
CONFIRMATION AND TO ASSESS THE EXTENT OF EXPOSURE 

these  CMR  1A/1B  substances 

  For  this  group  of  substances/construction  articles:  there  is  information  supporting  the 
presence  of 
in  construction  articles  (based  on 
notification/registration  dossiers);  and  there  are  some  data  demonstrating  release  in  test 
chambers,  however,  no  data  on  monitoring  in  real  indoor  environments  (air/dust)  were 
found,  and  neither  were  studies  found  relating  the  consumer  exposure  to  emissions  from 
construction articles. More research (monitoring in indoor air/dust and source apportioning) 
is  needed  to  investigate  the  consumer  exposure  to  CMR  substances  arising  from 
construction articles.  

The  detailed  evidence  for  criteria  1-5  for  each  substance  (in  relation  to  Construction  Article) 
categorized into group 4 can be found in Annex 3.  

4.5.5 GROUP 5: CMR SUBSTANCES FOR WHICH THERE IS EVIDENCE OF PRESENCE IN CA FOR WHICH 

NO ASSESSMENT IS POSSIBLE  

For  a  group  of  substances/construction  articles:  the  only  information  found  was  the 
in  construction  articles  (based  on 
assumed  presence  of  these  CMR  substances 
notification/registration  dossiers);  for  these  substances/construction  articles,  there  is  no 
further  evidence  supporting  or  ‘falsifying’  the  consumer  exposure  to  these  substances. 
More research (emission studies, adequate techniques for monitoring in indoor air/dust) is 
needed to investigate the consumer exposure to CMR substances arising from construction 
articles 

o  For  example:  boric  acid,  disodium  tetraborate  anhydrous,  and  magnesium 

nitrate 

The  detailed  evidence  for  criteria  1-5  for  each  substance  (in  relation  to  Construction  Article) 
categorized into group 5 can be found in Annex 3.  

4.5.6 GROUP 6: CMR SUBSTANCES FOR WHICH THERE IS EVIDENCE OF PRESENCE IN CA (>0.1 %) 

WITH INDIRECT EVIDENCE FOR LOW LIKELIHOOD OF CONSUMER EXPOSURE.  

this 

For 
substance-specific 
release/exposure/monitoring  data  are  available  (e.g.  cadmium  oxide);  however,  there  are 

substances/construction  article  pairs,  no 

set  of 

181 

 
 
 
 
 
 
 
 
 
 
monitoring  data  available  for  ‘proxies’  of  these  substances.  For  example,  no  monitoring 
data are available for ‘Cadmium oxide’; however, monitoring data are available for total Cd 
levels  in  dust  (among  which  cadmium  oxide  might  be  one  of  the  species)  –  these 
monitoring  data  indicate  the  presence  of  Cd  in  indoor  dust  (ubiquitously  present  in  EU 
indoor  environments),  and  thus  potentially  the  presence  of  cadmium  oxide  in  dust,  and 
potential consumer exposure.  

However,  studies  identifying  sources  of  metals  in indoor  dust  do  not  indicate  construction 
materials as an important source (other sources, mainly from outdoor origin contribute to 
metal levels in dust); this is the case for nearly all metals present in construction articles. 

o  For  example:  nickel,  cadmium,  cadmium  oxide,  orange  lead,  lead  monoxide, 

lead sulfochromate  

o  Consequently,  restrictions  on  these  substances/article  pairs  when  used  in 
construction  articles  would  probably  not  be  an  efficient  measure  to  reduce 
consumer  exposure  to  these  CMR  substances;  other  actions  (reduction  of 
outdoor  sources,  pollution  sites,  etc.)  would  be  more  effectively  to  reduce 
exposure to these CMR substances  

Two important remarks should be made with regard the uncertainties for exposure assessment 
for this group of substances:  

-  The  absence  of  relationship  between  ‘proxy’  of  substances  and  exposure  was 
extrapolated to absence of relationship between the substance itself (as present in CA) 
and exposure. This extrapolation is prone to uncertainties:  it cannot be excluded that 
the  substance  itself  (e.g.  lead  tetroxide)  provokes  exposure  (assume  lead  tetroxide 
would be present in housedust if analytical techniques to measure lead tetroxide were 
available); however, as the fraction of lead tetroxide in the total lead content of indoor 
dust  samples  might  be  small,  there  is  a  pitfall  that  lead  tetroxide  from  construction 
articles  is  not  visible  enough  in  the  total  content  of  lead  in  housedust;  where  the 
majority of lead fractions (other than lead tetroxide) in housedust does not come from 
construction articles. 
As  a  consequence,  this  assumption  (using  data  for  the  ‘proxy’  instead  of  substance 
itself)  could  lead  to  an  underestimate  of  the  exposure  of  the  substance  released  from 
construction articles. 

- 

In relation with the previous bullet: no strict borderline can be set between group 5 and 
group 6:  the allocation of a substance to either group 6 is based on whether the proxy 
for  substance  (e.g.  proxy:  ‘lead’  for  substance  ‘lead  tetroxide’)  is  an  appropriate 
estimate or not. For example, it was – based on expert judgment – assessed that levels 
of lead in dust is an adequate proxy for lead tetroxide; on the contrary – if lead could 
not  be  considered  as  an  adequate  proxy  for  lead  tetroxide,  one  would  allocate  lead 
tetroxide  into  group  5  (CMR  substances  present  in  CA    for  which  no  assessment  is 
possible) 

The  detailed  evidence  for  criteria  1-5  for  each  substance  (in  relation  to  Construction  Article) 
categorized into group 6 can be found in Annex 3.  

4.5.7 GROUP  7:  CMR  SUBSTANCES  FOR  WHICH  THERE  IS  EVIDENCE  OF  PRESENCE  IN  CA  WITH 

(VERY) LOW LIKELIHOOD OF CONSUMER EXPOSURE  

For  this  group  of  substances/article  pairs,  the  substance  is  assumed  to  be  present 
based  on  notification  and  registration  dossiers  in  levels  >0.1  %;  however,  the 
available  exposure  data  (e.g.  monitoring  data  in  indoor  air  or  dust)  indicate  the 

182 

 
 
 
  
 
 
 
 
 
absence  of  exposure;  therefore,  it  can  be  assumed  that  the  content  does  not 
provoke exposure. 

For  example,  acrylonitrile  was  registered  for  a  use  in  building  and  construction 
articles  (SU  19);  however  in  none  of  the  emission  testing  data  (e.g.  BUMA 
database)  release  of  Acrylonitrile  was  detected  (notwithstanding  that  this 
substances  is  included  in  the  list  of  substances  measured  under  the  prEN  16516 
emission  testing  protocol).  In  addition,  acrylonitrile  was  not  detected  in  any  of  50 
non-smoking  dwellings  in  Montana.  Therefore,  it  is  assumed  that  acrylonitrile 
exposure from construction articles is negligible. 

The  detailed  evidence  for  criteria  1-5  for  each  substance  (in  relation  to  Construction  Article) 
categorized into group 7 can be found in Annex 3.  

4.5.8 CMR  SUBSTANCES  SUBJECT  TO  AUTHORISATION  AND  WITH  NO  AUTHORISED  USES  RELEVANT 

FOR CONSTRUCTON ARTICLES  

  For  several  substance  on  the  authorization  list  identified  as  being  present  in  construction 
articles  (based  on  past  registrations,  notifications)  and,  for  some  of  these:  release  to 
indoor air in test chamber was demonstrated, and supported by indoor air/dust monitoring 
data,  the use of these substances in construction articles produced in the EU will no longer 
be  allowed  after  the  sunset  date  (for  several  substances:  sunset  date  in  2015  or  2016) 
since  no  authorisation  in  the  field  of  construction  articles  was  granted  yet.  It  should  be 
investigated whether this policy action will effectively lead to reduced consumer exposure  

Such CMR substances may be present in any of above mentioned groups of CMR/CA pairs 
and are annotated with an asterisk “*”. For example, BBzP released from flooring materials 
was  categorized  under  group  1  “CMR  substances  present  in  CA  (>0.1%)  with  high 
likelihood of consumer  exposure; widespread exposure” because BBzP was  reported to be 
present in PVC flooring (crit. 1), release in test chambers was demonstrated (crit. 2), BBzP 
was  measured  in  indoor  air  and  dust  (crit.  4),  and  flooring  was  identified  as  important 
source (crit. 5).  However, it is anticipated that after the sunset date, criteria 1, 2, 3 and 5 
will become negative since no authorization for BBzP is granted in the field of construction 
articles.  

This is the case for: lead chromate, tris(2-chloroethyl)phosphate, benzylbutylphthalate, di-
isobutylphthalate, trichloroethylene and dibutylphthalate. 

 4.6 SUMMARY 

Information  gathered  during  task  3  (Chapter  4)  confirmed  the  presence  of  several  CMR 
substances  1A/1B  substances  in  a  number  of  construction  articles.  Experimental  data 
demonstrated  that  some  CMR  substances  are  effectively  released  to  indoor  air,  and/or  are 
potentially released to the skin upon dermal contact.  

Monitoring data of formaldehyde, benzene and phthalates in residential premises confirm that 
these CMR substances are widely present in the indoor environment.  However, other sources 
(e.g. outdoor air, cleaning products, etc.) in addition to construction articles are likely to also 
contribute to these indoor levels, at least for benzene.   

For other CMR substances, (e.g. TCEP, N-methyl-2-pyrrolidone) monitoring data in indoor dust in 
various dwellings have shown that these substances occur only in a small minority of buildings 
in the EU. 

183 

 
 
 
 
 
 
Methods to assess exposure to CMR for the scenario ‘consumer exposure via indoor air during 
article  service  lifetime’  are  well  established  (CEN/TS  16516  emission  test)  and  embedded  in 
regulatory frameworks (e.g. Construction Product Regulation); and results from experimentally 
measured  emission  rates  have  been  demonstrated  to  match  with  indoor  air  levels  in  real 
indoor environments (e.g., Missia et al., 2010).   

However,  methods  for  assessing  the  consumer  exposure  scenario  of  dermal  exposure  upon 
skin contact with construction articles are more prone to uncertainties. These uncertainties are 
due to the defaults taken, and the model approach, in particular the default for layer thickness 
and the extrapolation of released amounts to the contact area. In addition, the behaviour data 
included  in  the  models  may  be  criticised  as  too  conservative  and  unrealistic.  Also, 
experimentally determined migration data to skin is prune to uncertainties of relevant physico-
chemical composition of the extraction media, and the lack of accounting for transfer factors. 
These  limitations  render  it  difficult  to  generate  sound  exposure  estimate  for  dermal  exposure 
to  substances  in  construction  articles.  In  contrast  to  indoor  air  exposure,  dermal  exposure  to 
substances in construction articles is not (yet) embedded in an official standard, e.g. under the 
Construction Product Regulation.  

Besides the two most evident consumer exposure scenarios   (direct releases to the indoor air,  
and  direct  dermal  contact  between  skin  and  construction  articles)  ,  other  indirect  exposure 
scenarios  for  SVOC  substances  in  constructions  have  been  described  in literature  as  well;  for 
example,  release  to  the  dust  phase  and  surfaces,  and  subsequently  oral  and  dermal  contact 
the  dust  phase  and/or  surfaces.    Monitoring  data  of  for  example  SVOC  CMR  substances  (e.g. 
DEHP, TCEP) in dust demonstrate that this is a likely pathway of exposure, however, no widely 
accepted tools to assess this exposure has been agreed upon yet (discussions are ongoing at 
OECD level).   

Data  on  do-it-yourself  exposure  and  professional  exposure  scenarios  were  more  scarce 
compared to article life service  exposure. Professional exposure to substances in construction 
articles (e.g. installers of PVC flooring) is not included in the workers exposure tools reference 
in the REACH guidance.  Exposures for this occupational group is believed to be lower than for 
workers  in  contact  with  industrial  processes  where  contact  with  these  substances  in  products 
and formulations is likely. 

In  order  to  assess  the  likelihood  of  exposure  to  CMR  substances  arising  from  construction 
articles,  5  criteria  have  been  applied  on  each  of  the  identified  cases  from  task  2,  namely  1) 
criterion  1:    presence  of  CMR  in  construction  articles;    criterion  2:  emission  of  CMR  in 
construction articles (from monitoring programs); criterion 3: estimated exposure (modelling), 
taking into account release, article loading,  exchange rate in indoor environments; criterion 4: 
measured  indoor  exposure  (monitoring  Indoor  Air  Quality  (IAQ)  in  buildings);  criterion  5: 
source apportioning supporting that construction articles are main source of indoor exposure . 
Moving from criterion 1 to 5 gives increasing evidence for exposure to CMR 1A/1B substances 
in relation to presence of construction articles.  

Based  on  the  scoring  for  these  5  criteria,  the  different  pairs  of  CA  and  CMR  substances  were 
organized into groups. Pairs of CA/CMR substances belonging to the same group have a similar 
likelihood of consumer exposure to CMR substances present in construction articles.  

As  a  result,  there  was  a  wide  range  in  evidence  for  exposure  to  CMR  1A/1B  substances  in 
relation  to  presence  of  construction  articles:  on  the  one  hand,  for  some  substances  (e.g. 
formaldehyde),  consumer  exposure  has  been  demonstrated  in  several  way  (emission  data, 
monitoring  data  in  indoor  air),  the  exposure  is  ubiquitous  in  the  EU  and  indoor  construction 
articles have been demonstrated as a significant source of indoor exposure. On the other hand, 
for other cases, monitoring data below detection limits in all monitored premises suggest that 
the  substance  does  not  occur  in  indoor  environments,  and  thus  the  possible  presence  of  the 
substance  in  construction  articles  does  not  appear  to  lead  to  consumer  exposure  (e.g. 
acrylonitrile). However, for the majority of the substances, the evidence is less clear: in some 
cases, indications are available that exposure origination from construction articles is probably 
minor; in other cases, no assessment could be made based on the available information, thus 
more monitoring data are needed to make a sound assessment possible.  

184 

 
 
CHAPTER 5  LABORATORY EXPERIMENTS TO DETERMINE THE PRESENCE OF 
CMR COMPOUNDS IN CONSTRUCTION PRODUCTS 

 5.1 LITERATURE REVIEW 

See Chapter 4 

 5.2 LABORATORY EXPERIMENTS 

The  objective  of  task  4  (task  4.2)  was  to  perform  analytical  testing  on  construction  articles 
where CMR data are not readily available.  

After  consultation  with  the  Commission  on  11  September  2015  it  was  decided  to  perform 
analytical  testing  on  8  resilient  floor  covering  materials  and  2  wall  covering  materials, 
purchased  from  the  Belgian  retail  market  (Table  39).  All  the  articles  were  EU-made.  No 
imported PVC floorings or wall papers were readily available in the visited shops. The analytical 
tests performed include content testing (and dermal exposure testing), and indoor air emission 
testing.  

Extra information (out of the scope of the current project) was provided on the product labels 
concerning non-CMR compounds and the relation to the Belgian, French and German product 
emission  legislations  (Table  39),  such  as  emitted  (non  CMR)  VOC  compounds  causing  non-
compliance with certain legislations.  

Used  methodologies  are  described  in  the  paragraphs  below,  and  a  list  with  the  target  CMR 
compounds is given in Table 40, with the CAS number, the type of compound (VOC, SVOC or 
VVOC) and the instrumental techniques used in the contents and emission experiments. 

Table 39: Sample description 

Sample 
code 

Sample  
description 

Information from technical data sheet 

Product information 

Labelling* 

20152190  PVC flooring 

EN ISO 26986 

20152191  PVC flooring 

EN ISO 26986 

20152192  PVC flooring 

EN ISO 10874 

Phthalate free 
BIAQ < 100 µg/m³ 
A+ 
Phthalate free 
BIAQ < 100 µg/m³ 
A+ 
EN717 E1 

20152193  PVC flooring 

EN ISO 10874 

EN717 E1 

20152194  wall paper 

non-woven backing 

20152195  wall paper 

20152250  PVC flooring 

Non-woven backing + top 
layer: water based ink 
EN ISO 10874 
EN 14041 

20152251  PVC flooring 

EN ISO 10874 
EN 14041 

20152252  PVC flooring 

EN ISO 10874 

PEFC certified paper 
or FSC certified non-woven 
A+ 

Floorscore 
Ü-mark 
A+ 
Phthalate free 
BIAQ < 100 µg/m³ 
Ü-mark 
EN 717 E1 

185 

 
 
 
20152253  PVC flooring 

EN ISO 26986 
EN ISO 10874 

Phthalate free 
BIAQ < 100 µg/m³ 
A+ 

*: 

BIAQ < 100 µg/m³: Better Indoor air quality, YVOC < 100 µg/m³ after 28 days 
A+: French decree of emission labelling 
EN 717 E1: formaldehyde emission after 28 days < 120 µg/m³  
Ü-mark: product complies with AgBB health-related evaluation procedure for VOC from building products 

Table 40: Overview CMR compounds 

Compounds 

CAS no. 

Type* 

Content 

Emission 

Acrylonitrile 
Allyl glycidyl ether 
Benzene 
2,2'-Bioxirane 
Bis (chloromethyl) ether 
Resorcinol diglycidyl ether 
Epichlorhydrine 
(R)-(-)-Epichlorohydrine 
Benzyl chloride 
1,2-Dibromo-3-
chloropropane 
1,2-Dibromoethane 
1,4-Dichlorobut-2-ene 
Ethylene dichloride 
1,3-Dichloro-2-propanol 
1,3-Dichloropropene, 
isomers 

107-13-1 
106-92-3 
71-43-2 
1464-53-5 
542-88-1 
101-90-6 
106-89-8 
51594-55-9 
100-44-7 
96-12-8 

106-93-4 
602-073-00 
107-06-2 
96-23-1 
10061-02-5 
and 
10061-02-6 

79-46-9 
924-16-3 
55-18-5 
621-64-7 
601-77-4 
612-64-6 
1116-54-7 

Vinylcyclohexane diepoxide  106-87-6 
680-31-9 
Hexamethylphosphoric 
triamide 
2-Nitropropane 
N-Nitrosodibutylamine 
N-Nitrosodiethylamine 
Nitrosodipropylamine 
N-Nitrosodiisopropylamine 
N-Ethyl-N-nitrosoaniline 
2,2'-
(Nitrosoimino)bisethanol 
N-Methyl-N-nitroso-
ethylamine 
N-Nitrosomorpholine 
N-Nitrosopiperidine 
N-Nitrosopyrrolidine 
2-Nitrotoluene 
Phenyl glycidyl ether 
5-Allyl-1,3-benzodioxole 
Styrene oxide 
Sulfallate 
2,3,4-Trichlorobut-1-ene 
Trichloroethylene 

59-89-2 
100-75-4 
930-55-2 
88-72-2 
122-60-1 
94-59-7 
96-09-3 
95-06-7 
2431-50-7 
79-01-6 

10595-95-6 

186 

VOC 
VOC 
VOC 
VOC 
VOC 
VOC 
VOC 
VOC 
VOC 
VOC 

VOC 
VOC 
VOC 
VOC 
VOC 

VOC 
VOC 

VOC 
VOC 
VOC 
VOC 
VOC 
VOC 
VOC 

VOC 

VOC 
VOC 
VOC 
VOC 
VOC 
VOC 
VOC 
VOC 
VOC 
VOC 

SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 

SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 

TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 

TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 

SE-GC-MS 
SE-GC-MS 

TD-GC-MS 
TD-GC-MS 

SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 

TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 

SE-GC-MS 

TD-GC-MS 

SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 

TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 

 
 
 
 
 
Compounds 

CAS no. 

Type* 

Content 

Emission 

SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 

SE-GC-MS 

SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
SE-GC-MS 
LC-MS 
LC-MS 
LC-MS 
LC-MS 
LC-MS 
LC-MS 
LC-MS 
LC-MS 
LC-MS 
LC-MS 

SVOC 

117-81-7 

110-71-4 
110-80-5 
111-15-9 
115-96-8 

VOC 
VOC 
VVOC 
SVOC 
SVOC 
SVOC 
VOC 
VOC 
VOC 
SVOC 

96-18-4 
1,2,3-Trichloropropane 
68-12-2 
Dimethyl formamide 
75-21-8 
Ethylene oxide 
84-69-5 
Diisobutylphthalate (DIBP) 
Dibutylphthalate (DBP) 
84-74-2 
Benzylbutylphthalate (BBP)  85-68-7 
1,2-Dimethoxyethane 
2-Ethoxyethanol 
2-Ethoxy-ethyl acetate 
Tris(2-
chloroethyl)phosphate 
(TCEP) 
Bis(2-ethylhexyl) phthalate 
(DEHP) 
Chloroprene 
N,N-dimethyl acetamide 
Dipenthyl phthalate (DPP) 
N-methyl-2-pyrrolidone 
Trixylyl phosphate 
1,2-Dimethylhydrazine 
Acrylamide 
o-Toluidine 
o-Anisidine 
4-Chloroaniline 
Quinoline 
2,4,6-Trimethylaniline 
2-Methoxy-5-methylaniline 
4-Chloro-2-methylaniline 
4,4-Methylene-bis-2-
methylaniline 
Bis(2-chloroethyl) sulfide 
Dimethylcarbamoyl chloride  79-44-7 
Methyl azoxy methyl 
acetate 
N-methylbis(2-
chloroethyl)amine 
Morpholine-4-carbonyl 
chloride 
1,3-Propansulton 
4-Chlorobenzotrichloride 
Tetranitromethane 
Benzotrichloride 
Urethane 
Formaldehyde 
*: according to prEN 16516 
SE-GC-MS: solvent extraction – gas chromatography – mass spectrometer 
TD-GC-MS: thermal desorption – gas chromatography – mass spectrometer 
LC-DAD: liquid chromatography – diode array detection 

126-99-8 
127-19-5 
131-18-0 
872-50-4 
25155-23-1 
540-73-8 
79-06-1 
95-53-4 
90-04-0 
106-47-8 
91-22-5 
137-17-7 
120-71-8 
95-69-2 
838-88-0 

VOC 
VOC 
SVOC 
VOC 
SVOC 
VOC 
VOC 
VOC 
VOC 
VOC 
VOC 
VOC 
VOC 
VOC 
VOC 

1120-71-4 
5216-25-1 
509-14-8 
98-07-7 
51-79-6 
50-00-0 

VOC 
VOC 
VOC 
VOC 
VOC 
VVOC 

VOC 
VOC 
VOC 

15159-40-7 

- 
- 
- 
- 
- 
- 

505-60-2 

592-62-1 

51-75-2 

- 
- 
- 

VOC 

VOC 

- 

- 

TD-GC-MS 
TD-GC-MS 
SE-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 

TD-GC-MS 

TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 

TD-GC-MS 
TD-GC-MS 
TD-GC-MS 

TD-GC-MS 

TD-GC-MS 

TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
TD-GC-MS 
LC-DAD 

187 

 
 
 
 5.3 METHOD DESCRIPTION CONTENT TESTING 

Content testing can be divided into 4 subtasks: 

1.  Content screening with SE-GC-MS: Samples are subjected to an appropriate extraction 
technique;  the  organic  compounds  are  collected  in  an  organic  solvent  by  liquid-liquid 
extraction  with  ethyl-acetate.  This  extraction  will  extract  the  apolar  to  semi-polar 
compounds. The obtained extract is injected into a gas chromatograph equipped with a 
mass  spectrometric  detector.  The  recording  is  done  in  full  scanning  electron  impact 
mode. The identification is done by comparing recorded mass spectra with existing MS 
libraries of organic compounds. 

2.  Headspace screening with SE-GC-MS: Headspace testing is conducted by measuring the 
VOC content in the vapour overlying a liquid or solid. Headspace gas chromatography is 
most  suited  to  the  analysis  of  low  molecular  weight  compounds  that  can  be  efficiently 
partitioned  into  the  headspace  gas  volume  from  the  liquid  or  solid  matrix  sample. 
Higher  boiling  semi-volatiles  are  not  detectable  with  this  technique  due  to  their  low 
partition  in  the  headspace  volume.  The  obtained  headspace  extract  is  injected  into  a 
gas chromatograph equipped with a mass spectrometric detector. The recording is done 
in full scanning electron impact mode. The identification is done by comparing recorded 
mass spectra with existing MS libraries of organic compounds. 

3.  Quantification  with  LC-MS/MS:  Many  previously  used  methods  for  primary  aromatic 
amines (PAA) analysis lack robustness,  selectivity and sensitivity, and require lengthy, 
costly,  and  time-consuming  pre-treatments  (derivatization,  SPE).  This  application  note 
that we used, describes an accurate, fast, and  robust alternative method for the  rapid 
analysis of PAAs, using the ACQUITY UPLC H-Class System coupled with the XEVO-TQS-
Detector (mass spectrometer) 

4.  Migration  of  substances  from  the  samples  to  artificial  sweat:  The  objective  of  the 
migration analyses was to investigate exposure when using PVC-flooring and wall paper 
whereas  the  quantitative  analyses  detected  the  content  of  the  selected  phthalates. 
During  the  migration  analyses,  the  products  were  in  contact  with  artificial  sweat  that 
subsequently was extracted and analysed for the phthalates (leachability).  

The  methodology  used  in  the  4  different  approaches  for  content  testing  is  described  in  the 
following paragraphs. 

5.3.1 CONTENT SCREENING WITH SE-GC-MS 

It  was  decided  to  use  ethylacetate  (EtoAc)  as  extraction  solvent.  From  the  homogenized 
samples 0.1 gram was used and 10 gram of EtoAc was added to the sample. The samples were 
placed  in  a  sonication  bath  and  were  sonicated  for  1  hour.  Afterwards  the  samples  were 
allowed to settle down. 1 mL of the upper layer was taken and 50 µL of internal standard (PCB 
167  or  internal  code  MIE-OR-PCB167-003)  was  added,  to  obtain  a  final  concentration  of 
985.83 ng/µl. 

The  gas  chromatography  (GC)  –  mass  spectrometry  (MS)  analysis  was  conducted  in  the 
scanning  (SCN)  mode  on  an  GC  (Trace  GC,  Thermo  Fisher  Scientific)  directly  coupled  to  a 
mass selective detector (Trace DSQ, Thermo Fisher Scientific). The GC column was a DB-XLB 
column with a length of 30 m, an internal diameter of 0.25 mm, and a film thickness of 0.25 
μm.  Helium  was  used  as  the  carrier  gas  (linear  velocity  of  1mL/min).  A  total  of  1  μL  was 
injected  in  splitless.  The  oven  temperature  program  was  as  follows:  40°C  (0  min)  and 
10°C/min  to  320°C  (40  min).  The  electron  energy  was  set  at  70  eV,  and  the  ion  source 

188 

 
 
 
 
 
 
 
 
temperature  was  set  at  250°C.  An  internal  standard  PCB  167  (area  and  concentration)  was 
used for a semi-quantification of the CMR compounds. 

5.3.2 HEADSPACE SCREENING WITH SE-GC-MS 

For  this  method  it  was  decided  to  use  methanol  (MeOH)  as  extraction  solvent.  From  the 
homogenized samples 0.1 gram was used and 10 gram of MeOH was added to the sample. The 
samples  were  placed  in  a  sonication  bath  and  were  sonicated  for  1  hour  and  afterwards  the 
samples  were  shaken  for  1  hour.  The  samples  were  centrifuged  at  4000  rpm  for  10  minutes 
and 0.5 gram of the upper layer was transferred to a headspace vial. This vial was filled with 
1.5  g  sodium  chloride  and  4.5  g  of  SPA  water.  To  this  mixture  an  internal  standard  mix, 
containing  D6-benzene,  D4  1.2-chloroethane,  D16-heptane,  D8-toluene,  D10  ethylbenzene, 
dibuthylether  and  D4  1.4  dichlorobenzene  (final  conc.  around  1.5  ng/µL),  was  added.  Before 
injection in the GC the vial was heated at 70°C during 30 minutes. 

The  gas  chromatography  (GC)–mass  spectrometry  (MS)  analysis  was  conducted  in  the 
scanning  (SCN)  mode  on  an  HS  (Agilent  G1888  Headspace  sampler  -  GC  (HP  6890)  directly 
coupled to a mass selective detector (HP 5973). The GC column was a DB-VOC column with a 
length of 30 m, an internal diameter of 0.20 mm, and a film thickness of 1.12 μm. Helium was 
used as the carrier gas (linear velocity of 1mL/min). A total of 1 μL was injected splitless. The 
oven temperature program was as follows: 35°C (0 min) and 5°C/min to 170°C (30 min). The 
electron  energy  was  set  at  70  eV,  and  the  ion  source  temperature  was  set  at  230°C.  An 
internal  standard  mix  (area  and  concentration)  was  used  for  a  semi-quantification  of  the 
compounds of interest. 

189 

 
 
 
 
5.3.3 QUANTIFICATION WITH LC-MS/MS 

From  the  homogenized  samples  0.5  gram  was  taken  and  10  mL  of  methanol  (MeOH)  was 
added for extraction of the compounds of interest. For the procedural blank only methanol was 
used. The samples were sonicated for 30 minutes in a sonication bath. 1 mL of the upper layer 
(MeOH) was taken and centrifuged at 10000 rpm for 10 min. The upper layer was transferred 
to a LC-vial before measurements with LC-MS/MS.  

For  quantification  we  used  standards  (Table  41)  which  were  accurately  weighed  on  an 
analytical  scale  balance  and  dissolved  in  acetonitrile  to  prepare  stock  solutions.  The  stock 
solutions  of  the  respective  individual  compounds  are  diluted  and  combined  to  obtain  the 
following calibration solutions; 0.05 ng/mL, 5 ng/mL and 500 ng/mL. 

Table 41: Calibration standards used in the LC-MS/MS content analysis 

Compounds LC-MS/MS 

Lab code 

Concentration  
stock solution 
(µg/mL) 

1 

2 

3 

4 

5 

6 

7 

8 

9 

1,2-Dimethylhydrazine 
dihydrochloride 
Acrylamide  

MIE-OR-1,2-Dimethylhydrazine 
dihydrochloride-001 
MIE-OR-Acrylamide-001 

o-Toluidine 

o-Anisidine 

4-Chloroaniline 

Quinoline 

MIE-OR-o-Toluidine-001 

MIE-OR-o-Anisidine-001 

MIE-OR-4-chloroaniline-001 

MIE-OR-Quinoline-001 

2,4,6-Trimethylaniline 

MIE-OR-2,4,6-Trimethylaniline-001 

1462 

1560 

1906 

2143 

1209 

2628 

2195 

2-Methoxy-5-methylaniline 

MIE-OR-2-Methoxy-5-methylaniline-001 

1519 

4-Chloro-2-methylaniline 

MIE-OR-4-chloro-2-methylaniline-001 

1265 

10  Hexamethylphosphoramide 

MIE-OR-Hexamethylphosphoramide-001  1457 

11  4,4-Methylene-bis(2-
methylaniline) 

MIE-OR-4,4-Methylene-bis-(2-
methylaniline)-001 

1335 

The  instrumental  analysis  was  performed  by  means  of  ultra  high  performance  liquid 
chromatography  (UHPLC)-tandem  mass  spectrometer  using  a  Waters  H-class  Acquity  UPLC 
system  (Waters,  Milford,  MA,  USA).  The  UHPLC  system  consisted  of  an  Acquity  quaternary 
solvent  manager,  an  Acquity  sample  manager  and  an  Acquity  column  heater  manager.  The 
UHPLC  system  was  coupled  to  a  Waters  Xevo  TQ-S  tandem  mass  spectrometer,  which  was 
operated  in  the  positive  electrospray  ionization  mode  (ESI+).  These  measurements  were 
performed in MRM mode. The compounds were separated on a Waters Acquity HSS SB Column 
(2.1  mm  X  100  mm;  1.8  μm).  The  column  temperature  was  kept  at  40°C  and  an  injection 
volume  of  10  μl  was  used.  Optimum  separation  was  obtained  with  a  binary  mobile  phase 
constituted  of  milli-q-water  (solvent  A)  and  methanol  (solvent  B).  The  gradient  elution 
program  was:  0  min:  95%  A;  0-10  min:  95-0%  A;  10-12  min:  0%  A;  12-15  min:  95%  A 
(return  to  initial  conditions  and  equilibration  of  the  column).  The  parameters  of  the  mass 
spectrometer  were  as  follows:  electrospray  source  block  and  desolvation  temperature  150  °C 
and 350°C, respectively; argon collision gas flow 0.25 mL/min; cone and desolvation nitrogen 
gas  flow  150  L/h  and  800  L/h,  respectively.  A  capillary  voltage  of  3.0  kV  was  used  for  all 
compounds. 

190 

 
 
 
 
 
 
 
5.3.4 MIGRATION OF SUBSTANCES FROM ARTICLES TO ARTIFICIAL SWEAT– METHOD DESCRIPTION 

Transfer combined with migration at long term dermal exposure was  simulated by a one
step 
extraction  at  shaking  conditions,  pH  5.5  and  37°C  with  artificial  sweat  prepared  according  to 
E04  (ISO,  2013).  This  ISO  standard  also  considers  artificial  sweat  at  pH  8. 
DIN  EN  ISO  105
values  were 
Since  no  significant  differences  in  migration/extraction  efficiency  at  these  pH
expected for the substances of interest, the test was only performed at pH 5.5. The extractions 
were  performed  at  37°C  under  shaking  conditions  in  a  warm  waterbath  (see  Figure  5).  The 
shaking was performed with a shaking frequency of 170 rpm. 

‐

‐

‐

Figure 5: Extraction of the samples at 37°C in a warm waterbath (shaking –dynamic) 

All the glasswork was heated for 24h at 450°C and precleaned with n-hexane. The PVC flooring 
sample and the wall papers were cut out with a cleaned scissor into pieces of the nominal size 
shown in Table 42 and extracted with 20 ml artificial sweat.  

Table 42: Pieces of the samples used for extraction with artificial sweat 

Sample 
code 

Sample code 

Sample  Weight (g) 

Total area 
(cm2) 

Cut pieces 
(cm2) 

20152190 

151007-0040 

20152191 

151007-0041 

20152192 

151007-0042 

PVC 
flooring 
PVC 
flooring 
PVC 
flooring 

5.69 

10x5 

6.1 

10x5 

1x1 

1x1 

5.78 

10x3.5 

1x1.2 

20152194 

151007-0044  wall paper  4.95 

20152250 

151007-0046 

20152253 

151007-0049 

PVC 
flooring 
PVC 
flooring 

4.88 

20x10 

1x12 

x1x 

1x1 

5.35 

3.5x10 

1x1.2 

Volume 
artificial 
sweat 
(mL) 

20 

20 

20 

20 

20 

20 

After addition of the test piece we draw a sample at time 24 h. The use of this sampling time 
gave us the opportunity to estimate long dermal exposure. Also 3 blank procedures were taken 
into  account  (to  check  if  there  was  a  possible  contamination  present).  The  samples  were 
extracted two times with n-hexane (2x15mL) and 25 µL of the internal standard PCB-167 was 

191 

 
 
 
 
 
added. After the extraction (Figure 6), 30 mL of the samples were evaporated with nitrogen to 
dryness. The dry extracts were redissolved in 750 µL n-hexane before analysis with GC-MS. 

Figure 6: extraction of the artificial sweat with n-hexane 

The  gas  chromatography  (GC)–mass  spectrometry  (MS)  analysis  was  conducted  in  the 
scanning  (SCN)  mode  on  an  GC  (Trace  GC,  Thermo  Fisher  Scientific)  directly  coupled  to  a 
mass selective detector (Trace DSQ, Thermo Fisher Scientific). The GC column was a DB-XLB 
column with a length of 30 m, an internal diameter of 0.25 mm, and a film thickness of 0.25 
μm.  Helium  was  used  as  the  carrier  gas  (linear  velocity  of  1mL/min).  A  total  of  1  μL  was 
injected splitless. The oven temperature program was as follows: 40°C (0 min) and 10°C/min 
to 320°C (40 min). The electron energy was set at 70 eV, and the ion source temperature was 
set  at  250°C.  An  internal  standard  PCB  167  (area  and  concentration)  was  used  for  a  semi-
quantification of the compounds. 

 5.4 METHOD DESCRIPTION EMISSION EXPERIMENTS 

The  product  emission  tests  were  performed  according  to  the  horizontal  test  standard  prEN 
16516  (2014)  “Construction  products  –  assessment  of  release  of  dangerous  substances  – 
determination  of  emissions  into  indoor  air”.  Dynamic  chamber  testing  involves  the 
determination  of  the  emissions  from  indoor  materials  and  products  under  controlled 
environmental conditions, and the results can be used to conduct exposure assessments. 

This  European  Standard  was  developed  under  the  remit  of  Mandate  M/366  "Development  of 
horizontal standardized assessment methods for harmonised approaches relating to dangerous 
substances  under  the  Construction  Products  Regulation  (CPR)"  addressing  the  preparation  of 
horizontal  measurement/test  methods  for  the  determination  of  emission  of  regulated 
dangerous substances from construction articles into indoor air.  

This  European  Standard  specifies  the  horizontal  reference  method  for  testing  the  emission 
(release)  of  dangerous  substances  from  construction  products  into  indoor  air.  This  method 
uses  a  test  chamber  in  which  emissions  are  generated  under  conditions  which  are  kept 
constant during the test (temperature, relative humidity and air change rate). These conditions 
are selected so that the test results can be expressed in terms of concentrations of dangerous 
substances in the air of the reference room (see Clause 7 and Clause 9 of the standard). It is 
to be noted that the test chamber is defined in terms of performance requirements.  

192 

 
 
 
 
 
This  responds  to  the  requirement  of  Mandate  M/366  for  a  horizontal  approach  while 
maintaining  sufficient  flexibility  on  chamber  dimensions  to  ensure  representative  samples  of 
different  materials  can  be  accommodated  (see  Clause  5  of  the  standard).  Clause  8  of  this 
European Standard specifies how emitted regulated dangerous substances should be analysed. 

For some compounds such as certain CMR SVOCs the prEN 16516 method was complemented 
with  other  air  sampling  methods  such  as  the  new  innovative  air  sampling  method  based  on 
PDMS/TENAX developed by VITO100. 

The air sampling times will be selected to reflect the consumer exposure during the installation 
or lifetime of the article. 

Sampling after 3 days was done to assess the exposure during installation. Sampling after 28 
days was done to assess the lifetime exposure in accordance with the JRC report N°27 (2012) 
“Harmonisation framework for indoor products labelling schemes in the EU”. 

5.4.1 EMISSION TEST CHAMBERS 

Test chambers and test conditions 

Preliminary  screening  experiments  were  performed  with  the  microchamber  (µchamber) 
technique conform ASTM 7706-11 and following the GUT procedure for floor coverings. Round 
test samples of 45 mm diameter were prepared and positioned at the bottom of the chambers 
(Figure 7). 

Figure 7: µchamber setup 

Sampling  was  done  after  15  minutes  of  equilibration  for  a  duration  of  60  minutes.  The 
µchamber was operated in splitless mode with a supply flow (pure air) of 100 ml/min at room 
temperature. 

For  the  determination  of  vapour  phase  organic  compounds  released  from  construction 
materials  into  indoor  air  8  out  of  10  samples  were  tested  in  environmental  test  chambers 
(stainless steel) larger than 20 l conform to prEN 16516.  

100  Atmospheric  Environment  79  (2013)  780-786  “Optimization  steps  of  an  innovative  air 
sampling method for semi volatile organic compounds” 

193 

 
 
 
 
 
                                           
 
The other 2 samples were tested in a test emission cell (FLEC, conform ISO 16000-10). FLEC is 
an  alternative  technique  listed  in  annex  B  of  prEn  16516.  The  correlation  and  comparability 
between FLEC method and the reference test chamber method is demonstrated for these type 
of dry planar materials101,102. 

An overview of the test conditions is shown in Table 43. 

Table 43: Overview of the emission test chamber conditions 

Sample 
code 

Sample  
description 

Test chamber 

Type 

Volume 
(l) 

Temp. 

°C 

RH 

% 

ACR 
h-1 

20152190  PVC flooring 
20152191  PVC flooring 
20152192  PVC flooring 
20152193  PVC flooring 
20152194  wall paper 
20152195  wall paper 
20152250  PVC flooring 
20152251  PVC flooring 
20152252  PVC flooring 
20152253  PVC flooring 

CLR 1 

CLR 2 

Ch 1 

Ch 2 

CLR 7 

CLR 8 

CLR 3 

110 

110 

500 

500 

110 

110 

110 

FLEC 318 

0.035 

CLR 4 

110 

FLEC 251 

0.035 

23 

23 

23 

23 

23 

23 

23 

23 

23 

23 

50 

50 

50 

50 

50 

50 

50 

50 

50 

50 

0.5 

0.5 

0.5 

0.5 

0.5 

0.5 

0.5 

171 

0.5 

171 

Pictures of the different kinds of test chambers and some of the samples are shown below. 

101  Emission  cells  and  comparison  to  small  chambers for  materials  emission  testing, Innenraumluft    65  (2005) No.3, 
März, P. wolkoff et al 
102  Final  report  “Horizontal  evaluation  method  fort  he  implementation  of  the  Construction  Products  Directive 
(HEMICPD)”, Belsp D/2010/1191/12, M. Lor et al 

194 

 
 
 
 
 
 
                                           
 
Figure 8:110l test chamber system (left) and emission test sample (right) 

Figure 9:500l test chamber system (left) and emission test sample (right) 

The  FLEC  cell  is  placed  onto  the  (flat)  test  sample  and  is  designed  in  such  a  way  that  the 
surface of the sample is a part of the test cell. 

Figure 10: emission test cell and sample 

195 

 
 
 
 
 
 
 
Determination of VVOC, VOC and SVOC in test chamber air 

At the designated days the outgoing test chamber air is sampled on a multitude of sorbents to 
be  able  to  fully  cover  the  compound  range  from  VVOC  to  VOC  to  SVOC.  Some  sorbents  are 
compound-specific, others capture a wide range of organic compounds.  

By using a calibrated pump the outgoing test chamber air passes through the sorbent tube at a 
certain  air  flow  rate.  This  number  multiplied  with  the  sampling  time  gives  the  volume  of  air 
which later on can be recalculated to concentrations with knowledge of the analytical result. 

A comprehensive overview is shown in Table 44. 

Table  44:  Overview  of  the  emission  test  chamber  sampling  sorbents  and  corresponding 
analytical method 

Type 

Sorbent 

Compound 

Based on 

Method 

AC 

VVOC 

DNPH 

Ct202 

VOC 

ethylene 
oxide 

formaldehyde 

benzene 

Tenax 

all VOC 

PDMS/Tenax 

phthalates 
phosphates 

Vito method 

  SE-GC-MS 

prEN 16516 
ISO 16000-3 
prEN 16516 
ISO 16017 

prEN 16516 
ISO 16000-6 

UHPLC-DAD 

  TD-GC-MS 

  TD-GC-MS 

Vito method 

  TD-GC-MS 

SVOC 

XAD2 

phosphates 

ISO 16000-31 

  SE-GC-MS 

Tenax/glass 
wool 

phthalates 

ISO 16000-33 

  TD-GC-MS 

AC: active charcoal 
DNPH: dinitrophenylhydrazine 
Ct202: Carbotrap 202 
UHPLC: ultra high pressure liquid chromatography 
PDMS: polydimethylsiloxane 

For  most  VOCs  in  the  indoor  air  and  test  chamber  air  standards  the  designated  sorbent  is 
Tenax. However, for benzene it’s advised to use Carbotrap for the Tenax sorbent is known for 
showing blank values of benzene. 

The different analytical methods are described in the following paragraph. 

196 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
5.4.2 ANALYTICAL METHODS 

During  sampling  the  compounds  are  adsorbed  onto  the  sample.  In  order  to  analyse  the 
samples, the adsorbed compounds should be desorbed from the sample, and depending on the 
method this can be done in 2 ways, with solvent desorption or with thermal desorption. With 
the  former  one,  a  solvent  is  added  to  the  sample  so  that  the  compounds  will  transfer  to  the 
solvent  which  subsequently  is  analysed.  With  thermal  desorption,  the  sample  is  exposed  to 
elevated temperatures causing the compounds to desorb. 

The different analytical methods  are described  according to the type of vapour phase  organic 
compound. 

VVOC 

ethylene oxide 

The active charcoal is gravimetrically desorbed with 10 ml carbon disulfide and the mixture is 
mechanically  shaken  for  30  minutes  to  eluate  the  sorbed  compounds.  The  extracts  are 
transferred  to  the  autosampler  recipients.  1  µl  is  injected  at  230  °C,  a  split  ratio  of  5:1  is 
maintained,  and  transferred  to  a  Rtx-502.2  GC  column  (60m;  0.32  mm  id;  1.8  µm)  with  an 
oven program 35°C (3 min.), to 210°C at 50°C/min resulting in a total run of 12.5 min. 

formaldehyde 

The  Waters  DNPH  cartridges  are  desorbed  with  3  ml  of  acetonitrile  over  3  minutes  to  ensure 
the elution of the aldehyde hydrazons. The column Phenyl 1.7µm, 2.1 x 100 mm is equipped 
with a pre column and a mobile phase consisting of a gradient elution of 10% THF in water and 
acetonitrile.  Oven  temperature  is  40°C,  and  the  hydrazons  are  detected  with  a  photodiode 
array detector at 360 nm. 

VOC 

The  Tenax  and  Carbotrap  202  samples  have  been  analysed  according  to  ISO  16000-6,  ISO 
16017 and prEN 16516.  

Desorption is done in a Markes Ultra autosampler at 300 °C during 10 min with a split ratio of 
2:1 and the released compounds are captured on a cold trap at 10°C (High boilers trap Markes 
Unity-1  for  VOC  range  C6  -  C40).  At  the  maximum  heating  rate  of  50  °C/min  the  cold  trap  is 
then flash heated up to 350°C, held for 5 min, and the compounds are transferred to the GC 
column (Rxi-5 Sil MS, 60 m, 0.25 mm ID, 1.0 µm; oven program 50 °C (5 min), 9 °C/min to 
275 °C, 275 °C (15 min) resulting in a total run of 45 min) and detected with an Agilent MS 
using a scanning range of m/e between 35 and 250. 

SVOC 
The  PDMS/Tenax100  method  can  be  considered  as  un  upgrade  from  the  ISO  16000-33 
standard, it’s not a reference method but a new method which is validated for a whole range of 
SVOCs  including  phosphates  and  phthalates,  and  published  in  a  peer-reviewed  journal.  The 
reference method for phosphates includes sampling on XAD-2, solvent desorption and GC-MS 
analysis (ISO 16000-31). 

All the analyses were performed on a TD-GC-MS system, which consisted of a TD100 Thermal 
desorber (TD) equipped with a multi-tube autosampler (Markes International Ltd.) and coupled 
to a gas chromatograph Thermo Trace GC Ultra and a mass selective detector Thermo DSQII 
(Thermo  Fisher  Scientific  Inc.).  Thermal  desorption  of  the  sampling  tubes  was  carried  out  at 
300°C  with  a  flow  rate  of  20  ml  min-1  for  12  min,  followed  by  cold  trap  (10°C)  focusing. 
Thermal  desorber  system  control  was  performed  using  Thermal  Desorber  System  Control 
Program  version  4.4.1  (Markes  International  Ltd.).  The  GC-MS  system  control,  data  logging 
and data handling were performed using Xcalibur 2.0 software (Thermo Fisher Scientific Inc.).  

197 

 
 
 
 
 
The chromatographic separation was conducted on Rxi-5Sil MS capillary column (Restek) 30 m 
x  0,25  mm  i.d.  x  0,25  µm  film  thickness.  The  oven  program  was  the  following:  the  oven 
temperature started at 100 °C for 5 min, ramped at 25 °C min-1 to 255 °C and finally ramped 
at 5 °C min-1 to 300 °C. 

 5.5 RESULTS OF THE LABORATORY EXPERIMENTS 

5.5.1 CONTENT SCREENING RESULTS WITH GC-MS 

The extracted samples (1 mL) were brought into a GC-vial and 50 µL of the internal standard 
(PCB  167)  with  a  concentration  of  985.83  ng/µl  was  added  for  semi-quantification  of  the 
content  in  the  samples.  The  samples  were  screened  and  a  NIST  2.0  library  was  used  for  the 
identification  of  the  present  compounds  in  the  samples.  The  CAS  number  of  the  compounds 
was  used  for  searching  the  NIST  library  (spectrum)  and  the  results  of  the  content  screening 
(spectrum) were compared with the NIST library.  

No CMR compounds were detected in this screening experiment (>0.1%). 

The  main  groups  of  components  are  clusters  of  benzoic  or  cyclohexane  dicarboxylic  acid  and 
clusters  of  cyclohexane  dicarboxylic  acid  alkylesters  are  present  in  all  products  except 
20152195  and  20152251.  Also  some  abundant  masses  of  a  non  CMR  phthalate  (m/z  149, 
retention  time  19.95)  were  present  at  ~2%  in  the  samples  of  the  floor  coverings  20152190 
and  20152191.  A  representative  chromatogram  of  a  PVC  flooring  (20152190)  is  shown  in 
Figure 11. 

NL:
4.70E8
TIC  MS 
15100803

Figure 11: content GC-MS chromatogram of sample 20152190 

RT: 0.00 - 39.02

100

19.95

e
c
n
a
d
n
u
b
A
e
v
i
t

l

a
e
R

95

90

85

80

75

70

65

60

55

50

45

40

35

30

25

20

15

10

5

0

25.57

25.77

25.45

25.21

25.01

25.96

23.40

17.44

17.24

26.15

4.26

5.03

7.60 10.08

13.02

16.62

22.71

27.02 29.73

32.22 35.13

38.24

0

5

10

15

20

Time (min)

25

30

35

5.5.2 CONTENT HEADSPACE SCREENING RESULTS WITH GC-MS 

This  technique  focused  solely  on  the  presence  of  CMR  compounds.  The  results  confirm  the 
other screening technique findings, so no CMR compounds are present (>0.1%). 

198 

 
 
 
 
 
 
5.5.3 CONTENT RESULTS (QUANTITATIVE) WITH LC-MS/MS 

After  extraction  1  mL  of  the  centrifuged  samples  was  brought  in  a  LC-vial  and  10  µl  was 
injected to the LC-MS/MS. The limit of quantification (LOQ) was set at 0.0001% based on the 
signal/noise ratio of 3, calculated from the lowest standard in the calibration curve (0.05 ppb).  

None of the compounds from the CMR list are present at concentrations > 0.0001%. 

A chromatogram of a calibration standard of 5 ppb (Figure 12) and a chromatogram of a PVC 
flooring (Figure 13) and a wall paper (Figure 14) are shown below. 

Figure 12: LC-MS/MS chromatogram of a 5 ppb standard of the compounds of the calibration 
curve  

CMR mix standaard_5 ppb
CMR_20151015a03

7.91

11: MRM of 2 Channels ES+ 
TIC
5.50e7

%

0

CMR_20151015a03

%

0

CMR_20151015a03

100

%

0

CMR_20151015a03

%

0

CMR_20151015a03

%

0

0.37

CMR_20151015a03

%

0

CMR_20151015a03

100

%

0

CMR_20151015a03

%

0

CMR_20151015a03

100

%

0

CMR_20151015a03

%

0

CMR_20151015a03

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

5.50

6.00

6.50

7.00

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

6.27

10: MRM of 3 Channels ES+ 
TIC (Hexamethylphosphoramide)
5.53e7

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

5.50

6.00

6.50

7.00

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

6.82

9: MRM of 2 Channels ES+ 
TIC (4-Chloro-2-methylaniline)
2.26e6

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

5.50

6.00

6.50

7.00

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

6.30

8: MRM of 2 Channels ES+ 
TIC (2-Methoxy-5-methylaniline)
4.68e7

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

5.50

6.00

6.50

7.00

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

3.22

3.66

4.50

4.50

7.41

8.78

7: MRM of 2 Channels ES+ 
TIC (2,4,6-Trimethylaniline)
3.96e6

5.00

5.50

6.00

6.50

7.00

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

7.14

6: MRM of 2 Channels ES+ 
TIC (Quinoline)
4.44e7

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

5.50

6.00

6.50

7.00

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

5.67

5: MRM of 2 Channels ES+ 
TIC (4-Chloroaniline)
1.56e6

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

5.50

6.00

6.50

7.00

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

5.10

4: MRM of 2 Channels ES+ 
TIC (o-Anisidine)
2.90e7

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

5.50

6.00

6.50

7.00

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

5.19

3: MRM of 2 Channels ES+ 
TIC (o-Toluidine)
7.72e5

0.50

1.00

1.50

2.00

2.50

3.00

3.54

3.50

4.55

4.85

4.00

4.50

5.00

5.62

5.82

5.50

5.50

6.30

6.79

7.02

7.08

7.29

7.43

7.71

7.94

8.20

8.44

8.60

8.73

8.95

8.97 9.09

9.33

9.55

9.62

9.77

9.92

10.14

10.21

10.47

10.81

10.96

11.25

11.57

11.87

6.00

6.50

7.00

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

7.44

7.29

7.16

6.91

7.04

6.78

7.57

7.63

7.677.89 7.93

8.08

10.33

10.38

10.58

10.81

10.94

11.07

2: MRM of 2 Channels ES+ 
TIC (Acrylamide)
1.49e6

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

5.50

6.00

6.50

7.00

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

100

%

0

0.78

0.82

0.75

1.20

1.18

1.25

0.18

0.41

0.59

0.50

1.00

1.38

1.50

2.07

2.16

2.37

1.88

2.55

2.71

2.81

2.87

3.24

3.42

3.51

3.39

3.55

2.00

2.50

3.00

3.50

4.00

4.50

5.00

5.50

6.00

6.50

7.00

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

3.63

3.88

4.14

4.17

4.42

4.48

4.64 4.80 4.85

7.20

7.05

7.31

7.40

6.83

7.84

7.92

8.03

8.53

8.44

8.71

8.74

9.09

9.14

9.26

9.45 9.50

9.72

9.77 10.15

10.36

10.51

10.75

10.90

11.29

11.64

11.74

1: MRM of 2 Channels ES+ 
TIC (1,2-Dimethylhydrazine)
2.84e4

11.97

Time

Figure 13: LC-MS/MS chromatogram (TIC) of a PVC flooring sample (20152190) 

20152190
CMR_20151015a08

0.01

0.10

%

0.13

0.20

0.36

1.65

1.67

1.74

1.78

1.84

1.89

1.95

2.00

2.01

2.08

2.14

2.16

2.23

2.26

2.27

2.37

2.48

2.53

2.57 2.62

2.66

2.75

2.80

2.85

2.97

2.99

3.07

3.09

3.11 3.15

3.34

3.30

3.40

3.44

11: MRM of 2 Channels ES+ 
TIC
2.06e6

7
-0.00

0.10

0.20

0.30

0.40

0.50

0.60

0.70

0.80

0.90

1.00

1.10

1.20

1.30

1.40

1.50

1.60

1.70

1.80

1.90

2.00

2.10

2.20

2.30

2.40

2.50

2.60

2.70

2.80

2.90

3.00

3.10

3.20

3.30

3.40

3.50

3.60

3.70

CMR_20151015a08

0.10

0.04

0.14

0.23

0.29

%

0.38

0.40

0.45

1.01

1.18

1.20

1.28

1.33

1.36

1.47

1.49

1.55

1.59

1.65

1.70

1.74

1.79 1.80 1.88

1.95

1.99 2.05

2.09

2.13

2.22

2.25

2.31

2.34 2.43

2.47

2.55

2.63

2.68

2.70

2.75

2.78

2.84 2.86

2.91

3.00

3.03

3.08 3.10 3.16

3.19

3.90

3.80
10: MRM of 3 Channels ES+ 
TIC (Hexamethylphosphoramide)
3.00e6

4.00

7
-0.00

0.10

0.20

0.30

0.40

0.50

0.60

0.70

0.80

0.90

1.00

1.10

1.20

1.30

1.40

1.50

1.60

1.70

1.80

1.90

2.00

2.10

2.20

2.30

2.40

2.50

2.60

2.70

2.80

2.90

3.00

3.10

3.20

3.30

3.40

3.50

3.60

3.70

3.80

3.90

4.00

CMR_20151015a08

100

%

0.00

0.09

0.11

0.20

0.23

0.31

0.37

0.38

0.48

0.49

0.54

0.65

0.63

0.68

0.77

0.85

0.89 0.93

1.02

1.10

1.12

1.13

1.22

1.28

1.37

1.40

1.41

1.64

1.67

1.70

1.59

1.55

1.78 1.81

1.91

1.92

1.98

2.05

2.09

2.13

2.20

2.25

2.30

2.36

2.42

2.44

2.48

2.60

2.62

2.69

2.72

2.76

2.79

2.90

2.97

2.99

3.06

3.14

3.16

3.23

3.32

3.34

3.35

9: MRM of 2 Channels ES+ 
TIC (4-Chloro-2-methylaniline)
5.61e4

3.45 3.50

3.57

3.65

3.71

3.93

3.97

0.10

0.20

0.30

0.40

0.50

0.60

0.70

0.80

0.90

1.00

1.10

1.20

1.30

1.40

1.50

1.60

1.70

1.80

1.90

2.00

2.10

2.20

2.30

2.40

2.50

2.60

2.70

2.80

2.90

3.00

3.10

3.20

3.30

3.40

3.50

3.60

3.70

3.80

3.90

4.00

CMR_20151015a08

0.05 0.10

0.15

0.21

0.22

0.35

0.37

0.38

0.43

0.47

0.62

0.67

0.70

0.79

0.82

0.86

0.95

0.96

1.04

1.08

1.18

1.16

1.28

1.34

1.39

1.47

1.41

1.50

1.58

1.59

1.65

1.68

1.76

1.84

1.88

1.94

1.98

2.07

2.09 2.13

2.19 2.24

2.34

2.35

2.64

8: MRM of 2 Channels ES+ 
TIC (2-Methoxy-5-methylaniline)
1.89e5

0.10

0.20

0.30

0.40

0.50

0.60

0.70

0.80

0.90

1.00

1.10

1.20

1.30

1.40

1.50

1.60

1.70

1.80

1.90

2.00

2.10

2.20

2.30

2.40

2.50

2.60

2.70

2.80

2.90

3.00

3.10

3.20

3.30

3.40

3.50

3.60

3.70

3.80

3.90

4.00

0.06

0.10

0.15

0.17 0.22 0.27

0.39

0.37

0.48

0.49

0.54 0.61

0.65

1.16

1.44

1.49

1.55

1.65

1.70

1.72

1.74

1.86

1.87

1.88 1.93

1.57

2.02 2.07

2.13

2.14

2.19

2.48

2.63

2.74

2.80

2.86

2.88

2.98

3.06

3.13

3.17 3.19

3.27

3.32

3.37

3.40

3.60

3.66

3.71

7: MRM of 2 Channels ES+ 
TIC (2,4,6-Trimethylaniline)
5.45e5

3.82

3.92

0.10

0.20

0.30

0.40

0.50

0.60

0.70

0.80

0.90

1.00

1.10

1.20

1.30

1.40

1.50

1.60

1.70

1.80

1.90

2.00

2.10

2.20

2.30

2.40

2.50

2.60

2.70

2.80

2.90

3.00

3.10

3.20

3.30

3.40

3.50

3.60

3.70

3.80

3.90

4.00

CMR_20151015a08
0.01

0.37

0.38

0.40 0.44

0.04

0.14

0.19

0.26 0.34

0.78

0.82

0.84 0.89

0.97

1.01

0.64

0.71

1.26

1.36

1.39

1.49

1.52

1.57

1.64

1.72

1.67

1.82

1.86

1.92

1.99

2.02

2.04

2.13

2.17

2.22

2.30 2.35

2.40

2.46

2.55

2.57

2.65

2.68

2.78

2.75

6: MRM of 2 Channels ES+ 
TIC (Quinoline)
3.33e5

0.10

0.20

0.30

0.40

0.50

0.60

0.70

0.80

0.90

1.00

1.10

1.20

1.30

1.40

1.50

1.60

1.70

1.80

1.90

2.00

2.10

2.20

2.30

2.40

2.50

2.60

2.70

2.80

2.90

3.00

3.10

3.20

3.30

3.40

3.50

3.60

3.70

3.80

3.90

4.00

CMR_20151015a08

100

%

0.01

0
-0.00

0.15

0.16

0.26

0.36

0.38

0.45

0.52

0.54

0.70 0.71

0.85 0.91

0.98

1.06

1.09

1.19

1.35

1.38

0.64

0.66

1.46

1.51

1.58

1.59

1.67

1.73

1.76

1.77

1.92

1.89

1.99

2.03

2.15

2.11

2.25

2.30

2.37

2.44

2.52

2.61

2.67

2.64

2.80

2.77

2.88

2.93

2.97

3.04

3.10

3.14 3.18

3.24

3.33

3.46

3.52

3.58

0.10

0.20

0.30

0.40

0.50

0.60

0.70

0.80

0.90

1.00

1.10

1.20

1.30

1.40

1.50

1.60

1.70

1.80

1.90

2.00

2.10

2.20

2.30

2.40

2.50

2.60

2.70

2.80

2.90

3.00

3.10

3.20

3.30

3.40

3.50

3.60

CMR_20151015a08

0.10

0.15

0.17 0.23

0.37

0.38

0.42

0.48

0.29

0.34

0.60

0.63

0.77

0.72

0.56

0.80

0.82

0.83

0.92

1.03

1.01

1.09

1.15

1.20 1.28

1.30

1.39

1.43

1.52

1.55

1.59

1.65

1.67

1.70

1.77

1.84

1.90

1.99

2.00

2.04

2.14

2.18

2.22 2.24

2.34

2.46

2.48

2.49

2.58

2.64

2.67

2.74

2.78

2.87

2.90

3.03

3.01

3.10

3.15

3.20

3.30

3.33

3.34 3.42

3.47

3.69

3.73

5: MRM of 2 Channels ES+ 
TIC (4-Chloroaniline)
8.28e4

3.70

3.70

3.96

3.80

3.90

4.00

4: MRM of 2 Channels ES+ 
TIC (o-Anisidine)
1.67e5

0.10

0.20

0.30

0.40

0.50

0.60

0.70

0.80

0.90

1.00

1.10

1.20

1.30

1.40

1.50

1.60

1.70

1.80

1.90

2.00

2.10

2.20

2.30

2.40

2.50

2.60

2.70

2.80

2.90

3.00

3.10

3.20

3.30

3.40

3.50

3.60

3.70

3.80

3.90

4.00

CMR_20151015a08
0.00
0.04

100

%

0.05

0.14 0.18

0.40

0.43

0.44

0.25

0.31

0.37

0.50 0.58

0.65

0.66

0.73

0.80

0.88

1.05

1.14

1.21

1.23

1.26

1.38

1.45

1.16

1.49

1.51

1.60

1.62

1.68

1.75

1.79

1.74

1.87

1.94

1.97

2.01 2.03

2.13

2.19

2.31

2.28

2.33

2.38

2.44

2.46
2.51

2.58

2.59

2.61

2.66

2.71

2.80

2.82

2.90

2.84

2.97

3.05

3.01

3.13

3.21

3.23

3.26

3.34

3.43

3.46

3.48

3.57

3.65

3: MRM of 2 Channels ES+ 
TIC (o-Toluidine)
2.03e4

3.76

3.77

3.82 3.86

3.88

3.96

0
-0.00

0.10

0.20

0.30

0.40

0.50

0.60

0.70

0.80

0.90

1.00

1.10

1.20

1.30

1.40

1.50

1.60

1.70

1.80

1.90

2.00

2.10

2.20

2.30

2.40

2.50

2.60

2.70

2.80

2.90

3.00

3.10

3.20

3.30

3.40

3.50

3.60

3.70

3.80

3.90

4.00

0.66

0.78

0.57

1.23

1.52

1.65

1.67

1.70

1.79

1.86

1.90

2.00

2.04

2.29

2.17

2.22

2.24

2.58

2.87

3.13

3.46

3.73

2: MRM of 2 Channels ES+ 
TIC (Acrylamide)
1.13e6

0.10

0.20

0.30

0.40

0.50

0.60

0.70

0.80

0.90

1.00

1.10

1.20

1.30

1.40

1.50

1.60

1.70

1.80

1.90

2.00

2.10

2.20

2.30

2.40

2.50

2.60

2.70

2.80

2.90

3.00

3.10

3.20

3.30

3.40

3.50

3.60

3.70

3.80

3.90

4.00

0.15

0.44

0.55

0.56

0.61

0.66

0.67

0.79

0.81

0.89

0.91

1.27

1.35

1.41

1.21

1.25

1.43

1.54

1.52
1.45

1.63

1.64

1.75

1.77

1.66

1.88

1.78

1.95

2.07

2.16

2.15

2.01

2.28

2.27

2.31

2.40

2.48

2.56

2.60

2.61

2.50

2.81

2.74

2.76

2.84

2.91

2.99

3.06

3.08

3.13

3.18 3.21

3.36

3.37

3.40

3.51

3.52

0.10

0.20

0.30

0.40

0.50

0.60

0.70

0.80

0.90

1.00

1.10

1.20

1.30

1.40

1.50

1.60

1.70

1.80

1.90

2.00

2.10

2.20

2.30

2.40

2.50

2.60

2.70

2.80

2.90

3.00

3.10

3.20

3.30

3.40

3.50

3.60

3.70

3.80

3.90

1: MRM of 2 Channels ES+ 
TIC (1,2-Dimethylhydrazine)
1.52e4

Time

4.00

CMR_20151015a08

0
-0.00

%

3
-0.00

%

3
-0.00

%

5
-0.00

0.02

%

6
-0.00

CMR_20151015a08

CMR_20151015a08

%

1
-0.00

100

%

0
-0.00

199 

 
 
 
 
CMR_20151015a12

100

%

0

0.01

0.20

0.41

0.63

0.90

0.94

0.98

CMR_20151015a12

0.50

1.00

1.50

2.00

2.50

100

%

0

0.39

1.16

3.01

3.00

3.13

3.57

CMR_20151015a12

100

%

0

0.13

0.45

0.39

0.90

1.02

1.15

1.24

1.39

1.51

1.70

1.81 1.94

2.57

2.71

2.97

0.50

1.00

1.50

2.00

2.50

3.22

3.19

3.27

3.09

3.00

Figure 14: LC-MS/MS chromatogram (TIC) of a wall paper sample (20152194) 

20152194
CMR_20151015a12

100

%

0

0.22

0.24

0.36

0.44

0.85

0.94

1.11

1.15

1.17

1.47 1.50

1.651.87

1.90

2.75

2.96

3.06

3.15

3.18

3.49

3.67

3.69 3.95 4.104.22

7.43

7.46

7.49

7.62 7.79 8.08

8.14

8.22 8.34

8.45

8.58

8.77

8.97

8.99 9.17

9.63

9.68

10.21

11.08

11: MRM of 2 Channels ES+ 
TIC
9.36e5

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

5.50

6.00

6.50

7.00

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

CMR_20151015a12

%

0

0.40

0.59

1.05

1.15

1.28

1.37

0.50

1.00

1.50

2.00

2.26

2.31

2.60

2.50

2.70

2.82

3.07

3.49

3.73

3.85

3.98

4.15

4.37

4.53

4.66

4.92

5.17

6.28

6.36

6.05

6.09

6.44 6.64

3.00

3.50

4.00

4.50

5.00

5.50

6.00

6.50

6.92

7.00

7.46

7.53

8.00

8.15

8.31

8.24

8.50

8.78

9.28

9.62

10.11

10.22

11.03 11.22

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

10: MRM of 3 Channels ES+ 
TIC (Hexamethylphosphoramide)
1.90e6

CMR_20151015a12

100

%

0.02

0

0.38

0.41

0.21

0.64

0.68 0.89

1.22

1.27

1.64

1.61

1.79

1.82

1.97 2.25

2.71

2.82

2.94

3.26

3.24

3.29

3.41

3.75

6.24

7.23

6.99

7.13

7.33

7.42

7.45

7.68

8.03

8.08

7.90

8.61

8.72

8.30

8.45

8.84

8.97

9.35

9.46

9.63 9.68

9: MRM of 2 Channels ES+ 
TIC (4-Chloro-2-methylaniline)
7.62e4

11.01

11.09

11.19

11.88

11.97

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

5.50

6.00

6.50

7.00

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

4.88

4.96

4.78

3.82

4.23

4.36

4.55

4.57

4.98

5.23

5.28

5.78

5.95

5.60

6.11

6.25

6.37

6.42

6.64

7.13

7.34

7.46

7.49

7.55

7.84

7.87

8.02

8.27

8.32

8.47

8.75

8.82

8.84 9.049.16

9.34

9.38

9.62

9.64

8: MRM of 2 Channels ES+ 
TIC (2-Methoxy-5-methylaniline)
2.25e5

3.50

4.00

4.50

5.00

5.50

6.00

6.50

7.00

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

5.50

6.00

6.50

6.44

7.00

7.48

7.50

8.58

8.68

8.89

8.95

9.06

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

7: MRM of 2 Channels ES+ 
TIC (2,4,6-Trimethylaniline)
4.34e6

7.36

7.39

7.29

7.50

7.64

6: MRM of 2 Channels ES+ 
TIC (Quinoline)
2.76e5

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

5: MRM of 2 Channels ES+ 
TIC (4-Chloroaniline)
2.08e5

3.36 3.52

3.79

3.91

4.06

4.27

4.33

4.45 4.49

4.77

4.99

5.01

5.15

6.13

6.30

6.04

6.39

6.49

6.63

3.50

4.00

4.50

5.00

5.50

6.00

6.50

7.15

7.05

7.00

CMR_20151015a12

100

%

0

CMR_20151015a12

0.63

0.66

CMR_20151015a12

100

%

0

CMR_20151015a12

100

0.00

%

0

CMR_20151015a12

100

0

0.95

1.15

1.27

1.46

1.73

1.66

2.73

3.19

2.99

3.30

3.49

3.66

7.53

7.57

7.60 7.75

8.10 8.27

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

5.50

6.00

6.50

7.00

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

100

%

0

0.20

0.37

0.49

0.70

0.72

0.91

1.23

1.29

1.50

1.72

1.86

1.99

2.08

2.27

2.76

2.81

0.50

1.00

1.50

2.00

2.50

3.05

3.00

3.13

3.38

3.41

3.56

3.72 3.88

4.09

4.28

4.53

4.69

4.83

5.00

5.10

5.14
5.20

5.28

5.69

5.76

5.84

6.28

6.31

6.41

7.49

7.54

7.38

7.29

7.65

7.99

8.04

8.07

8.40

8.49

8.57

8.76 8.79 8.94 9.07

9.67

4: MRM of 2 Channels ES+ 
TIC (o-Anisidine)
3.09e5

3.50

4.00

4.50

5.00

5.50

6.00

6.50

7.00

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

3.53

3.70

3.99

4.04

4.26

4.50

4.53

4.87

4.89

5.08

4.92

7.41

7.47

7.51

7.55

7.28

7.15

8.01

8.04

8.07

7.88

8.47

8.68

8.84

8.95

8.58

9.06

9.12

9.32

9.60

9.65

9.71

10.07

10.20

11.06 11.23

3: MRM of 2 Channels ES+ 
TIC (o-Toluidine)
1.43e5

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

5.50

6.00

6.50

7.00

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

0.52

0.68

0.71

1.15

1.18

1.36

1.61 1.71 1.84

2.30

2.58

2.80

2.86

3.10

3.40

3.42

3.53

3.61

3.95

3.99

4.30

4.42

4.56

4.79

4.88

4.99

5.22

6.10

6.32

6.39

6.76

7.15

7.18

6.94

6.86

7.58

7.85

7.47

8.02

8.25

8.63

8.67

8.70

8.89

9.11

9.34

9.40

9.43 9.61

10.16

10.08

9.89

10.29

2: MRM of 2 Channels ES+ 
TIC (Acrylamide)
1.14e6

11.05

11.21

11.25

11.43 11.6411.80

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

5.50

6.00

6.50

7.00

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

%

0.19

0.33

0.40

0.65

0.85

0.43

1.07

1.18

1.28

1.75

1.78

1.52

2.17

2.24

2.48

2.04

2.71

2.80

2.52

3.00

3.02

3.24

3.26

3.58

3.60

3.70

4.084.10

4.61

4.63

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

6.50

7.00

7.50

8.00

8.50

9.00

9.50

10.00

10.50

11.00

11.50

5.31

5.51

5.50

6.28

5.98

6.00

6.98

7.10

7.35

7.32

7.527.54 7.88

8.05

8.13

8.288.31

8.64

8.70

8.79 8.96

9.28

9.38

9.56

9.61

9.86

10.06

10.20

1: MRM of 2 Channels ES+ 
TIC (1,2-Dimethylhydrazine)
1.50e4

11.21

11.38

11.56

Time

5.5.4 CONTENT RESULTS OF THE MIGRATION FROM SAMPLES TO ARTIFICIAL SWEAT 

All  the  phthalate  results  of  the  samples  were  lower  than  the  LOQ  (0.1%  m/m).  However  low 
amounts of some phthalates were present in all the samples (concentration around 100 µg/kg) 
and in procedural blanks due to the contamination of the products used for preparation of the 
artificial sweat. 

A standard mix of the phthalates (Table 45) was used for screening. 

Table 45: Retention times of the phthalate standard mix 

Compound 

Diisobutylphthalate              DiBP 

Di-n-butylphthalate                DBP 

Dipentylphthalate                   DPP 

Butylbenzylphthalate            BBP 

Bis(2-ethylhexyl)phthalate  DEHP 

RT (min) 

17.69 

18.71 

20.53 

22.45 

23.76 

5.5.5 RESULTS OF THE EMISSION SCREENING EXPERIMENTS 

A  first  screening  of  the  emission  behavior  was  performed  with  the  µchamber.  Two 
representative  chromatograms  are  shown,  from  a  PVC  floor  covering  (20152190,  Figure  15) 
and a wall covering (20152195, Figure 16). None of the CMR compounds were detected during 
these  experiments,  other  non-CMR  VOCs  are  present,  identified  and  quantified  with  the 
horizontal reference method (see section 5.5.6). 

200 

 
 
 
 
 
 
Figure 15: µchamber chromatogram of sample 20152190 

Abundance

TIC: 2015111902.D\data.ms

7500000

7000000

6500000

6000000

5500000

5000000

4500000

4000000

3500000

3000000

2500000

2000000

1500000

1000000

500000

Time-->

10.00

15.00

20.00

25.00

30.00

35.00

40.00

Figure 16: µchamber chromatogram of sample 20152195 

Abundance

 1.7e+07

 1.6e+07

 1.5e+07

 1.4e+07

 1.3e+07

 1.2e+07

 1.1e+07

   1e+07

9000000

8000000

7000000

6000000

5000000

4000000

3000000

2000000

1000000

Time-->

TIC: 2015111903.D\data.ms

10.00

15.00

20.00

25.00

30.00

35.00

40.00

5.5.6 RESULTS OF THE HORIZONTAL REFERENCE EMISSION EXPERIMENTS 

Also with the horizontal emission test reference method no CMR compounds were detected on 
Tenax,  Carbotrap  202,  XAD-2,  active  charcoal  and  PDMS/Tenax  at  concentrations  >  1  µg/m³ 
with  the  exception  of  low    formaldehyde  concentrations  sampled  on  DNPH  cartridges  (see 
Table 48).  

An  overview  of  the  non  CMR  compounds  is  listed  in  Table  46.  The  representative 
chromatograms  obtained  with  the  reference  sorbent  Tenax  after  3  and  28  days  are  listed  in 
Annex 4. 

For all samples the TVOC levels (see Table 47) are below 1000 µg/m3 which is the limit value 
in the Belgian, French and German product emission legislations. 

201 

 
 
 
 
 
The  TSVOC  levels  (see  Table  47)  are  not  below  100  µg/m3  for  all  samples  which  is  the  limit 
value  in  the  German  and  Belgian  product  emission  legislations.  Products  failing  national 
product  emissions  legislations  are  due  to  high  TSVOC  levels  and/or  to  high  phenol  emission. 
The wall covering 20152195 exceeds the allowed R value for use indoor. 

202 

 
 
 
Table 46: Overview of the TD-GC-MS results on Tenax after 28 days (in µg/m³) 

Compound 

CAS 

ID 103 

2015 

2015 

2015 

2015 

2015 

2015 

2015 

2015 

2015 

2015 

2190 

2191 

2250 

2252 

2194 

2195 

2192 

2193 

2253 

2251 

Pentanal 

Hexanal 

Heptanal 

Cyclohexanone 

Phenol 

Octanal 

2-Ethyl-1-hexanol 

1-Methyl-2-pyrrolidone 

Nonanal 

Butyldiglycol 

Decanal 

n-Tetradecane 

110-62-3 

66-25-1 

111-71-7 

108-94-1 

108-95-2 

124-13-0 

104-76-7 

872-50-4 

124-19-6 

112-34-5 

112-31-2 

629-59-4 

1-Methoxy-2-propyl acetate 

108-65-6 

Ethanol-2,2'-oxybis 

Benzaldehyde 

Benzylalcohol 

111-46-6 

100-52-7 

100-51-6 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

2 

2 

2 

2 

ND 

ND 

ND 

ND 

<5 

<5 

<5 

ND 

<5 

10 

<5 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

<5 

6 

<5 

ND 

ND 

ND 

ND 

ND 

<5 

ND 

ND 

ND 

<5 

ND 

18 

ND 

<5 

21 

<5 

ND 

ND 

ND 

ND 

ND 

<5 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

<5 

7 

<5 

<5 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

<5 

<5 

ND 

<5 

6 

<5 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

13 

52 

ND 

ND 

ND 

<5 

<5 

<5 

ND 

ND 

ND 

ND 

ND 

<5 

<5 

ND 

9 

ND 

ND 

<5 

<5 

ND 

7 

110 

ND 

ND 

ND 

5 

37 

ND 

<5 

<5 

ND 

ND 

ND 

ND 

<5 

<5 

<5 

<5 

ND 

ND 

ND 

ND 

31 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

11 

ND 

ND 

ND 

ND 

ND 

ND 

<5 

ND 

<5 

ND 

ND 

ND 

ND 

ND 

103 Identification: 

- 
- 

1: identification by standard solution and retention time, confirmed by spectrum library and specifically calibrated 
2: identification by comparison with spectrum library and plausibility declaration, calibrated as toluene equivalent 

203 

 
 
                                           
 
 
Compound 

CAS 

ID 103 

2015 

2015 

2015 

2015 

2015 

2015 

2015 

2015 

2015 

2015 

2190 

2191 

2250 

2252 

2194 

2195 

2192 

2193 

2253 

2251 

Hexanoic acid-2-ethyl 

2-Propenoic 
methylheptyl ester 

acid,6-

Ethanol,2-phenoxy- 

149-57-5 

54774-91-
3 

2 

2 

122-99-6 

2 

Benzaldehyde-2,4,6-trimethyl 

5779-72-6  2 

Butylated hydroxytoluene 

128-37-0 

2 

2-Nonenal,2-pentyl 

3021-89-4  2 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

120 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

12 

25 

46 

ND 

ND 

50 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

36 

ND 

ND 

ND 

ND 

ND 

ND 

16 

ND 

ND 

ND 

ND 

ND 

ND: not detected 

204 

 
 
Table 47: Overview of TVOC and TSVOC after 3 and 28 days (in µg/m³) 

Compound 

TVOC 

TVOC 

TSVOC 

TSVOC 

20152190 

20152191 

20152192 

20152193 

20152194 

20152195 

20152250 

20152251 

20152252 

20152253 

3d 

65 

27 

260 

60 

500 

520 

33 

22 

65 

21 

28d 

6 

<5 

100 

73 

120 

330 

47 

21 

63 

63 

3d 

90 

85 

19 

229 

250 

79 

<5 

<5 

<5 

620 

28d 

98 

85 

<5 

40 

420 

84 

<5 

<5 

180 

226 

Table 48: Overview of formaldehyde concentrations after 3 and 28 days (in µg/m³) 

Compound 

20152190 

20152191 

20152192 

20152193 

20152194 

20152195 

20152250 

20152251 

20152252 

20152253 

3d 

3 

3 

ND 

ND 

ND 

7 

ND 

ND 

ND 

ND 

28d 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

ND 

As observed in the content measurements of the samples 20152190 and 20152191 a non-CMR 
phthalate  was  also  detected  on  PDMS/Tenax  with  concentrations  of  ~5  µg/m³  and  ~6  µg/m³ 
respectively. 

 5.6 CONCLUSION 

The  10  samples  were  first  screened  on  CMR  content  with  (headspace)  GC-MS  techniques. 
Quantitative content measurements were performed with LC-MS/MS. It was clearly shown that 
none of the samples contained CMR substances. The content approach was complemented with 
dermal  exposure  experiments,  no  CMR  compounds  migrated  from  the  articles  to  the  artificial 
sweat. 

205 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
The  potential  release  to  indoor  air  of  CMR  compounds  from  the  10  samples  was  first 
investigated  by  means  of  the  µchamber  screening  technique.  Quantitative  emission 
measurements  were  performed  with  the  new  (prEn  16516,  2015)  European  horizontal 
emission test standard in test chambers of 110l, 500l and the complementary test cell method 
(FLEC). Sampling was executed on 6 types of sorbents to adequately capture the whole range 
of CMR compounds. The results only showed low emissions (<10 µg/m³) of formaldehyde after 
3  days  for  three  (2  floor  coverings  and  1  wall covering)  of  the  10  tested  materials.  No  other 
CMR 1A/1B substances were detected in any of the 10 articles.  

206 

 
 
 
 
 
CHAPTER 6  CONCLUSION 

The widespread use of construction products creates large opportunities for a high number of 
consumers to be exposed to substances with chronic toxicity properties that are released from 
such products.  

Hazardous  substances  can  i.a.  be  managed  by  restriction  of  these  substances  individually,  or 
when  used  in  mixtures  or  articles,  in  Annex  XVII  of  the  REACH  Regulation  (EU)  1907/2006. 
REACH,  through  Art.  68(2),  offers  a  simplified  restriction  procedure,  as  regards  consumer 
uses, for substances classified as carcinogenic, mutagenic or toxic for reproduction (CMR Cat. 
1A/1B).  This  project  studied  the  possible  application  of  Article  68(2)  to  CMR  substances  in 
construction  articles,  by  aiming  to  identify  CMR  Cat.  1A/1B  substances  used  in  such  articles 
and having the potential to lead to exposure of consumers. 

For  substances  and  mixtures,  merely  the  presence  of  a  substance  is  enough  to  assume 
exposure.  In the case  of articles, such as construction articles, it is the release rather than 
the  presence  of  a  substance  that  plays  an  important  role  in  the  assessment  of  potential 
exposure.  

In  Task  1  a  list  of  construction  products  was  compiled  from  which  consumer  exposure 
(inhalation  and  dermal)  to  their  chemical  content  is  possible  during  the  Do-it-Yourself  (DIY) 
installation and during service life. For construction products the definition in Article 2.1 of the 
Construction  Products  Regulation  (EU)  No  305/2011  (CPR)  was  applied.  The  diverse  range  of 
construction products was limited to products for which harmonized technical specifications are 
established  (Article  2.10  of  the  CPR);  they  are  covering  most  of  the  construction  products 
available  on  the  market.  In  addition,  the  final  compiled  list  was  restricted  to  construction 
products falling under the definition of articles according to Article 3.3 of REACH. 

To  limit  the  large  scope  of  possible  relevant  construction  products  for  consumer  exposure  a 
prioritization  was  made  based  on  expert  judgment  taking  into  account  the  following  four 
factors:  direct  contact  with  indoor  air;  likely  dermal  contact  during  use  phase;  DIY  likely 
exposure  (taking  into  account  the  exposure  time,  exposed  surface  and  manipulations 
involvement);  and  its  coverage  by  content/emissions  schemes.  The  final  list  consisted  of  the 
following construction products: 

Doors  and  windows,  ceramic  based  products,  thermal  insulation  products,  wall  coverings, 
concrete and cement, wood-based panels, masonry, flooring, surfaces for sport areas, gypsum 
and gypsum based products, suspended ceilings, stretched ceilings, terraces, and playgrounds. 

For  these  product  categories  (which  were  further  broken  down  in  subcategories),  a  market 
study was performed to evaluate the quantities produced/sold on the  European market. Data 
predict  an  upward  evolution  in  the  near  future  in  the  sales’  volumes  of  doors  and  windows, 
ceramic  tiles,  thermal  insulation  products,  wood  based  panels,  flooring  (except  cork),  and 
wood/plastic composite terraces.   

In  Task  2  an  overall  list  of  CMR  1A/1B  substances  that  are  contained  in  construction  articles 
was  compiled  based  on  information  gathered  via  various  sources  and  strategies.  As  a  result, 
we identified 31 CMR 1A/1B substances, for which there are indications that the substance 
is used for the manufacturing in at least one type of construction article, or that the substance 
is released from at least one type of a construction article. 

Information  regarding  the  content  and  technical  function  of  these  substances  was  collected. 
How widely these CMR 1A/1B substances are used in construction articles was assessed based 
on the number of cases in which these substances were detected in the consulted sources and 
on  the  manufactured/imported  volume  tonnage  bands  indicated  in  the  registration  dossiers. 
The  latter  provided  an  estimate  of  how  widespread  the  use  of  the  substance  in  general  is. 
However,  it  cannot  be  derived  from  this  which  fraction  of  the  use  specifically  concerns 
construction products. 

207 

 
In the second part of Task 2, an overview was made of existing national, European and third 
countries’ legislation restricting CMR 1A/1B substances in construction articles.  

Within  the  EU,  the  REACH  regulation  is  the  most  relevant  law  concerning  CMR  1A/1B 
substances in construction articles. Some specific CMR 1A/1B substance uses are addressed by 
authorisations  and  restrictions,  but  the  use  of  CMR  1A/1B  in  construction  articles  is  not 
generally  prohibited.  Bans  and  restrictions  of  CMR  1A/1B  substances  under  REACH  are  based 
on “presence or content” criteria, and not on release criteria.    

Some  EU  Member  States  have  additional  national legislation  concerning  the  aspect  of  (some) 
CMR  1A/1B  in  construction  articles.  These  national  legislations  are  in  general  release-
oriented.  For  example,  the  German,  Belgian  and  Lithuanian  legislation  limits  the  release  of 
CMR 1A/1B substances listed in the prEN 16516 emission testing protocol, to maximum model 
room levels of 1 µg/m³ after 28 days of emission testing. Another example is the limitation of 
formaldehyde release to maximum model room levels of 100 µg/m³ after 28 days of emission 
testing for floor covering materials in the Belgian legislation. 

Information gathered during Task 3 confirmed the presence in various construction articles of 
several  of  the  CMR  1A/1B  substances  identified  in  task  2.    It  was  assessed  whether  their 
presence in construction articles effectively provokes exposure. The literature reporting 
on experimental data demonstrated that some CMR 1A/1B substances are effectively released 
to the indoor air and/or are potentially released to the skin upon dermal contact.   

Literature  reporting  on  monitoring  data  for  formaldehyde,  benzene  and  phthalates  in 
residential premises confirm that they are widely present in the indoor environment.  However, 
other sources (e.g. outdoor air, cleaning products, etc.) in addition to construction articles are 
likely to also contribute to these indoor levels.   

For  other  CMR  1A/1B  substances,  (e.g.  tris(2-chloroethyl)phosphate  (TCEP)  and  N-methyl-2-
pyrrolidone)  monitoring  data  in  indoor  dust  in  various  dwellings  have  shown  that  these 
substances occur only in a small minority of buildings in the EU. 

Experimental  methods  to  assess  exposure  to  CMR  1A/1B  substances  for  the  scenario 
‘consumer exposure via indoor air during article service lifetime’ are well established (CEN/TS 
16516 emission test) and embedded in regulatory frameworks (e.g. CPR). These results from 
experimentally  measured  emission  rates  have  been  demonstrated  to  match  with  indoor  air 
levels  in  real  indoor  environments.    However,  methods  for  assessing  the  consumer  exposure 
scenario  of  dermal  exposure  upon  skin  contact  with  construction  articles  are  more  prone  to 
uncertainties.  In  contrast  to  indoor  air  exposure,  dermal  exposure  to  substances  in 
construction articles is not (yet) embedded in an official standard.  

Besides  the  two  most  evident  consumer  exposure  scenarios  (direct  releases  to  the  indoor  air 
and  direct  dermal  contact),  indirect  exposure  scenarios  for  semi-VOC  substances  in 
construction articles have been described in the literature as well: for example, release to the 
dust phase and surfaces and subsequently oral and dermal contact.  For example, monitoring 
data of semi-VOC CMR 1A/1B substances in dust (e.g. DEHP, TCEP) demonstrate that this is a 
likely  pathway  for  exposure,  however,  no  widely  accepted  tools  to  assess  this  exposure  have 
been agreed upon yet.    

Data  on  DIY  exposure  and  professional  exposure  scenarios  are  more  scarce  compared  to 
article life service exposure. Professional exposure to substances in construction articles (e.g. 
installers  of  PVC  flooring)  is  likely  lower  than  the  exposure  of  workers  in  contact  with  these 
substances during manufacture and production. 

In  order  to  assess  the  likelihood  of  exposure  to  CMR  1A/1B  substances  arising  from 
construction articles, 5 criteria have been applied on each of the identified cases from task 2, 
namely  1)  presence  of  CMR  1A/1B  substances  in  construction  articles;    2)  emission  of  CMR 
1A/1B substances in construction articles (from monitoring programs); 3) estimated exposure 
(modelling); 4): measured indoor  exposure; 5) source apportioning support that construction 

208 

 
 
 
 
articles are the main source of indoor exposure. Moving from criterion 1 to 5 gives increasing 
evidence  for  exposure  to  CMR  1A/1B  substances  in  relation  to  the  presence  of  construction 
articles.  

Based  on  the  scoring  for  these  5  criteria,  the  different  pairs  of  construction  articles  (CA)  and 
CMR  substances  were  organized  into  groups.  Pairs  of  CA/CMR  substances  belonging  to  the 
same  group  have  a  similar  likelihood  of  consumer  exposure  to  CMR  substances  present  in 
construction articles.  

As  a  result,  there  was  a  wide  range  in  evidence  for  exposure  to  CMR  1A/1B  substances  in 
relation  to  presence  of  construction  articles:  on  the  one  hand,  for  some  substances  (e.g. 
formaldehyde),  consumer  exposure  has  been  demonstrated  in  several  ways  (emission  data, 
monitoring  data  in  indoor  air),  the  exposure  is  ubiquitous  in  the  EU  and  indoor  construction 
articles have been demonstrated as a significant source of indoor exposure. On the other hand, 
for other cases, monitoring data below detection limits in all monitored premises suggest that 
the substance only rarely occurs in indoor environments, and thus the possible presence of the 
substance  in  construction  articles  does  not  lead  to  consumer  exposure  (e.g.  acrylonitrile). 
However,  for  the  majority  of  the  substances,  the  evidence  is  less  clear.  In  some  cases, 
indications are available that exposure origination from construction articles is probably minor; 
in  other  cases,  no  assessment  could  be  made  based  on  the  available  information,  thus  more 
monitoring data are needed to make a sound assessment possible.  

In  Task  4  analytical  testing  was  performed  on  construction  articles.  The  testing  was 
performed  on  8  resilient  PVC  floorcovering  materials  and  2  wall  papers  purchased  from  the 
Belgian retail market in 2015. The analytical tests performed included content testing, dermal 
exposure  testing,  and  indoor  air  emission  testing.  The  list  of  target  CMR  1A/1B  substances 
consisted of 71 volatile, semi-volatile and very volatile substances.  

For  the  content  testing,  the  10  samples  were  first  screened  for  CMR  1A/1B  content  with 
(headspace) GC-MS techniques. Quantitative content measurements were performed with LC-
MS/MS.  It  was  clearly  shown  that  none  of  the  samples  contained  CMR  1A/1B  substances  (> 
0.1 %). The content approach was complemented with dermal exposure experiments. Transfer 
step extraction 
combined with migration at long term dermal exposure was simulated by a one
at  shaking  conditions  at  pH  5.5  and  37°C  with  artificial  sweat.  No  CMR  1A/1B  substances 
migrated from the articles to the artificial sweat.  

‐

The potential release to indoor air of CMR substances from the 10 samples was first screened 
by  means  of  the  standard  microchamber  screening  technique.  Quantitative  emission 
measurements were performed with the new European horizontal emission test standard (prEn 
16516, 2015) in test chambers of 110l, 500l and the complementary test cell method (FLEC). 
The air sampling times were selected to reflect the consumer exposure during the installation 
(sampling  after  3  days)  or  lifetime  of  the  article  (sampling  after  28  days).    Sampling  was 
executed  on  6  types  of  sorbents  to  adequately  capture  the  whole  range  of  CMR  substances. 
The results only showed low emissions (corresponding to reference room concentrations of 1-
10 µg/m³) of formaldehyde after 3 days for three (2 floor coverings and 1 wall covering) of the 
10  tested  materials.  No  other  CMR  1A/1B  substances  were  detected  after  3  days.  No  CMR 
1A/1B substances were detected in any of the 10 articles after 28 days. 

The  analyses  performed  within  this  project  reveal  no  significant  problem.  However  there  are 
large  information  gaps  on  which  substances  are  used  in  construction  articles,  and  in  which 
specific  categories  of  construction  articles  they  are  used.  Data  on  technical  function  of 
substances  used  in  construction  articles  is  scarce,  and  information  on  secondary  reaction 
products arising from substances used in construction articles is minimal. 

Dermal  exposure  through  direct  contact  with  surface  of  flooring  materials  was  mimicked  by 
measuring release of substances to artificial sweat. Experiments with resilient flooring and wall 
paper in our experiments showed no detectable  release  of CMR 1A/1B substances to artificial 
sweat.  In  contrast,  reuse  of  spent  tires  on  playground  surfaces  and  sport  areas  has  been 
demonstrated to be of concern in literature. However, this concern for actual exposure should 

209 

 
 
be  further  investigated  since  it  is  unclear  to  what  extent  the  currently  available  testing 
procedures adequately reflect dermal exposure. 

The experimental work detected no release to test chamber air of CMR 1A/1B substances from 
resilient flooring and wall paper after 28 days. After 3 days low concentrations of formaldehyde 
were  measured  in  3  samples.  It  is  recommended  to  extend  release  measurements  to  other 
categories (e.g. wooden panels), to products manufactured in EU Member States without own 
legislation on limits for release of CMR 1A/1B substances from (specific) construction products    
and to imported articles.   

Restriction  regarding  the  release  of  formaldehyde  from  specific  articles  would  probably  be  an 
efficient  measure  to  reduce  consumer  exposure  to  this  CMR  substance.  Also  a  number  of 
phthalates  (bis  (2-ethylhexyl)phthalate  (DEHP),  diisobutyl  phthalate,  dibutylphthalate,  and 
benzylbutylphthalate), and trichloroethylene are known to be used in construction articles and 
have a high to moderate likelihood of consumer exposure. However they are included in Annex 
XIV  of  REACH  and  anticipated  not  to  be  present  in  new  construction  articles  after  the  sunset 
date and no longer to lead to consumer exposure after that date. 

For the following substances there is no indication that they are used in construction articles in 
a  concentration  >  0.1%:  benzene,  trichloroethylene,  chloroprene,  N,N-dimethylacetamide, 
dipentylphthalate, dimethyl formamide and 2-ethoxyethanol. However  release to indoor air in 
test  chambers  has  been  measured;  these  substances  may  be  impurities  or  degradation 
products.  Restrictions  on  the  use  of  these  substances  may  not  be  an  efficient  tool  to  reduce 
exposure, unless they include specific measures related to presence in articles. 

For  another  set  of  substances  used  in  used  in  the  manufacturing  of  construction  (2- 
ethoxyethyl acetate, tris(2-chloroethyl)phosphate, 1-methyl-2-pyrrolidone and beryllium there 
are  –  bases  on  notifications  and  registrations),  there  are  limited  indications  that  the  use  of 
these  substances  in  construction  articles    provoke  consumer  exposure  2;  however,  more 
indoor air measurements are needed to confirm test chamber results and to assess the extent 
of exposure. 

For  the  following  substances  there  is  information  supporting  their  presence  in  construction 
articles,  however  more  research  (emission  studies,  adequate  techniques  for  monitoring  in 
indoor  air/dust)  is  needed  to  investigate  the  consumer  exposure  to  CMR  substances  arising 
from  construction  articles:  ,  diboron  trioxide,  boric  acid,  disodium  tetraborate  anhydrous, 
magnesium  nitrate,  potassium  pentaborate,    and  aluminosilicate  Refractory  Ceramic  Fibres 
(index number 650-017-00-8 in Annex VI of the CLP Regulation). 

210 

 
 
 
   
 
  
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213 

 
 
ANNEX 1 - LIST OF NON-HARMONIZED CLASSIFIED CMR SUBSTANCES (1A/1B) USED IN CONSTRUCTION ARTICLES 

This Annex includes a list of non-harmonized CMR 1A/1B substances  contained in construction articles (with priority to green-flagged 
Joint entries in the C&L inventory) 

Substance 

EC-
number 

Use in construction articles  Likelihood/wide
spreadness  of 
occurrence 
in 
construction 
articles 

Concentration 
of  SVHC 
article? 

in 

Technical 
function 

Information source(s) of presence 
of this CMR 1A/1B in construction 
article 

Dibutyltin 
dilaurate 

201-039-8 

19: 

building 

and 
SU 
construction  work;    and  ERC 
3,  ERC  5,  ERC6d,  ERC10a, 
ERC10b  or  ERC11a  or  a 
combination  of  these  ERCs; 
not further specified  

Alfa-terpinene 

202-795-1  wood based panels  

208-168-9)  SU 

19: 

building 

and 
construction  work;    and  ERC 
3,  ERC  5,  ERC6d,  ERC10a, 
ERC10b  or  ERC11a  or  a 
combination  of  these  ERCs; 
not further specified 

Cadmium 
carbonate*  

214 

unknown 

 tonnage  band: 
1,000 
100 
- 
tonnes 
per 
annum 

not  mentioned  in 
consulted 
sources 

registration 

dossiers: 
REACH 
in  building  and 
substance  used 
construction  work 
(SU  19)  and 
relevant  ERCs  (ECHA  dissemination 
website) 

data 
to 

available 
pertain 
emission 
to 
strengths 
indoor  air  (35-
µg/h/m²) 
360 
to 
not 
and 
the 
in 
content 
articles 

unknown 

very 
limited 
number 
of 
occurrence 
(1 
in 
materials 
BUMA database) 

tonnage 
100 
- 
tonnes 
annum 

band: 
1,000 
per 

not  mentioned  in 
consulted 
sources 

Construction  materials 
database BUMA; 

emission 

not  mentioned  in 
consulted 
sources 

registration 

dossiers: 
REACH 
in  building  and 
substance  used 
(SU  19)  and 
construction  work 
relevant  ERCs  (ECHA  dissemination 
website) 

 
 
 
Substance 

EC-
number 

Use in construction articles  Likelihood/wide
spreadness  of 
in 
occurrence 
construction 
articles 

Concentration 
of  SVHC 
article? 

in 

Technical 
function 

Information source(s) of presence 
of this CMR 1A/1B in construction 
article 

19: 

building 

and 
SU 
construction  work;    and  ERC 
3,  ERC  5,  ERC6d,  ERC10a, 
ERC10b  or  ERC11a  or  a 
combination  of  these  ERCs; 
not further specified  

19: 

building 

SU 
and 
construction  work;    and  ERC 
3,  ERC  5,  ERC6d,  ERC10a, 
ERC10b  or  ERC11a  or  a 
combination  of  these  ERCs; 
not further specified  

19: 

building 

SU 
and 
construction  work;    and  ERC 
3,  ERC  5,  ERC6d,  ERC10a, 
ERC10b  or  ERC11a  or  a 
combination  of  these  ERCs; 
not further specified  

19: 

building 

SU 
and 
construction  work;    and  ERC 
3,  ERC  5,  ERC6d,  ERC10a, 
ERC10b  or  ERC11a  or  a 
combination  of  these  ERCs; 
not further specified 

19: 

building 

SU 
and 
construction  work;    and  ERC 
3,  ERC  5,  ERC6d,  ERC10a, 
ERC10b  or  ERC11a  or  a 
combination  of  these  ERCs; 
not further specified 

1,000  -  10,000 
tonnes 
per 
annum 

unknown 

not  mentioned  in 
consulted 
sources 

registration 

dossiers: 
REACH 
in  building  and 
substance  used 
construction  work 
(SU  19)  and 
relevant  ERCs  (ECHA  dissemination 
website) 

10  -  100  tonnes 
per annum 

unknown 

not  mentioned  in 
consulted 
sources 

registration 

dossiers: 
REACH 
in  building  and 
substance  used 
construction  work 
(SU  19)  and 
relevant  ERCs  (ECHA  dissemination 
website) 

1,000  -  10,000 
per 
tonnes 
annum 

unknown 

not  mentioned  in 
consulted 
sources 

registration 

dossiers: 
REACH 
in  building  and 
substance  used 
construction  work 
(SU  19)  and 
relevant  ERCs  (ECHA  dissemination 
website) 

10,000+  tonnes 
per annum 

unknown 

not  mentioned  in 
consulted 
sources 

registration 

dossiers: 
REACH 
in  building  and 
substance  used 
construction  work 
(SU  19)  and 
relevant  ERCs  (ECHA  dissemination 
website) 

100,000 
1,000,000 
tonnes 
annum 

- 

unknown 

per 

not  mentioned  in 
consulted 
sources 

registration 

dossiers: 
REACH 
in  building  and 
substance  used 
construction  work 
(SU  19)  and 
relevant  ERCs  (ECHA  dissemination 
website) 

Dibutyltin oxide 

212-449-1 

Dibutyltin 
di(acetate) 

213-928-8 

Tris 

213-934-0 

(2-
methoxyethoxy) 

vinylsilane 

Diantimony 
trioxide** 

215-175-0 

Zinc oxide*** 

215-222-5 

215 

 
Substance 

EC-
number 

Use in construction articles  Likelihood/wide
spreadness  of 
occurrence 
in 
construction 
articles 

Concentration 
of  SVHC 
article? 

in 

Technical 
function 

Information source(s) of presence 
of this CMR 1A/1B in construction 
article 

19: 

building 

SU 
and 
construction  work;    and  ERC 
3,  ERC  5,  ERC6d,  ERC10a, 
ERC10b  or  ERC11a  or  a 
combination  of  these  ERCs; 
not further specified  

19: 

building 

SU 
and 
construction  work;    and  ERC 
3,  ERC  5,  ERC6d,  ERC10a, 
ERC10b  or  ERC11a  or  a 
combination  of  these  ERCs; 
not further specified  

19: 

building 

SU 
and 
construction  work;    and  ERC 
3,  ERC  5,  ERC6d,  ERC10a, 
ERC10b  or  ERC11a  or  a 
combination  of  these  ERCs; 
not further specified 

19: 

building 

SU 
and 
construction  work;    and  ERC 
3,  ERC  5,  ERC6d,  ERC10a, 
ERC10b  or  ERC11a  or  a 
combination  of  these  ERCs; 
not further specified  

19: 

building 

and 
SU 
construction  work;    and  ERC 
3,  ERC  5,  ERC6d,  ERC10a, 
ERC10b  or  ERC11a  or  a 
combination  of  these  ERCs; 
not further specified  

10  -  100  tonnes 
per annum 

unknown 

not  mentioned  in 
consulted 
sources 

registration 

dossiers: 
REACH 
in  building  and 
substance  used 
construction  work 
(SU  19)  and 
relevant  ERCs  (ECHA  dissemination 
website) 

1,000,000 
10,000,000 
tonnes 
annum 

- 

unknown 

per 

not  mentioned  in 
consulted 
sources 

registration 

dossiers: 
REACH 
in  building  and 
substance  used 
construction  work 
(SU  19)  and 
relevant  ERCs  (ECHA  dissemination 
website) 

10,000 
100,000 
per annum 

- 
tonnes 

unknown 

not  mentioned  in 
consulted 
sources 

1,000  -  10,000 
tonnes 
per 
annum 

unknown 

not  mentioned  in 
consulted 
sources 

- 

100 
tonnes 
annum 

1,000 
per 

unknown 

not  mentioned  in 
consulted 
sources 

registration 

dossiers: 
REACH 
in  building  and 
substance  used 
construction  work 
(SU  19)  and 
relevant  ERCs  (ECHA  dissemination 
website) 

registration 

REACH 
dossiers: 
substance  used 
in  building  and 
(SU  19)  and 
construction  work 
relevant  ERCs  (ECHA  dissemination 
website) 

registration 

dossiers: 
REACH 
in  building  and 
substance  used 
construction  work 
(SU  19)  and 
relevant  ERCs  (ECHA  dissemination 
website) 

Dibutoxy-
dibutylstannane 

222-103-1 

Lead 

231-100-4 

Copper 
sulphate*** 

231-847-6 

Disodium 
octaborate 

234-541-0 

Dimethyl 
propylphosphona
te 

242-555-3 

216 

 
 
Substance 

EC-
number 

Use in construction articles  Likelihood/wide
spreadness  of 
in 
occurrence 
construction 
articles 

Concentration 
of  SVHC 
article? 

in 

Technical 
function 

Information source(s) of presence 
of this CMR 1A/1B in construction 
article 

Dibutylbis(penta
ne-2,4-dionato-
O,O')tin 

245-152-0 

19: 

building 

and 
SU 
construction  work;    and  ERC 
3,  ERC  5,  ERC6d,  ERC10a, 
ERC10b  or  ERC11a  or  a 
combination  of  these  ERCs; 
not further specified  

- 

100 
tonnes 
annum 

1,000 
per 

unknown 

not  mentioned  in 
consulted 
sources 

registration 

dossiers: 
REACH 
in  building  and 
substance  used 
construction  work 
(SU  19)  and 
relevant  ERCs  (ECHA  dissemination 
website) 

* Currently, the substance is included in Annex VI of the CLP Regulation as part of the group entry for cadmium compounds (Index number 048-001-00-5). The 
dossier  submitter  for  a  harmonised  classification  and  labelling  (CLH  dossier),  Sweden,  proposed  to  add  classification  for  carcinogenicity  (cat  1B);  germ  cell 
mutagenicity (cat 1B) and specific target organ toxicity to the existing harmonised classification. 

** The substance has a harmonised classification as CMR cat. 2 and a non-harmonised classification CMR 1A 

*** The substance has a harmonised classification but not as CMR, and a non-harmonised classification CMR 1A 

217 

 
 
ANNEX  2  –  MARKET  SURVEY  ON  CONSTRUCTION  ARTICLES  (CONTAINS 

CONFIDENTIAL INFORMATION AND MAY NOT BE DISTRIBUTED) 

European Commission – DG Environment 

SCOPING STUDY FOR THE APPLICATION OF ARTICLE 68(2) OF 
REACH TO CONSTRUCTION ARTICLES CONTAINING CMR 
SUBSTANCES WITH LIKELIHOOD OF CONSUMER EXPOSURE 
CMR MARKET SURVEY 

Final report 

June 2015 

Cide-Socran asbl 
Parking Saint-Denis (7ème étage) | Rue Lambert Lombard, 3 | 4000 Liège 

T : +32 4 220 56 00 | F : +32 4 220 56 09 | www.cide-socran.be 

218 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 3: CRITERIA FOR LIKELIHOOD OF EXPOSURE TO SUBSTANCES PRESENT IN CONSTRUCTION ARTICLES  

TASK 2: list of substances an applications in construction articles 

TASK 3: criteria supporting the likelihood of presence/absence of consumer exposure arising from construction articles 

substance 

EC-number 

use in construction 
articles 

technical 
function 

criterion 1: presence of 
CMR in construction 
article 

criterion 2: emissions of CMR 
from construction articles   
 (test chamber method CEN/TS 
16516 or similar method) 

criterion 3: estimated exposure 

criterion 4: measured indoor exposure 

criterion 5: source apportioning 
data?    
(only relevant if data on criterion 
4) 

group no 

group name 

Aluminosilicate 
Refractory Ceramic 
Fibres are fibres 
covered by index 
number 650-017-00-8 
in Annex VI 

use in stone, plaster, 
cement, glass and ceramic 
articles 

not mentioned 
in consulted 
sources 

assumed to be present in 
levels >  0.1 %  
(SVHC notification)  

no data 
substance not in spectrum of 
CEN/TS 16516 

no data 

no data 
(substance not measured in indoor 
monitoring campaigns) 

not relevant since lack of data on 
indoor exposure 

group 5 

CMR substances for which there is 
evidence of presence in CA, and with a 
high likelihood of consumer exposure, 
and widespread exposure in the EU   

formaldehyde is 
used in the 
production of 
resins that act 
as glues used 
for 
manufacturing 
of construction 
articles 

assumed to be present in 
construction articles   
(REACH registered use SU 
19 )  

yes: emission rates at 28 days 
testing from several floor 
covering materials  reported (0-
45 µg/h/m²) 

yes, consumer/professional (installer) 
inhalation exposure and estimated 
based on emission rates, and 
ventilation rates and materials loading 
of  CEN/TS 16516 (see Table 33) 

yes: numerous data on monitoring of 
formaldehyde in EU buildings (mainly 
dwellings):   
average range: 15 - 40 µg/m³  

yes: emission rates at 28 days 
testing from several gypsum 
based articles reported (0-85 
µg/h/m²) 

yes: emission rates at  28 days 
testing from several wood based 
panels reported (2-108 µg/h/m²) 

yes: emission rates at  28 days 
testing from glass fibre wall 
paper reported (25 µg/h/m²) 

emission rates at  28 days testing 
from one XPS thermal insulation 
material reported (0 µg/h/m²) 

group 1 

CMR substances for which there is 
evidence of presence in CA, and with a 
high likelihood of consumer exposure, 
and widespread exposure in the EU   

yes: construction articles identified 
as important source of indoor 
formaldehyde 
 (e.g. Missia: 12 % formaldehyde 
indoor comes from laminate 
flooring)  
other types of construction articles 
as important sources for indoor 
formaldehyde exposure: insulating 
materials, particleboards 
containing formaldehyde-based 
resins (INDEX study, 2005) 

Formaldehyde 

200-001-8 

Resilient, textile and 
laminate floor coverings 

Gypsum and gypsum 
based products 

Round and sawn timber 

Wood based panels 

Wall covering 

Thermal insulation 
materials 

SU 19: building and 
construction work;  ERC 3 
(formulation in materials); 
not further specified 

Resilient, textile and 
laminate floor coverings 

Dimethyl formamide 

200-679-5  

not mentioned 
in consulted 
sources 

Not assume to be present 
in levels > 0.1 % (no 
notifications or relevant 
registrations)   

yes: emission data for 1 tested 
material (BUMA): 10 µg/m²/h  

no data 

no data 

not relevant since lack of data on 
indoor exposure 

Benzene 

200-753-7  

Resilient, textile and 
laminate floor coverings 

not mentioned 
in consulted 
sources 

Not assumed to be present 
in levels > 0.1 % (no 
relevant notifications or 
registrations )   

yes: emission rates (28 days test 
chamber) from resilient floorings: 
0- 2 µg/m²/h 

yes, consumer/professional (installer) 
inhalation exposure estimated based on 
emission rates, and ventilation rates 
and materials loading of  CEN/TS 16516 
(see Table 33) 

yes:  numerous monitoring data of 
benzene in EU buildings (mainly 
dwellings):   
average range in EU: 2 - 30 µg/m³   

Gypsum and gypsum 
based products 

Round and sawn timber 

219 

yes: emission rates (28 days test 
chamber) from gypsum based 
articles: 0- 7 µg/m²/h 

construction articles to be likely a 
minor source of indoor pollution 
(e.g. linoleum and laminate up to 3-  
10 % ; Missia et al., 2012); 
outdoor air is main source of 
indoor benzene (e.g. I/O ratio's 
Airmex study) 
Main indoor sources are cigarette 
smoking; not construction articles 
(INDEX study, 2005) 

group 3C 

group 3B 

CMR substances for which there is no 
evidence that the substances are are  
present in CA ; though these substances 
have been demonstrated to be released 
from CA,  (e.g. as a result of secondary 
reactions, or from impurities) 

(not possible to assess the extent of 
exposure 

 CMR substances for which there is 
evidence of presence in CA, and with a 
high likelihood of consumer exposure, 
and widespread exposure in the EU   

 
  
  
  
 
  
  
  
  
  
  
 
 
  
  
  
  
  
  
  
  
 
  
  
  
  
  
 
 
 
  
  
Wood based panels 

Wall covering 

painted articles 

SU 19: building and 
construction work;  ERC 5 
(industrial use resulting in 
inclusion into or onto a 
matrix); not further 
specified 

Resilient, textile and 
laminate floor coverings 

Ethylene oxide  

200-849-9  

Trichloroethylene 

201-167-4  

TASK 2: list of substances an applications in construction articles 

TASK 3: criteria supporting the likelihood of presence/absence of consumer exposure arising from construction articles 

substance 

EC-number 

use in construction 
articles 

technical 
function 

criterion 1: presence of 
CMR in construction 
article 

criterion 3: estimated exposure 

criterion 4: measured indoor exposure 

criterion 5: source apportioning 
data?    
(only relevant if data on criterion 
4) 

group no 

group name 

criterion 2: emissions of CMR 
from construction articles   
 (test chamber method CEN/TS 
16516 or similar method) 

yes: emission rates (28 days test 
chamber) from wood based 
panels: 0- 30 µg/m²/h 

yes: emission rates (28 days test 
chamber) from wall coverings: 0- 
2 µg/m²/h 

not mentioned 
in consulted 
sources 

assumed to be present in 
levels > 0.1 % (registered 
use SU 19)   

no emission data found for 
ethylene oxide  
ethylene oxide is within the 
spectrum of CEN/TS 16516 

no data  

no data 

not relevant since lack of data on 
indoor exposure 

group 7 

CMR substances for which there is 
evidence of presence in CA with (very) 
low likelihood of consumer exposure 

not mentioned 
in consulted 
sources 

assumed to be present in 
levels > 0.1 % (registered 
use SU 19)  
anticipated not to be 
present  > 0.1 % after 
sunset date (21/04/2016)  
since no authorized use in 
domain of construction 
articles   

yes: limited data for 2 materials 
at 3 days emissions from resilient 
flooring: 3 µg/h/m² 

yes, professional (installation) 
inhalation exposure estimated based on 
3days emission rates, and ventilation 
rates and materials loading of  CEN/TS 
16516 (see Table 33 

yes: trichloroethylene (TCE) was 
measured in Helsinki (EXPOLIS study; 
Edwards et al., 2001). In 97 % of the 
indoor environments, TCE was not 
detected. The maximum level of TCE 
was 41 µg/m³ in one dwelling 

Indoor levels of trichloroethylene 
are commonly ≥3 times higher than 
outdoor levels due to releases from 
building materials and consumer 
products (ATSDR, 2011) 

group 3B 
* 

CMR  substances  for  which  there  is  no 
evidence  that  the  substances  are  are  
present in CA ; though these substances 
have been demonstrated to be released 
from  CA,   (e.g.  as  a  result  of  secondary 
reactions,  or 
; 
from 
*:  CMR  substances  anticipated  not  be 
present in CA after sunset data 

impurities) 

Wood based panels 

not possible to identify 
type of construction article 
in which it is used 

not mentioned 
in consulted 
sources 

no authorized use in 
domain of construction 
article (sunset date: 
21/04/2016) 

Construction articles as a 
source of TCE are not 
mentioned in the RAR  

Di-isobutyl phthalate 

201-553-2  

wall covering  

plasticizer 

assumed to be present in 
levels > 0.1 % (relevant 
notifications) 

yes: emission rates (10 days) 
from 2 vinyl wall coverings: 0.12 - 
0.46 µg/m²/h 

anticipated not to be 
present  > 0.1 % after 
sunset date (21/02/2015)  
since no authorized use in 
domain of construction 
articles   

yes, consumer/professional (installer) 
inhalation exposure and estimated 
based on emission rates, and 
ventilation rates and materials loading 
of  CEN/TS 16516 (see Table 33) 

consumer exposure via ingestion of 
dust, inhalation of air and dermal 
exposure (surfaces, air, dust); indoor 
sources (air, and dust) approximately 50 
% of total exposure (Beko et al., 2013) 

yes: DiBP was detected in indoor air and 
indoor dust in 30 dwellings in a French 
monitoring campaign in 2011 
settled dust (100 % detections): 8 - 227 
µg/g; indoor gas phase (100 % 
detections): 43- 2690 ng/m³; airborne 
particles (93 % detections): <5 -115 
ng/m³  

yes: Weschler et al.(2006) and Beko 
et al. (2013)  demonstrated that 
ingestion of dust, inhalation of air 
and dermal contact   has a 
significant contribution to 
aggregate exposure of DIPB. 
No studies demonstrating 
relationship between presence of 
construction materials (e.g. 
floorings) and DiPB in dust and air 
found; however, for other 
phthalates this relationship was 
demonstrated (e.g.; see DEHP and 
BBzP), and is potentially similar for 
DiPB 

group 1* 

CMR substances for which there is 
evidence of presence in CA, and with a 
high likelihood of consumer exposure, 
and widespread exposure in the EU   
*: CMR substances anticipated not be 
present in CA after sunset data 

cat 8: floor covering: PVC 
floor covering (cushion 
vinyl) 

no authorized use in 
domain of construction 
article (sunset date: 
21/02/2015) 

220 

 
 
  
  
  
  
  
 
 
  
  
  
  
  
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
  
  
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
 
 
  
  
  
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
TASK 2: list of substances an applications in construction articles 

TASK 3: criteria supporting the likelihood of presence/absence of consumer exposure arising from construction articles 

substance 

EC-number 

use in construction 
articles 

technical 
function 

Di butylphthalate  

201-557-4  

wall covering  

plasticizer 

criterion 2: emissions of CMR 
from construction articles   
 (test chamber method CEN/TS 
16516 or similar method) 

yes: emission rates (28 - 180 
days) from PVC and linoleum 
flooring and vinyl wall covering 
(0.8 - 32 µg/m³/h) 

criterion 1: presence of 
CMR in construction 
article 

assumed to be present in 
levels > 0.1 % (relevant 
notifications) 

anticipated not to be 
present  > 0.1 % after 
sunset date (21/02/2015)  
since no authorized use in 
domain of construction 
articles   

criterion 3: estimated exposure 

criterion 4: measured indoor exposure 

yes, consumer/professional (installer) 
inhalation exposure and estimated 
based on emission rates, and 
ventilation rates and materials loading 
of  CEN/TS 16516 (see Table 33) 

 consumer exposure via ingestion of 
dust, inhalation of air and dermal 
exposure (surfaces, air, dust):  
 indoor sources (air, and dust) 
approximately 15 % of total exposure 
(Beko et al., 2013) (Wormuth et al., 
2006; Beko et al., 2013) 

yes:  dibutylphthalate was detected in 
indoor air and indoor dust in 30 
dwellings in a French monitoring 
campaign in 2011 
settled dust (97 % detections): <0.71 - 
59.7 µg/g; indoor gas phase (97 % 
detections): <10- 234 ng/m³; airborne 
particles (100 % detections): 2.9 -57.8 
ng/m³  

criterion 5: source apportioning 
data?    
(only relevant if data on criterion 
4) 

yes: Weschler et al.(2006) and Beko 
et al. (2013)  demonstrated that 
ingestion of dust, inhalation of air 
and dermal contact   has a 
significant contribution to 
aggregate exposure of di 
butylphthalate. 
No studies demonstrating 
relationship between presence of 
construction materials (e.g. 
floorings) and di butylphthalate  in 
dust and air found; however, for 
other phthalates this relationship 
was demonstrated (e.g.; see DEHP 
and BBzP), and is potentially similar 
for di butylphthalate  

group no 

group name 

group 1* 

CMR substances for which there is 
evidence of presence in CA, and with a 
high likelihood of consumer exposure, 
and widespread exposure in the EU   
*: CMR substances anticipated not be 
present in CA after sunset data 

plasticizer 

cat 1: used in roll doors 

other: insulation and 
sealing materials in 
airconditioning units and 
heat pumps 
tarpaulin covers (roofing) 

no authorized use in 
domain of construction 
article (sunset date: 
21/02/2015) 

Benzylbutylphthalate 

 201-622-7   

cat 8: flooring material 

plasticizer 

No authorized use in 
domain of construction 
articles (sunset date: 
21/02/2015) 

confirmed to be present in 
levels > 0.1 % (Article 33 
request) 

anticipated not to be 
present  > 0.1 % after 
sunset date (21/02/2015)  
since no authorized use in 
domain of construction 
articles   

no emission data found  
benzylbutylphthalate is not 
included in the regulated 
carcinogenic (S)VOCs categories 
1A & 1B according to the prEN 
16516 emission testing protocol 

consumer exposure via ingestion of 
dust, inhalation of air and dermal 
exposure (surfaces, air, dust) (Wormuth 
et al., 2006; Beko et al., 2013) 
indoor sources have a small 
contribution to aggregate exposure for 
adults, however, for infants and 
toddlers: significant contribution 
(Wormuth et al.,2006) 

yes:  dibutylphthalate was detected in 
indoor air and indoor dust in  various 
studies in the EU (Germany, France) 
e.g. total airborne levels: 19 (median) - 
57 ng/m³ (Fromme et al., 2008); settled 
dust: median values ranging from 13 - 
30 mg/kg 
French study settled dust (100 % 
detections): 0.17 - 79.5 µg/g; indoor gas 
phase (23 % detections): <1.3- 6.5 
ng/m³; airborne particles (100 % 
detections): 1.1 -14.6 ng/m³  

yes: Bornehag et al.(2004) 
demonstrated an association 
between BBzP in dust and the 
amount of PVC used as flooring and 
wall material in the home 

group 1* 

CMR substances for which there is 
evidence of presence in CA, and with a 
high likelihood of consumer exposure, 
and widespread exposure in the EU   
*: CMR substances anticipated not be 
present in CA after sunset data 

Acrylonitrile 

203-466-5  

SU 19: building and 
construction work;  ERC 3 
(formulation in materials); 
not further specified 

not mentioned 
in consulted 
sources 

assumed to be present in 
levels > 0.1 % (registered 
use relevant for 
construction articles)   

no emission data found  
acrylonitrile is included in the 
regulated carcinogenic VOCs 
categories 1A & 1B according to 
the prEN 16516 emission testing 
protocol 

no data 

no data for buildings in the EU 
in an US study (Montana): in all of 50 
monitored non-smoking dwellings, 
acrylonitrile was below detection limit 

no data found (not relevant since 
no exposure in indoor arising from 
construction articles is probably 
negligible)  

group 7  

CMR  substances  for  which  there 
is 
evidence  of  presence  in  CA  with  (very) 
low likelihood of consumer exposure 

221 

 
  
  
  
  
  
 
 
  
  
  
 
 
 
 
 
 
  
  
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
TASK 2: list of substances an applications in construction articles 

TASK 3: criteria supporting the likelihood of presence/absence of consumer exposure arising from construction articles 

substance 

EC-number 

use in construction 
articles 

technical 
function 

2 ethoxyethanol 

 203-804-1   

Resilient, textile and 
laminate floor coverings 

formed as a 
degradation 
product from 
PVC flooring 
and water-
based glue  

criterion 1: presence of 
CMR in construction 
article 

assumed not to be present 
in levels > 0.1 % (no 
relevant notifications or  
registrations)   

criterion 2: emissions of CMR 
from construction articles   
 (test chamber method CEN/TS 
16516 or similar method) 

yes: emission data from 19 PVC 
flooring materials (tested at 28 
days): median value: 5 µg/h/m² 

criterion 3: estimated exposure 

criterion 4: measured indoor exposure 

criterion 5: source apportioning 
data?    
(only relevant if data on criterion 
4) 

group no 

group name 

yes, consumer/professional (installer) 
inhalation exposure and estimated 
based on emission rates, and 
ventilation rates and materials loading 
of  CEN/TS 16516 (see Table 33) 

no data 

not relevant since lack of data on 
indoor exposure 

group 3C 

CMR substances NOT present in CA in 
levels > 0.1 %; though released from  
CA;  not possible to assess the extent of 
exposure  

wood based panels 

from the information in 
the EU RAR, it is deduced 
that construction articles 
treated with inks or 
lacquers may  contain 2 
ethoxy-ethanol 

use in stone, plaster, 
cement, glass and ceramic 
articles 

Tris(2-
chloroethyl)phosphate 

204-118-5  

Impurity 
formed as a 
reaction by-
product in the 
manufacture of 
other 
commercial 
flame 
retardants  

assumed to be present in 
levels > 0.1 % (relevant 
notifications) 

anticipated not to be 
present  > 0.1 % after 
sunset date (21/08/2015)  
since no authorized use in 
domain of construction 
articles   

no data found  
Tris(2-chloroethyl)phosphate is 
not included in the regulated 
carcinogenic (S)VOCs categories 
1A & 1B according to the prEN 
16516 emission testing protocol 

no data 

no data for dwellings in EU 
data of 60 dwellings in Canada: average 
0.79 µg/g settled dust (Fan et al., 2014) 

no data  

group 4*   CMR  substances  for  which  there 

is 
evidence  of  presence  in  CA;  available 
information  indicates  that  exposure  is 
possible;  more  data  needed 
for 
confirmation and to assess the extent of 
exposure 
*:  CMR  substances  anticipated  not  be 
present in CA after sunset data   

roof insulation 

SU 19: building and 
construction work;  ERC 
10a (Wide dispersive 
outdoor use of long-life 
articles and materials with 
low release; not further 
specified 

No authorized use in 
domain of construction 
articles (sunset date: 
21/08/2015) 

cat. 1: doors, windows, 
shutters, building 
hardware and curtain 
walling: fence roll doors, 
seals for windows, doors, 
wooden doors 

not mentioned 
in consulted 
sources 

plasticizer 

Bis (2-
ethylhexyl)phthalate 
(DEHP) 

204-211-0  

cat 8: floor covering made 
by PVC, flooring 
plastic floor tiles 
plastic flooring 
PVC floor coverings 
(cushion vinyl 

others: tarpaulin covers 
(as roofing) 
shower hoses (sanitary 

222 

yes: DEHP emission from vinyl 
flooring and wall paper : 0 - 1 
µg/m²/h (14 days) (Uhde et al., 
2001) and up to 7   µg/m²/h (700 
days) 

assumed to be present in 
levels > 0.1 % (relevant 
notifications) 
confirmed by monitoring 
data (e.g. Clausen et 
al.,2015: 176 mg/cm³ in 
PVC flooring) 
authorized use of DEHP in 
manufacturing of PVC 
articles, of which several 
used in construction 

yes, consumer/professional (installer) 
inhalation exposure and estimated 
based on emission rates, and 
ventilation rates and materials loading 
of  CEN/TS 16516 (see Table 33) 
 consumer exposure via ingestion of 
dust, inhalation of air and dermal 
exposure (surfaces, air, dust) (Wormuth 
et al., 2006; Beko et al., 2013) 
indoor sources have a small 
contribution to aggregate exposure for 
adults, however, for infants and 
toddlers: significant contribution 
(Wormuth et al.,2006) 

yes:  DEHP was detected in indoor air 
and indoor dust in  various studies in 
the EU (Germany, France, Denmark) 
e.g. total airborne levels: 126 ng/m³ 
(median) -  368 ng/m³ (P95)(Fromme et 
al., 2008); settled dust: median values 
ranging from 480 - 1050 mg/kg 
French study settled dust (100 % 
detections): 13 - 1520g; indoor gas 
phase (10%  detections): <10- 20.2 
ng/m³; airborne particles (100 % 
detections): 21.7 -158 ng/m³  

yes: Bornehag et al.(2004) 
demonstrated an association 
between DEHP in dust and the 
amount of PVC used as flooring and 
wall material in the home 

Xu et al. (2010) predicted 
residential exposure to DEHP from 
vinyl flooring, and comparison with 
biomonitoring data  

group 1 

CMR substances for which there is 
evidence of presence in CA, and with a 
high likelihood of consumer exposure, 
and widespread exposure in the EU   

 
 
  
  
  
  
  
  
  
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
 
 
 
 
 
 
  
  
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
TASK 2: list of substances an applications in construction articles 

TASK 3: criteria supporting the likelihood of presence/absence of consumer exposure arising from construction articles 

substance 

EC-number 

use in construction 
articles 

technical 
function 

criterion 1: presence of 
CMR in construction 
article 

criterion 2: emissions of CMR 
from construction articles   
 (test chamber method CEN/TS 
16516 or similar method) 

criterion 3: estimated exposure 

criterion 4: measured indoor exposure 

criterion 5: source apportioning 
data?    
(only relevant if data on criterion 
4) 

group no 

group name 

appliances 

authorized use of DEHP in 
manufacturing of PVC 
articles, of which several 
used in construction (e.g. 
PVC flooring, window 
frames, plastic pipes) 

Resilient, textile and 
laminate floor coverings 

Chloroprene 

204-818-0  

not mentioned 
in consulted 
sources 

assumed not to be present 
in levels > 0.1 % (no 
relevant notifications or  
registrations)   

emission data (3 days testing) 
from 'plastic laminate assembly' 
from 2 materials: 2 - 120 µg/h/m² 

yes, consumer/professional (installer) 
inhalation exposure and estimated 
based on emission rates, and 
ventilation rates and materials loading 
of  CEN/TS 16516 (see Table 33) 

no data found 

not relevant since lack of data on 
indoor exposure 

group 3C 

N,N-dimethyl 
acetamide 

204-826-4  

gypsum and gypsum based 
products 

not mentioned 
in consulted 
sources 

assumed not to be present 
in levels > 0.1 % (no 
relevant notifications or  
registrations)   

emission data from 1 plaster 
based material : 6.3 µg/h/m² (day 
3 ) and 0 µg/h/m² (day 28) 

yes, consumer/professional (installer) 
inhalation exposure and estimated 
based on emission rates, and 
ventilation rates and materials loading 
of  CEN/TS 16516 (see Table 33) 

0.1 ppm N,N-dimethyl acetamide 
measured in 3 offices in Bucharest 
(Vasile, 2015) 

no data found 

group 3C 

none of the uses in the 
notification dossier  could 
be related construction 
articles 

Dipentylphthalate 

210-088-4  

wall coverings 

plasticizer 

assumed not to be present 
in levels > 0.1 % (no 
relevant notifications or  
registrations)   

emission data from 3 vinyl wall 
coverings: 0.8 -2 µg/m²/h (tested 
at 8 days) - no data for 28 days 

yes, consumer/professional (installer) 
inhalation exposure and estimated 
based on emission rates, and 
ventilation rates and materials loading 
of  CEN/TS 16516 (see Table 33) 

no data found 

not relevant since lack of data on 
indoor exposure 

group 3C 

1-Methyl -2- 
pyrrolidone 

212-828-1  

Resilient, textile and 
laminate floor coverings 

not mentioned 
in consulted 
sources 

assumed to be present in 
levels > 0.1 % (notification 
for confidential use, 
potentially relevant for 
construction articles)   

emission data for 4 PVC floorings: 
19-69 µg/m²/h (28 days test) 

yes, consumer/professional (installer) 
inhalation exposure and estimated 
based on emission rates, and 
ventilation rates and materials loading 
of  CEN/TS 16516 (see Table 33) 

no data found  

not relevant since lack of data on 
indoor exposure 

group 4 

CMR substances for which there is no 
evidence that the substances are are  
present in CA ; though these substances 
have been demonstrated to be released 
from CA,  (e.g. as a result of secondary 
reactions, or from impurities) not 
possible to assess the extent of 
exposure 

CMR substances for which there is no 
evidence that the substances are are  
present in CA ; though these substances 
have been demonstrated to be released 
from CA,  (e.g. as a result of secondary 
reactions, or from impurities) not 
possible to assess the extent of 
exposure 

CMR substances for which there is no 
evidence that the substances are are  
present in CA ; though these substances 
have been demonstrated to be released 
from CA,  (e.g. as a result of secondary 
reactions, or from impurities) not 
possible to assess the extent of 
exposure 

CMR substances present in CA (>0.1 %); 
available information indicates that 
exposure is possible; more data needed 
for confirmation  and to assess the 
extent of exposure  

impurity 

maybe there are some 
additional uses not 
mentioned in notification 
dossier (confidential uses) 

from the information in 
the EU RAR, it is deduced 
that construction articles 
treated with inks or 
lacquers may  contain 1-
vinyl-2-pyrrolidone 

No authorized use in 
domain of construction 
articles (sunset date: 
21/05/2015) 

223 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
TASK 2: list of substances an applications in construction articles 

TASK 3: criteria supporting the likelihood of presence/absence of consumer exposure arising from construction articles 

substance 

EC-number 

use in construction 
articles 

technical 
function 

Diboron trioxide 

 215-125-8   

use in stone, plaster, 
cement, glass and ceramic 
articles 

not mentioned 
in consulted 
sources 

criterion 1: presence of 
CMR in construction 
article 

assumed to be present in 
levels > 0.1 % 
(registrations relevant for 
construction articles)   

criterion 2: emissions of CMR 
from construction articles   
 (test chamber method CEN/TS 
16516 or similar method) 

no emission data found 
diboron trioxide is not included 
in the regulated carcinogenic 
(S)VOCs categories 1A & 1B 
according to the prEN 16516 
emission testing protocol 

criterion 3: estimated exposure 

criterion 4: measured indoor exposure 

no data 

no data 

criterion 5: source apportioning 
data?    
(only relevant if data on criterion 
4) 

group no 

group name 

not relevant since lack of data on 
indoor exposure 

group 5  

CMR substances for which there is 
evidence of presence in CA for which no 
assessment is possible 

service life of cellulose 
insulation (cat. 3) 

SU 19: building and 
construction work;  ERC 3 
(formulation in materials); 
not further specified 

SU 19: building and 
construction work;  ERC 3 
(formulation in materials); 
not further specified 

not mentioned 
in consulted 
sources 

Cadmium oxide  

215-146-2  

assumed to be present in 
levels > 0.1 % 
(registrations relevant for 
construction articles)   
EU RAR CdO mentions 
brazing materials 
containing up to 20 % Cd 
can be purchased by 
consumers in do-it-
yourself shops 

no emission data found 
cadmium oxide is not included in 
the regulated carcinogenic 
(S)VOCs categories 1A & 1B 
according to the prEN 16516 
emission testing protocol 

EU  RAR  Cd:  consumer  uses  of  brazing 
material are likely to be infrequent and 
duration  of  exposure  is  expected  to  be 
shorter  than  in  an  industrial  setting.  In 
case  of  use  by  the  consumer  of  such 
brazing 
inhalation 
exposure 
considered.” 
However,  no    quantitative  data  of  such 
exposure were found in the RAR 

sticks,  mainly 
should  be 

no data for cadmium oxide  found; 
monitoring data of  elemental Cd in 
indoor dust described in the literature; 
e.g. in France: 473 indoor dust samples: 
most samples were below DL (0.8 
µg/m²; max. value: 11 µg Cd/m²) 
(Glorennec et al., 2012) 
in a review paper on metals in dust, 
Ibanez et al. (2010) reported a range of 
0.6 - 64 µg Cd/g house settled dust  

group 6 

CMR  substances  for  which  there 
is 
evidence of presence in CA with indirect 
evidence for low likelihood of consumer 
exposure 

indoor construction materials are 
not likely to be a major source of 
Cd  in indoor dust; 
we did not found an in-depth 
source apportioning study, instead 
some general descriptions lead us 
to above conclusion:" metal  
concentrations in dust 
may be influenced by outdoor 
environment, because they mainly 
originate from soil (Mn, V 
(Fergusson et al., 1986)), from 
traffic and notably brakes (Cu, Sb 
(Amato et al., 2009)). But indoor 
dust concentrations 
depend also on building (ex: paint 
(Mielke et al., 2001)) or furnishing 
materials (carpets: Cr, Cd (Kim and 
Fergusson, 1993)), 
and on human behaviours such as 
smoking (Cr, Cd (Madany et 
al.,1994)), cooking and cleaning 
habits." 
In the review paper of Ibanez et al. 
(2010), carpet, galvanized roofs, 
busy roads were described as 
factors influencing Cd 
concentrations in house settled 
dust.  
 Besides 'galvanise roofs', no other 
construction articles are mentioned 
as a source of metals in indoor dust 

use in ceramics, glasses, 
enamels and  plastics 

Orange lead (lead 
tetroxide) 

215-235-6  

consumer use of ceramics 
(cat 2) 

pigments and 
stabilizers to 
retard 
degradation 
process in PVC 

pigment 

224 

assumed to be present in 
levels > 0.1 % (notifications 
relevant for construction 
articles)   

no emission data found 
orange lead is not included in the 
regulated carcinogenic (S)VOCs 
categories 1A & 1B according to 
the prEN 16516 emission testing 
protocol 

no data 

no data on orange lead; 
monitoring data on elemental Pb in 
indoor dust described in literature; e.g. 
a wide range  Pb levels in indoor dust 
was reported. (e.g. ranging from 
median value of 5.9 µg/g in Germany 
background areas to nearly 1000 µg/g 
(UK)(source: Pb  VRAR, 2005)  

Lucas et al.(2014) investigated the 
sources of lead in residential floor 
dust. Main identified sources were:  
outdoor sources (air), lead based 
painting, track-in of exterior soil, 
sites of pollution in the vicinity and 
demolition of nearby old buildings. 
Indoor sources: smoking and lead-
based paint in old, non-renovated 
buildings. Indoor use of 
construction articles were not 
mentioned as source of Pb in 

group 6 

CMR  substances  for  which  there 
is 
evidence of presence in CA with indirect 
evidence for low likelihood of consumer 
exposure 

 
 
  
  
  
  
  
  
  
  
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
TASK 2: list of substances an applications in construction articles 

TASK 3: criteria supporting the likelihood of presence/absence of consumer exposure arising from construction articles 

substance 

EC-number 

use in construction 
articles 

technical 
function 

Lead sulfochromate 
yellow (C.I. Pigment 
Yellow 34) 

215-693-7  

cat 1: fences: roll doors 

pigment 

criterion 1: presence of 
CMR in construction 
article 

criterion 2: emissions of CMR 
from construction articles   
 (test chamber method CEN/TS 
16516 or similar method) 

assumed to be present in 
levels > 0.1 % (notifications 
potentially relevant for 
construction articles)   
authorized use  potentially 
indirectly relevant for 
construction articles 

no emission data found 
Lead sulfochromate yellow is not 
included in the regulated 
carcinogenic (S)VOCs categories 
1A & 1B according to the prEN 
16516 emission testing protocol 

criterion 3: estimated exposure 

criterion 4: measured indoor exposure 

no data  

no data for lead sulfochromate yellow  
found; 
monitoring data of  elemental Cr and 
elemental Pb  in indoor dust described 
in the literature; for data on Pb: see 
above lines; for data on Cr: e.g. in 
France: 473 indoor dust samples: most 
samples were below DL (10 µg/m²;P90 
value: 14 µg/m² max. value: 121 µg 
Cr/m²) (Glorennec et al., 2012) 
in a review paper on metals in dust, 
Ibanez et al. (2010) reported a range of 
11 301 µg Cr/g house settled dust  

group no 

group name 

group 6 

CMR  substances  for  which  there 
is 
evidence of presence in CA with indirect 
evidence for low likelihood of consumer 
exposure 

criterion 5: source apportioning 
data?    
(only relevant if data on criterion 
4) 

residential dust  

indoor construction materials are 
not likely to be a major source of Cr 
and Pb  in indoor dust; (for data on 
Pb: see above); for Cr: 
we did not found an in-depth 
source apportioning study, instead 
some general descriptions lead us 
to above conclusion:" metal  
concentrations in dust 
may be influenced by outdoor 
environment, because they mainly 
originate from soil (Mn, V 
(Fergusson et al., 1986)), from 
traffic and notably brakes (Cu, Sb 
(Amato et al., 2009)). But indoor 
dust concentrations 
depend also on building (ex: paint 
(Mielke et al., 2001)) or furnishing 
materials (carpets: Cr, Cd (Kim and 
Fergusson, 1993)), 
and on human behaviours such as 
smoking (Cr, Cd (Madany et 
al.,1994)), cooking and cleaning 
habits." 
In the review paper of Ibanez et al. 
(2010), granulometry of dust is 
described as factor influencing Cr 
concentrations in house settled 
dust.  
No  construction articles are 
mentioned as a source of Cr in 
indoor dust 

service life of coated 
articles: stone, plaster, 
cement, glass and ceramic 
articles  

cat 6: pigments in articles 
(wood) 

other: tarpaurin covers 
(e.g. roofing) 

SU 19: building and 
construction work;  ERC 3 
(formulation in materials); 
not further specified 

authorized use which is 
potentially indirectly 
relevant for construction 
article (authorized use: 
Distribution and mixing 
pigment powder in an 
industrial environment 
into solvent-based paints 
for non-consumer )use 

Nickel used in production 
of stainless steel (with 
uses of steel in 
construction sector) 

Nickel 

231-111-4  

225 

nickel present (8-12 %) in 
stainless steel; several 
construction articles have 
stainless steel parts 

no emission data found 
nickel is not included in the 
regulated carcinogenic (S)VOCs 
categories 1A & 1B according to 
the prEN 16516 emission testing 
protocol 

the EU RAR on nickel substances dealing 
with consumer exposure does not 
include a consumer exposure scenario 
related to construction articles  

monitoring data for Ni in household 
dust:  
several data on Ni  in indoor dust 
described in the literature; r: e.g. in 
France:  
in a review paper on metals in dust, 

indoor construction materials are 
not likely to be a major source of Ni   
in indoor dust 
we did not found an in-depth 
source apportioning study, instead 
some general descriptions lead us 

group 6 

CMR  substances  for  which  there 
is 
evidence of presence in CA with indirect 
evidence for low likelihood of consumer 
exposure 

 
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
  
 
  
  
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
  
  
  
  
  
  
  
  
 
 
  
TASK 2: list of substances an applications in construction articles 

TASK 3: criteria supporting the likelihood of presence/absence of consumer exposure arising from construction articles 

substance 

EC-number 

use in construction 
articles 

technical 
function 

criterion 1: presence of 
CMR in construction 
article 

criterion 2: emissions of CMR 
from construction articles   
 (test chamber method CEN/TS 
16516 or similar method) 

criterion 3: estimated exposure 

criterion 4: measured indoor exposure 

Ibanez et al. (2010) reported a range of 
10 -  167 µg µ Ni/g settled housedust  

group no 

group name 

criterion 5: source apportioning 
data?    
(only relevant if data on criterion 
4) 

to above conclusion:" metal  
concentrations in dust 
may be influenced by outdoor 
environment, because they mainly 
originate from soil (Mn, V 
(Fergusson et al., 1986)), from 
traffic and notably brakes (Cu, Sb 
(Amato et al., 2009)). But indoor 
dust concentrations 
depend also on building (ex: paint 
(Mielke et al., 2001)) or furnishing 
materials (carpets: Cr, Cd (Kim and 
Fergusson, 1993)), 
and on human behaviours such as 
smoking (Cr, Cd (Madany et 
al.,1994)), cooking and cleaning 
habits." 

In none of the reviews on Ni in 
dust, we found  construction 
articles mentioned as a source of Ni 
in indoor dust 

Beryllium 

231-150-7  

SU 19: building and 
construction work;  ERC 3 
(formulation in materials); 
not further specified 

not mentioned 
in consulted 
sources 

assumed to be present in 
levels > 0.1 % 
(registrations potentially 
relevant for construction 
articles)   

Cadmium 

231-152-8  

SU 19: building and 
construction work;  ERC 3 
(formulation in materials); 
not further specified 

pigments and 
stabilizers to 
retard 
degradation 
process in PVC 

assumed to be present in 
levels > 0.1 % 
(registrations  relevant for 
construction articles)   

no emission data found 
beryllium is not included in the 
regulated carcinogenic (S)VOCs 
categories 1A & 1B according to 
the prEN 16516 emission testing 
protocol 

no emission data found 
cadmium  is not included in the 
regulated carcinogenic (S)VOCs 
categories 1A & 1B according to 
the prEN 16516 emission testing 
protocol 

no data  

monitoring data Be in household dust: 
0.5 µg/g (Rasmusssen et al., 2001) 

no data found  

group 4 

CMR  substances  for  which  there 
is 
evidence  of  presence  in  CA;  available 
information  indicates  that  exposure  is 
possible;  more  data  needed 
for 
confirmation and to assess the extent of 
exposure 

no data  

data on Cd levels in indoor dust 
described in literature: 
see cadmium oxide 

indoor construction materials are 
not likely to be a major source of 
Cd  in indoor dust; 
explanation: see cadmium oxide 

group 6 

is 
CMR  substances  for  which  there 
evidence of presence in CA with indirect 
evidence for low likelihood of consumer 
exposure 

use of cadmium is 
restricted for use in 
articles for several plastic 
materials 

use in ceramics, glasses, 
enamels and  plastics 

Lead chromate 

231-846-0  

cat 1: fences: roll doors 

not mentioned 
in consulted 
sources 

assumed to be present in 
levels > 0.1 % (relevant 
notifications) 

anticipated not to be 
present  > 0.1 % after 
sunset date (21/05/2015)  
since no authorized use in 
domain of construction 
articles   

other: tarpaulin coverings 
(e.g. roofing) 

No authorized use in 
domain of construction 
articles (sunset date: 
21/05/2015) 

226 

no emission data found 
lead chromate is not included in 
the regulated carcinogenic 
(S)VOCs categories 1A & 1B 
according to the prEN 16516 
emission testing protocol 

the  V RAR on lead substances dealing 
with consumer exposure does not 
include a consumer exposure scenario 
related to construction articles  

no data on lead chromate found; 
data on monitoring of elemental Pb and 
Cr found in literature: see lead 
sulfochromate yellow 

indoor construction materials are 
not likely to be a major source of Cr 
and Pb  in indoor dust (see above) 

group 6 

CMR  substances  for  which  there 
is 
evidence of presence in CA with indirect 
evidence for low likelihood of consumer 
exposure 

 
 
  
  
 
  
  
  
  
  
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
 
 
 
 
 
 
  
  
  
  
  
  
  
 
 
TASK 2: list of substances an applications in construction articles 

TASK 3: criteria supporting the likelihood of presence/absence of consumer exposure arising from construction articles 

substance 

EC-number 

use in construction 
articles 

technical 
function 

Boric acid 

233-139-2; 
234-343-4   

use in stone, plaster, 
cement, glass and ceramic 
articles 

not mentioned 
in consulted 
sources 

criterion 1: presence of 
CMR in construction 
article 

assumed to be present in 
levels > 0.1 % (relevant 
notifications and 
registrations) 

criterion 2: emissions of CMR 
from construction articles   
 (test chamber method CEN/TS 
16516 or similar method) 

no emission data found 
boric acid is not included in the 
regulated carcinogenic (S)VOCs 
categories 1A & 1B according to 
the prEN 16516 emission testing 
protocol 

criterion 3: estimated exposure 

criterion 4: measured indoor exposure 

no data 

no data found 

criterion 5: source apportioning 
data?    
(only relevant if data on criterion 
4) 

group no 

group name 

not relevant since lack of data on 
indoor exposure 

group 5  

is 
CMR  substances  for  which  there 
evidence of presence in CA for which no 
assessment is possible 

SU 19: building and 
construction work;  ERC 3 
(formulation in materials); 
not further specified 

Disodium tetraborate  
anhydrous 

233-139-2; 
234-343-4   

use in stone, plaster, 
cement, glass and ceramic 
articles 

creates optimal 
glass 
fiberization 

assumed to be present in 
levels > 0.1 % (relevant 
notifications and 
registrations) 

no emission data found 
Disodium tetraborate  anhydrous 
is not included in the regulated 
carcinogenic (S)VOCs categories 
1A & 1B according to the prEN 
16516 emission testing protocol 

no data 

no data found 

not relevant since lack of data on 
indoor exposure 

group 5  

CMR  substances  for  which  there 
is 
evidence of presence in CA for which no 
assessment is possible 

service life of cellulose 
insulation (cat. 3) 

natural fibre insulation 
product (cat 3) 

use of borates in 
plasterboards and wood 
(cat. 6, cat. 10)  

SU 19: building and 
construction work;  ERC 3 
(formulation in materials); 
not further specified 

SU 19: building and 
construction work;  ERC 3 
(formulation in materials); 
not further specified 

flame retardant 

not mentioned 
in consulted 
sources 

not mentioned 
in consulted 
sources 

assumed to be present in 
levels > 0.1 % (relevant 
notifications and 
registrations) 

Magnesium nitrate 

233-826-7  

Potassium 
pentaborate 

234-371-7  

SU 19: building and 
construction work;  ERC 3 
(formulation in materials); 
not further specified 

not mentioned 
in consulted 
sources 

assumed to be present in 
levels > 0.1 % (relevant 
notifications and 
registrations) 

Trilead dioxide 
phosphonate 

235-252-2   

 'use of lead-stabilized 
plastic materials as an 
internal structural 
component of buildings  

stabilizer 

assumed to be present in 
levels > 0.1 % (relevant 
notification) 

227 

no emission data found 
magnesium nitrate is not 
included in the regulated 
carcinogenic (S)VOCs categories 
1A & 1B according to the prEN 
16516 emission testing protocol 

no emission data found 
potassium pentaborate is not 
included in the regulated 
carcinogenic (S)VOCs categories 
1A & 1B according to the prEN 
16516 emission testing protocol 

no emission data found 
trilead dioxide phosphonate  is 
not included in the regulated 
carcinogenic (S)VOCs categories 
1A & 1B according to the prEN 
16516 emission testing protocol 

no data 

no data found 

not relevant since lack of data on 
indoor exposure 

group 5  

CMR  substances  for  which  there 
is 
evidence of presence in CA for which no 
assessment is possible 

no data 

no data found 

not relevant since lack of data on 
indoor exposure 

group 5  

CMR  substances  for  which  there 
is 
evidence of presence in CA for which no 
assessment is possible 

no data 

no data on trilead dioxide phosphonate 
data on monitoring of elemental Pb  
found in literature: see lead 
sulfochromate yellow 

for Pb: see above 

group 6 

is 
CMR  substances  for  which  there 
evidence of presence in CA with indirect 
evidence for low likelihood of consumer 
exposure 

 
  
  
  
  
  
  
  
  
  
  
  
 
 
  
  
  
  
  
  
 
  
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
  
  
  
  
  
  
 
 
TASK 2: list of substances an applications in construction articles 

TASK 3: criteria supporting the likelihood of presence/absence of consumer exposure arising from construction articles 

criterion 2: emissions of CMR 
from construction articles   
 (test chamber method CEN/TS 
16516 or similar method) 

no emission data found 
lead chromate molybdate 
sulphate red is not included in 
the regulated carcinogenic 
(S)VOCs categories 1A & 1B 
according to the prEN 16516 
emission testing protocol 

criterion 1: presence of 
CMR in construction 
article 

assumed to be present in 
levels > 0.1 % (notifications 
potentially relevant for 
construction articles)   

authorized use  potentially 
indirectly relevant for 
construction articles 

criterion 3: estimated exposure 

criterion 4: measured indoor exposure 

no data 

no data on lead chromate molybdate 
sulphate found; 
data on monitoring of elemental Pb and 
Cr found in literature: see lead 
sulfochromate yellow 
data on elemental Mo: 2 µg/g 
(Rasmussen et al., 2001) 

criterion 5: source apportioning 
data?    
(only relevant if data on criterion 
4) 

indoor construction materials are 
not likely to be a major source of Cr 
and Pb  in indoor dust (see above) 
for Mo: no information 

group no 

group name 

group 6 

CMR  substances  for  which  there 
is 
evidence of presence in CA with indirect 
evidence for low likelihood of consumer 
exposure 

substance 

EC-number 

use in construction 
articles 

technical 
function 

235-759-9  

cat 1: fences: roll doors 

pigment 

Lead chromate 
molybdate sulphate 
red (C.I. Pigment Red 
104) 

service life of coated 
articles: stone, plaster, 
cement, glass and ceramic 
articles ((cat. 1, cat. 2, cat. 
5, cat. 7, cat. 10) ) 

cat 6: pigments in articles 
(wood) 

other: tarpaurin covers 
(e.g. roofing) 

SU 19: building and 
construction work;  ERC 3 
(formulation in materials); 
not further specified 

authorized use which is 
potentially indirectly 
relevant for construction 
article (authorized use: 
Distribution and mixing 
pigment powder in an 
industrial environment 
into solvent-based paints 
for non-consumer )use 

228 

 
 
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
  
  
  
  
  
  
  
 
 
 
 
ANNEX 4 - CHROMATOGRAMS OBTAINED WITH THE HORIZONTAL EMISSION TEST REFERENCE METHOD 

Abundance

Abundance

TIC: 2015100534_100_40_dbc.d\data.ms

TIC: 2015102917_100_40_dbc.d\data.ms

2400000

2200000

2000000

1800000

1600000

1400000

1200000

1000000

800000

600000

400000

200000

0

10.00

15.00

20.00

25.00

30.00

35.00

40.00

2800000

2600000

2400000

2200000

2000000

1800000

1600000

1400000

1200000

1000000

800000

600000

400000

200000

0

10.00

15.00

20.00

25.00

30.00

35.00

40.00

Time-->

Time-->

Chromatogram of sample 20152190 after 3 days (left) and 28 days (right) 

Abundance

Abundance

TIC: 2015100535_100_40_dbc.d\data.ms

TIC: 2015102918_100_40_dbc.d\data.ms

2400000

2200000

2000000

1800000

1600000

1400000

1200000

1000000

800000

600000

400000

200000

0

10.00

15.00

20.00

25.00

30.00

35.00

40.00

2800000

2600000

2400000

2200000

2000000

1800000

1600000

1400000

1200000

1000000

800000

600000

400000

200000

0

10.00

15.00

20.00

25.00

30.00

35.00

40.00

Time-->

Time-->

Chromatogram of sample 20152191 after 3 days (left) and 28 days (right) 

229 

 
 
 
 
 
 
 
Abundance

Abundance

TIC: 2015100524_100_40_dbc.d\data.ms

TIC: 2015102921_100_40_dbc.d\data.ms

 2.4e+07

 2.3e+07

 2.2e+07

 2.1e+07

   2e+07

 1.9e+07

 1.8e+07

 1.7e+07

 1.6e+07

 1.5e+07

 1.4e+07

 1.3e+07

 1.2e+07

 1.1e+07

   1e+07

9000000

8000000

7000000

6000000

5000000

4000000

3000000

2000000

1000000

0

10.00

15.00

20.00

25.00

30.00

35.00

40.00

9000000

8500000

8000000

7500000

7000000

6500000

6000000

5500000

5000000

4500000

4000000

3500000

3000000

2500000

2000000

1500000

1000000

500000

0

10.00

15.00

20.00

25.00

30.00

35.00

40.00

Time-->

Time-->

Chromatogram of sample 20152192 after 3 days (left) and 28 days (right) 

Abundance

Abundance

TIC: 2015100525_100_40_dbc.d\data.ms

TIC: 2015102922_100_40_dbc.d\data.ms

5500000

5000000

4500000

4000000

3500000

3000000

2500000

2000000

1500000

1000000

500000

0

Time-->

7500000

7000000

6500000

6000000

5500000

5000000

4500000

4000000

3500000

3000000

2500000

2000000

1500000

1000000

500000

0

10.00

15.00

20.00

25.00

30.00

35.00

40.00

Time-->

Chromatogram of sample 20152193 after 3 days (left) and 28 days (right) 

230 

10.00

15.00

20.00

25.00

30.00

35.00

40.00

 
 
 
 
 
 
 
 
 
 
 
Abundance

6500000

6000000

5500000

5000000

4500000

4000000

3500000

3000000

2500000

2000000

1500000

1000000

500000

0

Time-->

TIC: 2015100536_100_40_dbc.d\data.ms

10.00

15.00

20.00

25.00

30.00

35.00

40.00

Abundance

1.15e+07

 1.1e+07

1.05e+07

   1e+07

9500000

9000000

8500000

8000000

7500000

7000000

6500000

6000000

5500000

5000000

4500000

4000000

3500000

3000000

2500000

2000000

1500000

1000000

500000

0

Time-->

Chromatogram of sample 20152194 after 3 days (left) and 28 days (right) 

TIC: 2015100537_100_40_dbc.d\data.ms

Abundance

9500000

9000000

8500000

8000000

7500000

7000000

6500000

6000000

5500000

5000000

4500000

4000000

3500000

3000000

2500000

2000000

1500000

1000000

500000

Time-->

10.00

15.00

20.00

25.00

30.00

35.00

40.00

Abundance

 1.1e+07

1.05e+07

   1e+07

9500000

9000000

8500000

8000000

7500000

7000000

6500000

6000000

5500000

5000000

4500000

4000000

3500000

3000000

2500000

2000000

1500000

1000000

500000

0

Time-->

Chromatogram of sample 20152195 after 3 days (left) and 28 days (right) 

231 

TIC: 2015102919_100_40_dbc.d\data.ms

10.00

15.00

20.00

25.00

30.00

35.00

40.00

TIC: 2015102920_100_40_dbc.d\data.ms

10.00

15.00

20.00

25.00

30.00

35.00

40.00

 
 
 
 
 
 
 
 
 
 
Abundance

Abundance

TIC: 2015100818_100_40_dbc.d\data.ms

TIC: 2015110436_100_40_dbc.d\data.ms

2600000

2400000

2200000

2000000

1800000

1600000

1400000

1200000

1000000

800000

600000

400000

200000

Time-->

10.00

15.00

20.00

25.00

30.00

35.00

40.00

5000000

4500000

4000000

3500000

3000000

2500000

2000000

1500000

1000000

500000

0

Time-->

Chromatogram of sample 20152250 after 3 days (left) and 28 days (right) 

Abundance

1600000

1400000

1200000

1000000

800000

600000

400000

200000

0

Time-->

TIC: 2015100817_100_40_dbc.d\data.ms

10.00

15.00

20.00

25.00

30.00

35.00

40.00

Abundance

2800000

2600000

2400000

2200000

2000000

1800000

1600000

1400000

1200000

1000000

800000

600000

400000

200000

0

Time-->

Chromatogram of sample 20152251 after 3 days (left) and 28 days (right) 

232 

10.00

15.00

20.00

25.00

30.00

35.00

40.00

TIC: 2015110439_100_40_dbc.d\data.ms

10.00

15.00

20.00

25.00

30.00

35.00

40.00

 
 
 
 
 
 
 
 
 
 
Abundance

3000000

2500000

2000000

1500000

1000000

500000

0

Time-->

TIC: 2015100819_100_40_dbc.d\data.ms

10.00

15.00

20.00

25.00

30.00

35.00

40.00

Abundance

1.15e+07

 1.1e+07

1.05e+07

   1e+07

9500000

9000000

8500000

8000000

7500000

7000000

6500000

6000000

5500000

5000000

4500000

4000000

3500000

3000000

2500000

2000000

1500000

1000000

500000

0

Time-->

TIC: 2015110437_100_40_dbc.d\data.ms

10.00

15.00

20.00

25.00

30.00

35.00

40.00

Chromatogram of sample 20152252 after 3 days (left) and 28 days (right) 

Abundance

Abundance

TIC: 2015100816_100_40_dbc.d\data.ms

TIC: 2015110438_100_40_dbc.d\data.ms

 1.7e+07

 1.6e+07

 1.5e+07

 1.4e+07

 1.3e+07

 1.2e+07

 1.1e+07

   1e+07

9000000

8000000

7000000

6000000

5000000

4000000

3000000

2000000

1000000

0

10.00

15.00

20.00

25.00

30.00

35.00

40.00

9500000

9000000

8500000

8000000

7500000

7000000

6500000

6000000

5500000

5000000

4500000

4000000

3500000

3000000

2500000

2000000

1500000

1000000

500000

0

Time-->

Time-->

Chromatogram of sample 20152253 after 3 days (left) and 28 days (right) 

233 

10.00

15.00

20.00

25.00

30.00

35.00

40.00

 
 
 
 
 
 
 
 
HOW TO OBTAIN EU PUBLICATIONS 

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doi:10.2779/451235