Exemptions from the criteria document General exemptions for certain chemical product groups and substances The products and substances that generally are accepted, even though they do not meet the criteria are presented in 4 and 5. Note that substitution always shall be considered before general exemptions are applied. There is an obligation to provide information regarding substances subjected by the general exemptions. Table 4. Accepted exemptions for certain product groups. Chemical products Exemptions for use as Grounds for exemption Zinc phosphate primer classified as H410 Replacement for chromates in primers. The risk for the environment will be lower than when using chromates. Zinc-rich paint classified as H410 Corrosion protection on steel when the zinc-rich paint is included in a colour system and when repairing galvanized constructions. Gives a significantly better protection of corrosion, in combination of very little zinc leakage thanks to additional layers in the paint system. Also, very small amounts are used when repairing with zinc-rich paint. Allergenic products specified in AFS 2011:19 § 37e classified as H317 and/or H334 and also polysulfides classified H317 and/or H334.. Foam sealant, moulding component, sealant, primer, paint, lacquer and adhesives. The use is regulated by The Swedish Work Environment Authority’s provision 2011:19 on occupational health and safety risks (re-written and altered in 2014:43). If the regulations are followed the OH&S risks are small when using these products. Products in the Swedish Armed Forces’ Product catalogue – Fuels, lubricant and associated products (CD PRKAT Drivmedel M7789-000183 Swedish edition alternatively M7789-000193 English edition). Fuels (i.e. lubricants, brake fluids, antifreeze agents) in the materiel system (vehicles, ships, aircrafts etc.) of the Swedish Armed Forces and the Swedish Defence Material Administration. The products in the catalogue are evaluated and the management is made clear. A limited assortment reduces the environment impact. New products in the Product catalogue shall be evaluated according to the criteria document. Table 5. Exemptions accepted for certain substances in chemical products or in articles. Name of the substance CAS no Reasons for avoiding the substance Exemptions for use
Exemptions from these restrictions have been granted for certain applications in the defence sector. If such exemptions exist, they are specified in the far right-hand column of the table. Note that this is not an exhaustive compilation, the table is intended as a guidance and includes examples of substances relevant for the defence sector. Classifications given in the table are harmonised within the EU and are given in Annex VI in CLP. In cases where the substance has no harmonised classification the most commonly reported classifications in the ECHA C&L inventory database are specified. Note that the complete classification of the substances is usually not specified, but only the classification declaring why the substance is restricted in relation to the criteria given in section 2.
Table 6. Examples of substances covered by restrictions in section 2. Substance/ Group of substances CAS No Reasons for avoiding the substance Examples of use Exemptions for certain applications Acrylamide 79-06-01 Carc.1B, H350 Mut.1B, H340 Skin Sens. 1, H317 Substance on the Candidate List. Raw-material for synthesis of plastic and flocculation agent for water purification. Present in sealants in the building industry. Alkanes, C10-13, chloro (Short Chain Chlorinated Paraffin’s) 85535-84-8 Aquatic Chronic 1, H410 PBT/vPvB-substance Substance on the Candidate List. Flame retardant and plasticiser in plastic and rubber industry. (Regulated in both REACH and EC No 850:2004) Aluminium silicate Refractory ceramic fibre Misses CAS-No Carc.1B, H350i Substance on the Candidate List. Fire protection for industrial equipment, i.e. within the aircraft and vehicle industry. Insulating material in kilns. Amosite (Asbestos material) 12172-73-5 Carc.1A, H350 Insulation for pipes, fireproof insulation boards, sprayed asbestos. Antophyllite (Asbestos material) 77536-67-5 Carc.1A; H350 Insulation materials, adhesives, plastic, and reinforcement material. Anthracene 120-12-7 PBT-substance Substance on the Candidate List. Signal smoke Arsenic and its compounds - Diarsenic pentaoxide - Diarsenic trioxide Several 1303-28-2 1327-53-3 Carc.1A, H350 Aquatic Chronic 1, H410 Substance subject to application and on the Candidate List. Electronics, surface treatment, wood. Arsenic is used in certain alloys. Among other things in ammunition. Yes (see table 5) Asbestos - Amosite - Antophyllite - Crokidolite - Chrysotile 12172-73-5 77536-67-5 12001-28-4 12001-29-5 Carc.1A, H350 Brake linings, building material, thermal insulation. Benzene 71-43-2 Carc.1A, H350 Muta 1B, H340 Solvent Gasoline component
Benzyl butyl phthalate (BBP) 85-68-7 Repr.1B, H360Df Aquatic Chronic 1, H410 Substance subject to application and on the Candidate List. Plasticiser Beryllium and its compounds Several Carc. 1B, H350i Electronics, radar. Yes (see table 5) Bis(tributyl (TBTO) 56-35-9 Aquatic Chronic 1, H410 PBT-substance Substance on the Candidate List. Occurs as preservative in imported articles such as textile, paper, leather, rubber and polymeric materials. Lead and its compounds. See examples below Several Substances specifically identified by the defence sector. Lead may release soluble lead salts. Major parts of lead compounds are toxic for reproduction and some are also carcinogenic, many are classified. Batteries, electrical and electronic products, ammunition, weights, surface treatment, transport fuels and lubricants (lubricants, fuel, oils) etc. Yes (see table 5) Lead azid 13424-46-9 Repr.1A, H360Df Aquatic Chronic 1, H410 Substance on the Candidate List. For ignition and reinforcement in detonators for civil and military use. Yes (see table 5) Lead chromate 7758-97-6 Carc.1B, H350 Repr 1A, H360Df Aquatic Chronic 1, H410 Substance subject to application and on the Candidate List. Pigment in paint, especially for protection, e.g. for vehicles, aircraft, agricultural machinery and road signs. Also military when marking camouflage and ammunition. Lead chromate molybdate sulphate (C.I.Pigment Red 104) 12656-85-8 Carc.1B, H350 Repr 1A, H360Df Aquatic Chronic 1, H410 Substance subject to application and on the Candidate List. Pigment in paint, especially for protection, e.g. for vehicles, aircraft, agricultural machinery and road signs. Also military when marking camouflage and ammunition. corrosion
Lead chromate sulphate (C.I.Pigment Yellow 34) 1344-37-2 Carc.1B, H350, Repr. 1A, H360Df Aquatic Chronic 1, H410 Substance subject to application and on the Candidate List. Pigment in paint, especially for protection, e.g. for vehicles, aircraft, agricultural machinery and road signs. Also military when marking camouflage and ammunition. Lead (II) picrate 6477-64-1 Repr. 1A, H360Df Aquatic Chronic 1, H410 Substance on the Candidate List. May occur in low levels in detonators, along with lead azide and lead styphnate. Yes (see table 5) Lead styphnate 15245-44-0 Repr. 1A, H360Df Aquatic Chronic 1, H410 Substance on the Candidate List. For ignition in small calibre ammunition. Yes (see table 5) Boron sodium oxide hydrate 12267-73-1 Repr. 1B, H360FD Substance on the Candidate List. Used as wood preservative, flame retardant etc. Boric acid 10043-35-3 11113-50-1 Repr. 1B, H360FD Substance on the Candidate List. Raw materials for glass and ceramics. In photo chemicals and in adhesives. Agent for wood protection, fertilisation, dis-infection, flame protection, metal treatment. May be found in preserved timber and in flame retarded insulation materials. Yes (see table 5) Boron oxide 1303-86-2 Repr. 1B, H360FD Substance on the Candidate List Additives in fiberglass. Raw material for the manufacture of glass, glassware, ceramics and metal production
Brominated flame retardants (some): - Decabromo diphenyl ether (Deca-BDE - Hexabromo cyclododecane (HBCDD) (stereoisomers) - Octabromo diphenyl ether (Octa-BDE) - Pentabromo diphenyl ether (Penta-BDE) - Polybrominated biphenyls (PBB) such as - 2,3,3´,4,4´, Several 1163-19-5 25637-99-4 3194-55-6 32536-52-0 32534-81-9 Several 59536-65-1 Different properties, e.g. toxic for reproduction, PBT. See respective substance. Substances on the Candidate List. Flame retardant Yes (see table 5). Applies in certain cases within the substance groups PBB and PBDE. CFC Several Ozone-depleting H420, GWP>2000 Refrigerant, also propellants. Decabromo diphenyl ether (Deca-BDE) (The substance is a PBDE) 1163-19-5 PBT/vPvB-substance Substance specifically identified by the defence sector. (Suspected to damage the development of the brain) Substance on the Candidate List. Flame retardant Dialkyl phthalates (branched C6-C8) 71888-89-6 Repr. 1B, H360Df Substances on the Candidate List. Plasticiser in PVC plastics. Dialkyl phthalates (branched and linear C7-C11) 68515-42-4 Repr. 1B, H360FD Substances on the Candidate List. Plasticiser in plastics. Di(2-ethylhexyl) phtalate (DEHP) 117-81-7 Repr.1B, H360FD Substance subject to application and on the Candidate List. Plasticiser
Di(2-methoxyethyl) phtalate 117-82-8 Repr.1B, H360Df Substances on the Candidate List. Plasticiser Diarsenic pentaoxide 1303-28-2 Carc. 1A, H350 Aquatic Chronic 1, H410 Substance subject to application and on the Candidate List. Wood protection, special glass. Diarsenic trioxide 1327-53-3 Carc. 1A, H350 Aquatic Chronic 1, H410 Substance subject to application and on the Candidate List. Wood protection, special glass, enamel. Dibutyl phtalate (DBP) 84-74-2 Repr. 1B, H360Df Substance subject to application and on the Candidate List. Plasticiser Diisobutyl phtalate 84-69-5 Repr. 1B, H360Df Substance subject to application and on the Candidate List. Plasticiser Dimethylacetamide (DMAC) 127-19-5 Repr.1B, H360D Substance on the Candidate List. Solvent Used in repairing car glasses. 2,4-Dinitrotoluene 121-14-2 Carc.1B, H350 Aquatic Chronic 1, H410 Substance subject to application and on the Candidate List. Included as a component in explosives. Used to make the product mouldable and to modify the burn rate of gun powder. 2,4-Dinitrotoluene is left as non-separable residue (contamination) in TNT. Phenolphthalein 77-09-8 Carc. 1B, H350 Substance on the Candidate List. Laboratory chemical and indicator in chemical analyses. Fatty acids, lead salts 91031-62-8 Repr.1A, H360Df Aquatic Chronic 1, H410 Substances on the Candidate List. Stabilizers for PVC.
(HFC) some R23 R125 R143a R227ea R236fa R404a R410a R417a R507 Several 75-46-7 354-33-6 420-46-2 431-89-0 690-39-1 The example substances given have GWP >2000 Propellants Coolant Fire extinguisher Formaldehyde, oligomeric reaction products with aniline. (Technical grade MDA, UVCB substance that mainly consists of 4,4’-diamino diphenyl methane, CAS No: 101-77-9 (see above). The classification of the substance is based on the content of 4,4’-diamino diphenyl methane) 25214-70-4 (101-77-9) Carc.1B, H350 Skin Sens. 1, H317 (CAS nr 101-77-9) Substance on the Candidate List. Licensable for use (according AFS 2011:19). Used as curing agent in epoxy resins, e.g. in adhesives, paints and lacquer. May be present in pipe couplings and moulds. Phthalates, some - Benzyl butyl phtalate (BBP) - Di(2-ethylhexyl) phtalate (DEHP) - Dibutyl phtalate (DBP) - Diisobutyl phtalate - phthalate Dihexyl phtalate, DHP Several 85-68-7 117-81-7 84-74-2 84-69-5 117-82-8 84-75-3 The phthalates given are classified as toxic for reproduction. They are substances subjected to application and/or on the Candidate List. See respective substance. Plasticiser in polymer products. Present in paints, raw material for plastics, rubber, adhesives, fillers and in raw material for paints. Diisopenthyl phtalate Diamyl phtalate 605-50-5 Repr. 1B, H360FD Substance on the Candidate List. Explosives (GBL) 96-48-0 Substance specifically identified by the defence sector. (Classified as narcotic). Solvent
(GHB) 591-81-1 Substance specifically identified by the defence sector. (Classified as narcotic). Solvent Halons t ex halon-1211, halon- 1301 Several Ozone depleting H420, GWP > 2000 Fire extinguishing agents Yes (see table 5) HA-oils (High aromatic oils). Contains 10-30 % polyaromatic hydrocarbons, PAH. - Contains high levels of substances (e.g. benzo[a]pyrene, anthracene) classified as inter alia Carc. 1B and PBT Car tyres HCFC Several Ozone depleting H420, GWP > 2000 Refrigerant, propellants. Hexabromo cyclododecane (HBCDD) (stereoisomers) 25637-99-4, 3194-55-6 PBT-substance Substance subject to application and on the Candidate List. Flame retardant (HFC 236fa, DeugenN) 920-66-1 Ozone depleting potential GWP > 2000 Fire extinguishing agents, refrigerant. Yes (see table 5) Hydrazine 302-01-2 7803-57-8 Carc. 1B, H350 Aquatic Chronic 1, H410 Substance on the Candidate List. Licensable for use (According to AFS 2011:19). Propellants, inhibitor in hot and cold water systems. Cadmium and its compounds Several Substance specifically identified by the defence sector. Cadmium may release soluble compounds. Many are classified as carcinogenic and toxic for reproduction. Electrical and electronic products, batteries, metals and alloys, surface treatment, paints and lacquers. Yes (see table 5)
(NMP) 872-50-4 Repr. 1B, H360D Substance on the Candidate List. Solvent in paints, lacquers and detergents, car care products, degreasers, paint removal, anti-friction lacquers. Methylene chloride (dichloromethane) 75-09-2 Substance specifically identified by the defence sector. Prohibited to use the substance occupationally in Sweden (SFS 1998:944). Also restrictions within the rest of the EU (REACH Annex XVII), limited evidence of a carcinogenic effect (H351). Solvent Sodium borates Disodium tetraborate Disodium tetraborate pentahydrate Disodium tetraborate decahydrate Tetraboron disodium heptaoxide, hydrate Several 1330-43-4 12179-04-3 1303-96-4 12267-73-1 Repr. 1B, H360FD Substances on the Candidate List. Raw material for glass and ceramics. Agent for wood protection, fertilisation, disinfection, flame protection, cleaning, metal treatment. Photo chemical. In adhesives, in preserved timber and in flame retardant insulation materials. Sodium dichromate Sodium dichromate, dihydrate 10588-01-9 7789-12-0 Carc. 1B, H350 Muta. 1B, H340 Repr. 1B H360FD Acute Tox. 2, H330 Resp. Sens. 1 H314 Skin Sens. 1, H317 Substance subjected to application as well as on the Candidate List. In surface treatment agents for metals and products. Yes (see table 5)
Nonylphenol etoxylate ((C2 H4 O)n C15H24O) 9016-45-9 Substance on the Candidate List. (N Nonylphenol etoxylate is degraded in the environment and forms nonylphenol (CAS No 25154-52-3 or 84852- Nonylphenol is classified as inter alia very dangerous for the environment with long-term adverse effects. The substance also has suspected endocrine disruptive properties.). Surface active substance that is above all used in detergents, but also in washing agents for textiles produced outside the EU. Octabromo diphenyl ether (Octa-BDE) (This is a PBDE) 32536-52-0 Repr. 1B, H360Df Flame retardant Yes (see table 5) Pentalead tetraoxide sulphate, Leadsulphate, tetrabasic 12065-90-6 Repr. 1A, H360D Aquatic Chronic 1, H410 Substance on the Candidate List. Stabilizers for PVC; plastic products, lead-acid batteries. Pentabromo diphenyl ether (Penta-BDE) (This is a PBDE) 32534-81-9 Lact., H362 Aquatic Chronic 1, H410 Substance specifically identified by the defence sector. (suspected vPvB) Flame retardant Yes (see table 5) Perfluorocarbons Several Ozone-depleting H420, GWP >2000 Fire extinguishing agent Perfluorooctane sulfonates and its derivatives (PFOS) C8F17SO2X (X=OH, metal salt (O-M+), halide, amide, and other derivatives including polymers) Several PBT-substances Extinguishing agent, impregnation of textiles, paper, and leather among other things for dirt protection. Perfluorooctanoic acid (PFOA) 335-67-1 Repr. 1B, H360D Lact. H362 PBT-substance Substance on the Candidate List. Extinguishing agent, Impregnation of textiles Floor wax and paint
Polybrominated biphenyls (PBB) such as 2,3,3´,4,4´, biphenyl Several 59080-40-9 Substances specifically identified by the defence sector. (suspected vPvB) Textiles, leather and clothing. Flame retardant in electrical and electronic equipment. Yes (see table 5) Polychlorinated biphenyls (PCB) Several 1336-36-3 PBT/vPvB Dielectric medium in capacitors and transformers. In sealants. Sulphur hexafluoride 2551-62-4 GWP >2000 Insulating medium in high voltage equipment, switches, and transformers. Yes (see table 5) 4-tert-octylphenol; phenol) 140-66-9 Aquatic Chronic 1, H410 Substance on the Candidate List. Vulcanization agent, regulator of viscosity and complexing agent at manufacturing of polymers and etoxilates, e.g. adhesive and sealant. May be present in paint, lacquer, coating and ink. Triethyl arsenate 15606-95-8 Carc. 1A, H350 Aquatic Chronic 1, H410 Substance on the Candidate List. May be present in the electronics industry in integrated circuits. (Freon TF) 76-13-1 Ozone-depleting H420, GWP >2000 Solvent 1,1,1-Trichloro ethane 71-55-6 Ozone-depleting, H420 Solvent Tri(2-chloroethyl) phosphate 115-96-8 Repr. 1B, H360F Substances subjected to application. Flame retardant in plastic, paint, lacquer and adhesives. Part of building products, furniture and textiles. Trichloroethylene 79-01-06 Carc.1B, H350 Substances subjected to application. Degreasing agent for metal, solvent. (Prohibited to use the substance occupationally in Sweden (SFS 1998:944)).