Heavy Metals: In order to facilitate compliance with local, State and federal (e.g. Consumer Product Safety Improvement Act of 2008 CPSIA 2008) or international laws, Supplier shall not sell or deliver to RRD any material that exceeds any of the following concentrations, including incidental presence in any accessible homogenous part or component: Antimony (60 ppm), Arsenic (25 ppm), Barium (1000 ppm soluble), Selenium (500 ppm), Chromium (60 ppm soluble), Mercury (0.001 ppm), Cadmium (40 ppm), and Lead (90 ppm).
Certain Dangerous Substances (REACH):All manufacturing materials supplied to RRD, regardless of location, are required to be in compliance with the restriction of substances under the REACH Annex XVII as revised and Article 33, substances added to the Candidate List by the European Union under REACH as a Substance of Very High Concern (SVHC) in concentrations greater than 0.1% by weight. More information can be found here:
Restriction of Heavy Metals and Brominated Fire Retardants(RoHS):No manufacturing material may exceed the most restrictive concentration for regulated heavy metals and brominated fire retardants permitted by Restriction of Hazardous Substances (RoHS) laws in the European Union (2002/95/EC) and China (SJ/T 11363-2006) as amended. More information can be found at the following website:
- EU RoHS
- China RoHS
Phthalates: In order to meet Laws in multiple jurisdictions (CPSIA 2008 and California Proposition 65), RRD prohibits the use of the following phthalates in concentrations of greater than 0.1% or 1000 ppm: Bis (2-ethylhexyl) phthalate (DEHP), CAS [117-81-7 ] ; Butyl benzyl phthalate (BBP), CAS [85-68-7 ]; Dibutylphthalate (DBP), CAS[84-74-2 ]; Diisononyl Phthalate (DiNP), CAS [28553-12-0, 68515-48-0]; Diisodecyl Phthalate (DIDP), CAS [68515-49-1, 26761-40-0]; Di-n-octyl Phthalate (DnOP), CAS [117-84-0]; and Dinonylhexyl Phthalate (DnHP), CAS [84-75-3].
Conflict Minerals (As required by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act):
- Supplier must provide products which do not contain columbite, tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted) also known as 3TGs (Tin, Tungsten, Tantalum and Gold); or their derivatives, or if 3TGs are contained, they must originate from countries outside the Democratic Republic of Congo and adjoining countries (“Covered Countries”) or the 3TGs must be processed by conflict-free smelters or refineries; and
- Upon RRD's request, Supplier must disclose any Materials that it provides to RRD that contain (i) columbite, tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (ii) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo and adjoining countries ("Covered Countries"); and
- Provide a certification in a form approved by RRD as to whether such Materials (i) originate in the Covered Countries, (ii) are processed in conflict-free smelters or refineries; or (iii) come from recycled sources.
Toxics in Packaging: All Materials supplied to RRD must comply with the most stringent Law applicable to heavy metals, including but not limited to Toxics in Packaging Laws enacted in selected States, and the European Union Directive on Packaging and Packaging Waste (94/62/EC). Specifically, no materials shall contain more than 100 parts per million (ppm) of Lead, Cadmium, Mercury and Hexavalent Chromium in the aggregate, that is, all four of the metals combined (if lead alone no more than 90 ppm). There may be no deliberate additions of these toxic heavy metals in the manufacturing processes of any materials sold by the Supplier to RRD. Please see the following link for more information: www.toxicsinpackaging.org.
California Proposition 65: Carcinogens, Mutagens, Reproductive Toxins (CMRs): ): RRD prohibits the use of carcinogens, mutagens, and reproductive toxins in concentrations which would require warning or labeling in a manufactured or supplied Finished Product under any Law. CMRs include any substances listed by California as known to cause cancer, birth defects or other reproductive harm by Proposition 65, Safe Drinking Water and Toxic Enforcement Act of 1986. In addition, substances identified by the International Agency for Research on Cancer (IARC) as a carcinogen or potential carcinogen; listed as a carcinogen or potential carcinogen in the Annual Report on Carcinogens published by the National Toxicology Program (NTP) latest edition; regulated by U. S. Occupational Safety and Health Act (OSHA) as a carcinogen. For more information, see below:
- Proposition 65
Maine and Washington State Chemicals of High Concern: The Maine Toxic Chemicals in Children’s Product law and the Washington Children’s Safe Product Act. Supplier shall not sell or deliver to RRD any materials containing chemicals of high concern as defined by the respective Laws that require Manufacturers or Distributors to provide Notification to any Agency. More information can be found at the following websites:
- Maine Toxic Chemicals in Children’s Products
- Washington Children’s Safe Product Act
Asbestos and Radioactive Substances: RRD prohibits the presence of asbestos or asbestos-containing materials and radioactive substances or radioactive-containing materials in products supplied to RRD.
Sensitizing Substances. RRD prohibits the use of strong sensitizers in manufacturing materials as identified by the U. S. Federal Hazardous Substance Act (FHSA), and also restricts other known skin sensitizing substances identified by Annex VI of European Union’s Classification, Labeling, and Packaging (CLP) if present in materials supplied at concentrations known to cause allergic reaction and become an accessible part of a Finished Product. A list of FHSA Strong Sensitizers can be found under 16 CFR § 1500.
- FHSA Guidance Document
Ozone Depleting Substances (ODS): as identified by the Montreal Protocol on Substances That Deplete the Ozone Layer. No product received or manufactured by RRD may contain or be manufactured with a regulated ODS. As defined by the United States Environmental Protection Agency, a product contains an ODS if the ODS is physically held within its structure. A product is manufactured with an ODS if the product comes into physical contact with an ODS during its manufacture. A current list of Ozone Depleting Substances is found in Appendices A and B, 40 CFR Part 82 Subpart A.
Persistent Organic Pollutants (POPs): as identified by the Stockholm Convention on Persistent Organic Pollutants and Regulation (EU) 519/2012. All Materials supplied to RRD may not contain or be manufactured with a material listed as a POP.
- Regulation (EU) 519/2012
TSCA Section 6(h) Rules for Five PBT Chemicals: Suppliers must provide products which do not contain five Persistent Bioaccumulative and Toxic (PBT) chemicals as set forth by U.S. Environmental Protection Agency (EPA) under Section 6(a) of the Toxic Substances Control Act (TSCA):
- 2,4,6-Tris(tert-butyl)phenol (2,4,6-TTBP) (86 Fed. Reg. 866) - An intermediate/reactant used in fuels
- Decabromodiphenyl ether (decaBDE) (86 Fed. Reg. 880) - A flame retardant used in electronic appliances and textiles
- Hexachlorobutadiene (HCBD) (86 Fed. Reg. 922) - Used to manufacture chlorinated hydrocarbons
- Pentachlorothiophenol (PCTP) (86 Fed. Reg. 911) - Used to make rubber more pliable
- Phenol, isopropylated phosphate (3:1) (PIP (3:1)) (86 Fed. Reg. 894) - A plasticizer, flame retardant, anti-wear additive used in coatings, adhesives and lubricating oils
- PFAS - In order to meet laws in several jurisdictions, such as California PFAS (AB-1200) and New York PFAS § 37-0209, suppliers must provide products which do not contain perfluoroalkyl and polyfluoroalkyl substances or “PFAS”. PFAS means a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom.
- Bisphenol-A (BPA) - In order to meet laws in several jurisdictions, such as Connecticut BPA Ban and Illinois BPA Ban, suppliers must provide products which do not contain BPA.
Sections 2-3 below describe additional requirements applicable to specific types of materials, divided into their respective categories.