Special CASRN Reporting Requirements

Biological Ingredients: Biological ingredients such as wood and agrifiber do not require disclosure of a CASRN unless the ingredient is already registered with Chemical Abstract Services, in which case the number should be reported.

Electronic Components: Small electrical components do not require CASRN reporting, but the manufacturer must verify that these components are RoHS compliant. These components must be documented using the Small Electrical Components Exception. All products with small electrical components will therefore result in a Declaration Status of “Red List Approved” or “Declared”.

Float Glass: Float glass does not require CASRN reporting, but all glass coatings/interlayers/films must be reported. 

Geological Materials: Geological materials such as natural granite do not require disclosure of a CASRN; manufactured stone products require disclosure of CASRNs for all resins/binders/sealers in the product.

Impurities: There are instances when a Red List chemical is present in a product because it naturally occurs in the product’s raw materials or was unintentionally added through certain manufacturing or reclamation processes. Impurities do not require reporting on a Declare label.

Recycled Content: Recycled content should be reported using all known primary ingredients; a CASRN should be reported as applicable (based on guidance above).

Reaction Products: When a reaction occurs during the manufacturing of the product, the final reacted substance must be reported with a CASRN. If any residual reaction substances remain in the product above 100 ppm that are not covered by the CASRN of the reaction substance, they must also be reported with a CASRN.

Small Product Hardware: Small metal hardware must be reported with the metal type (i.e. steel), but reporting an alloy number is not required.

Required Non-CASRN Identifiers

Some material types are not accurately represented within the CASRN system. The disclosure requirements for the below materials use a different type of identifier.

European Community Number: If a CASRN is not available for a chemical, but a European Community (EC) Number is available, the EC number may be used to identify the chemical if the chemical name, molecular formula or molecular structure of the chemical is available on the ECHA Chem database. If the chemical contains a halogen (F, Cl, Br, I) a toxic heavy metal (As, Pb, Cd, hexavalent Cr, Hg), tin (Sn), or any benzene rings, then it cannot be self-disclosed in Declare and needs to be submitted and screened against the Red List chemical classes by an ILFI approved assessor. If the assessor determines that the chemical belongs to a Red List chemical class, the EC number must be submitted to declare.support@living-future.org for direct addition to the Priority List.

Metals and Metal Alloys: There are two pathways for disclosing metals and alloys.

1. Preferred pathway: Metals and Metal Alloys must be identified using the Unified Numbering System (UNS) or European Norm (EN) alloy numbers. Additional information about the alloy, such as ASTM grade, may also be reported as secondary information.
2. Alternative pathway: If a UNS or EN number is not available, then the CASRNs for the individual elements that make up the alloy may be disclosed (for example, brass is an alloy containing the pure elements copper, zinc, lead, tin, etc.)
   

The use of CASRNs referring to metal alloys (ie steel, bronze, brass, is disallowed. If an alloy contains a toxic heavy metal (As, Pb, Cd, hexavalent Cr, Hg) as defined by the ILFI Red List, but the alloy itself is not on the Red List, it may be used in a product as long as it complies with the relevant Red List exceptions. However, the alloy may be added to future versions of the Red List.

Metal surface treatments and coatings (ie galvanization, plating, etc) must be reported as separate ingredients from the base alloy.

Polymers with no CASRN: There are two pathways for disclosing a polymer with no CASRN or EC number. (If a polymer has a CASRN or EC number, it must be disclosed using that identifier according to typical Declare requirements.)

1. Preferred pathway: Manufacturers may use the guidance below to identify and screen the polymer’s key attributes.
2. Alternative pathway: Manufacturers may inventory the unreacted monomers and other additives using typical CASRN disclosure requirements.

Guidance for Polymers with no CASRN: This reporting pathway requires the engagement of an ILFI-Approved Third Party. Manufacturers or the Third Party must contact Declare.Support@living-future.org before pursuing this pathway and provide ILFI with the results of the supplier outreach survey below.

When disclosing polymers with no CASRN, all substances associated with the polymer and present above 100 ppm, shall be reported according to the typical Declare requirements. Examples include residuals, unreacted monomers, catalysts, functional additives, UV or heat stabilizers, colorants, plasticizers, and processing aids.

For the specific polymer substance with no CASRN, the following information is required:

• Polymer Name: Be as detailed as possible. IUPAC naming rules can help provide guidance. If oligomers are present in the final polymer, describe them here.
• Type of Polymer – choose from one of the following types:
  • Thermoset prepolymer (i.e. partially crosslinked)
  • Crosslinked thermoset (i.e. extensively crosslinked)
  • Thermoplastic
  • Elastomer
  • Other – only to be used if the others do not apply. If chosen, include a descriptor of the polymer type – do not leave this listed as “Other”
• Molecular Weight Number Average Molecular Weight in Daltons (Da) – choose from one of the following:
  • <1,000 Da
  • ≥1,000 Da and ≤ 10,000 Da
  • >10,000 Da
  • Enter a specific numerical value
• Percentage of Polymer <500 Da: Provide the percentage of the polymer that has a molecular weight of <500 Da. If this is unknown, enter “unknown”.

The name of the polymer will be disclosed using the following format: [Polymer Name] ( [Type of Polymer], [Number Avg. Mol. Weight], [% <500 Da] ). For example: Polystyrene-comb-polyisoprene (Thermoplastic, >10,000 Da, 0.05% is <500 Da).

In addition, responses to the following questions must be provided by the supplier of the polymer to determine compliance with the Red List and Declare requirements:

• Does this polymer have a CASRN or EC number? If so, please provide that number and use the normal process for disclosing this material.
• Provide the trade name of the polymer and other identifying information to the ILFI-approved third-party. As with all materials in Declare, supplier names and polymer trade names will not be publicly identified or disclosed unless permission has been granted to do so.
• Have all intentionally added substances associated with the polymer above 100 ppm been disclosed to the requester? These include residual and unreacted monomers, functional additives, stabilizers, colorants, plasticizers, processing aids, oligomers, and catalysts.
• Does this polymer contain any of the following atoms/compounds?
  • Chlorine
  • Tin
  • Arsenic
  • Cadmium
  • Chromium VI
  • Lead (added)
  • Mercury
  • Carbon-Fluorine bond
  • Alkylated Phenol
  • BPA or its structural analogues
• Is this polymer marketed as having antimicrobial properties?
• Is this substance considered a flame retardant containing a fluorine, chlorine, bromine, or iodine atom?
• Is this considered a formaldehyde-based substance or was it generated from the polymerization of formaldehyde?
• Was this substance generated from the reaction of phthalic anhydride with alcohol(s)?
• Is this a wood treatment containing creosote or pentachlorophenol?
  

If the polymer has no CASRN or EC number and all intentionally added substances have been disclosed to the assessor, then the polymer is compliant with the Declare disclosure requirement. A response of “Yes” to any of the chemical screening questions indicates the polymer is considered to be on the Red List. The polymer will be directly added to the Priority List for future addition to the Red List.