There are instances when a Red List ingredient 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. Therefore, as a general rule, products should have no “intentionally added” Red List ingredients. Intentionally added ingredients are defined as each discrete chemical, polymer, metal, bio-based material, or other substance added to the product by the manufacturer or suppliers that exists in the product as delivered for final use. Although trace amounts of unintentional ingredients are allowed, a full list of all intentionally added ingredients is still required. The following products are known to fall under this Clarification:

Materials with Naturally Occurring Trace Amounts

  • Clay
  • Minerals
  • Wood
  • Gypsum

Product with Unintentional Trace Amounts from Manufacturing

  • Recycled steel
  • Galvanized metal
  • Portland cement
  • Fly ash
  • Magnesium oxide board
  • Paint

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