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.
Unintentional trace amounts do not need to be reported on a product’s ingredient list, even if unintentional trace amounts of Red List ingredients are expected. A full list of all intentionally added ingredients is still required. The following products, that are likely to unintentionally contain some Red List ingredients, are known to fall under this Clarification, and other products not listed may also apply.
Table 13-1 Materials with Possible Unintentional Trace Amounts of Red List Chemicals
