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Certifications & International Approvals >> VOC >> Compliance with law

Compliance with law

  • European Directives and Laws
    • Construction Products
    • Food Packaging 
    • Toys
    • VOC in Paints Directive
      • VOC in Paints Directive French Version
  • European National Legislation
    • Pan-European VOC testing package
      • Included programs
      • The TVOC Issue
        • Coverage of TVOC
        • Calculation of TVOC
    • Belgian Regulation on VOC emissions
      • Belgian Regulation on VOC emissions (Dutch version)
      • Belgian Regulation on VOC emissions (French version)
      • Belgian Regulation on VOC emissions (German version)
      • Limit values in Belgian VOC emissions regulation
    • Danish MAL Code
    • French Regulation on VOC emissions
      • French VOC regulation (French version)
        • Produits concernés
        • Les classes d'émissions COV
        • Émissions CMR
        • Protocole AFSSET / ANSES
        • A+ et LEED
      • French VOC regulation (German version)
        • Betroffene Produkte
        • VOC-Emissionsklassen
        • CMR-Emissionen
        • AFFSET/ANSES-Bewertungsschema
        • A+ und LEED
      • Concerned products
      • French VOC classes
      • CMR emissions
      • AFSSET / ANSES guideline
      • A+ and LEED
    • German VOC regulation
      • German VOC regulation - French version
        • Details de la reglementation ABG
          • TR Revêtement de sol Textiles
        • DIBt-ABG - periode de transition
      • German VOC regulation - German version
        • Details der ABG Anforderungen
          • TR Textile Bodenbeläge
        • DIBt-ABG - Übergangsregelungen
        • AgBB und DIBt
          • AgBB und DIBt - Produktgruppen
          • AgBB und DIBt - NIK-Werte
          • Das Ü-Zeichen
          • DIBt und Ü-Zeichen - Abläufe
          • DIBt Zulassungen - Handelshemmnis?
      • Details of ABG regulation
        • TR Textile Floorings
      • AgBB 2015 limits / Grenzwerte
      • DIBt-ABG - transition period
      • German AgBB / DIBt
        • German Ü mark
        • DIBt and German Ü mark - Procedures
        • DIBt approval - barrier to trade?
    • Lithuanian Regulation on VOC emissions
    • Swiss VOC tax
    • Swedish Regulation on VOC emissions
  • US legislation
    • CPSC / CPSIA
    • California Proposition 65
    • CARB VOC in consumer products
    • CARB VOC in architectural coatings
    • SCAQMD VOC limitations
    • US formaldehyde act
    • CARB formaldehyde ACTM
  • Formaldehyde and Indoor Air
    • Formaldehyde - limit values
    • Formaldehyde - testing
   

Compliance with law

Eurofins may support showing compliance of a product with law:

For further information and other regulations please contact our national organisations or our specialists.

 

European Directives and Laws

 

Construction Products

Eurofins may provide support for dealing with many European Laws and Directives. Some examples are:

For further information and other regulations please contact our national organisations or our specialists.

Construction Products Regulation EU 2011/305

Construction products include a wide range of products, such as cement, bricks, wood, flooring, and complex structures such as facades.

To facilitate cross-border trade and to overcome trade barriers in form of national rules and standards, the Construction Products Regulation 305/2011/EU (CPR) was established, superseding Construction Products Directive (CPD) from 1989 (EU Directive 89/106/EEC).

 Role of Construction Products Regulation

The objective of the CPR is not to define the safety of construction products, but to ensure that reliable information is presented in relation to their performance - and all this in a harmonized manner across Europe.

The product shall be followed by a Declaration of Performance with a common technical language, as specified in the corresponding harmonized European product performance standards. The actual requirements still are specified by each EU Member State on its own.

CE marking in this context is the key tool and means just and only that a Declaration of Performance (DoP) following the product was drawn up in accordance with the specifications in the corresponding harmonized European standard.

Further Information

Services

The Eurofins laboratories and notified bodies can help you finding your way through conformity declaration, certification and CE marking, and support with related testing.

  • Important note:

A manufacturer can select a notified body freely and is not restricted to notified bodies in his own country.

Eurofins Product Testing A/S was involved in the development and validation of a harmonized testing method for emissions of volatile substances into indoor air in CEN Technical Committee TC 351, Working Group WG 2. This allows to use the expertise of the world-wide largest VOC emissions testing laboratory also for CE marking, as soon as the respective product standards have been released by CEN.

The resulting standard CEN/TS 16516 was published in October 2013, and Eurofins Product Testing A/S is ISO 17025 accredited and notified for such testing. You may want to see a publication describing CEN/TS 16516, also in comparison with ISO 16000 and EN 717-1 testing (in English) - in Gefahrstoffe Reinhaltung der Luft 74 (2014) 3, 62-68, see www.gefahrstoffe.de.

After additional validation steps were finalized in 2013, and some more refinements were included, the CEN/TS 16516 shall be converted into a final EN 16516 standard until 2017.

CE marking of Construction Products 

 

The CE mark is a prerequisite for a number of products for being marketed in the European Union. The EU Commission says:

By affixing the CE marking on a product, the manufacturer declares on his/her sole responsibility that the product is in conformity with the essential requirements of the directives that apply to it and that the relevant conformity assessment procedures have been fulfilled. Thus products bearing the CE marking benefit from free circulation in the European Market.

Please note also another important remark on the website of the European Commission:

Not all products must have CE marking. It is compulsory only for most of the products covered by the New Approach Directives. It is forbidden to affix CE marking to other products.

Please note that a CE marking does not indicate that a product have been approved as safe by the EU or by another authority. It does not indicate the origin of a product either.

CE marking of Construction Products

CE marking in this context is the key tool of the European Construction Products Regulation (EU 2011/305) and means just and only that a Declaration of Performance (DoP) following the product was drawn up in accordance with the specifications in the corresponding harmonized European standard.

The product shall be followed by a Declaration of Performance with a common technical language, as specified in the corresponding harmonized European product performance standards. The actual requirements still are specified by each EU Member State on its own.

CE marking requires that the EU Commission issued a mandate to CEN to establish a harmonized product standard describing how to specify the basic requirements of a concerned product. The basic properties specified in a harmonized European product standard to be declared with CE marking can cover mechanical stability, resistance to fire, hygienic properties (such as emissions of formaldehyde and of VOCs into indoor air), environmental properties and sustainability.

The harmonized European product performance standards will be challenged by the Commission to include testing and declaration of emissions of volatile dangerous substances, and/or release of dangerous substances into water and soil, with next revision.

Verification systems within CE marking

The CE mark is accompanied by a Declaration of Performance (DoP) containing actual product data. For some products this will be done by declaration of the manufacturer. For other products this will need involvement of independent third-party notified bodies and/or notified laboratories. Eurofins Group operates a number of notified bodies for construction products.

Different construction products will require different verification and monitoring systems for CE marking. These are specified by the European Commission and laid down in the harmonized European standards. Not all construction products are under this regime.

Verification
System

Factory
Production
Control (FPC)

Further testing of samples taken by manufacturer

Assessment of performance, Initial type
testing

Initial inspection (plant and FPC)

Continuous surveillance

Audit - testing of samples taken by Notified Body

1+ + + +++ +++ +++ ++
1 + + +++ +++ +++  
2+ + + + +++ +++  
3 +   ++      
4 +   +      

+    : Manufacturer
++  : Notified laboratory
+++: Notified body

Further Information

Services

The Eurofins laboratories and notified bodies can help to find your way through conformity declaration, certification and CE marking, and support with related testing.

Important note:

A manufacturer can select a notified body freely and is not restricted to notified bodies in his own country.

Eurofins Product Testing A/S was involved in the development and validation of the harmonized testing method for emissions of volatile substances into indoor air in CEN Technical Committee TC 351, Working Group WG 2. This allows you to use the expertise of the world-wide largest VOC emissions testing laboratory also for CE marking, as soon as the respective harmonized product standards have been released by CEN.

The resulting standard CEN/TS 16516 was published in October 2013, and Eurofins Product Testing A/S is ISO 17025 accredited and notified for such testing. You may want to see a publication describing CEN/TS 16516, also in comparison with ISO 16000 and EN 717-1 testing (in English) - in Gefahrstoffe Reinhaltung der Luft 74 (2014) 3, 62-68, see www.gefahrstoffe.de. After additional validation steps, this is published as EN 16516 in 2017.

Eurofins Notified Bodies under Construction Products Regulation 

 

Notified bodies

Notified bodies are testing laboratories and/or certification agencies for approving the assignment of CE marking.

A notified body is accredited in its proper EU member state and then notified to a European list of notified bodies ("NANDO"). Notified bodies are obliged to participate in working groups to exchange experience, and in round-robin tests if laboratory testing is involved.

At present, these laboratories within Eurofins Group are operating notified bodies of some construction products under Construction Products Regulation (EU 2011/305). For more details, please see our notifications at NANDO database:

Services

The Eurofins laboratories and notified bodies can help to find your way through conformity declaration, certification and CE marking, and support with related testing.

Important note:

A manufacturer can select a notified body freely and is not restricted to notified bodies in his own country.

List of products

Here some of the products for which Eurofins provides notified body services:

  • Interior products (EN 16516 testing) of e.g.
    • Floor coverings (EN 14041, EN 14342)
    • Thermal insulation
    • and many more products
  • Road traffic noise reducing devices (noise barrier)
    EN 14388  

    undefined
  • Windows and external pedestrian doorsets
    EN 14351-1

    undefined
  • Curtain walling
    EN 13830

  • Industrial, commercial and garage doors and gates
    EN 13241-1  

    undefined
  • Handles and knobs
    EN 1906

  • External blinds and shutters
    EN 1932

  • Fixed, vertical road traffic signs, EN 12899-1

Contacts

Interior products:

Please see here contact information of Eurofins VOC testing laboratories in Europe, China and Japan:
www.eurofins.com/voc-contacts. This includes a notified testing laboratory for TS/EN 16516.

Noise reduction products, doors, walls, blinds, shutters, and more:

Eurofins Product Testing Italy srl - Modulo Uno, Via Cuorgnè, 21 - 10156 Torino - Italy +39 011 22 22 225

General contact:

Please send an email to producttesting@eurofins.com.

 VOC Emissions under Construction Products Regulation

The Construction Products Regulation (EU 2011/305) (CPR) contains an annex with Basic Requirements. BR 3 dealing with hygiene, health and the environment, basically saying in very general terms that any construction work must not pose any harm to hygiene or health of occupants or neighbours, among others by giving-off of toxic gas, or by presence of dangerous particles or gases in the air. BR 3 mentions, among other issues, the emissions of dangerous substances, volatile organic compounds (VOC), greenhouse gases or dangerous particles into indoor or outdoor air.

As all other elements of this regulation, the purpose is not to influence the level of protection - the purpose is to harmonize technical description of products, for facilitating cross-border trade. The plan is that a CE marked product will be accompanied by a Declaration of Performance (DoP) that allows to see whether the product can be sold in the respective EU Member State. In a country without regulation on VOC emissions you still can sell CE marked products with the NPD option ("no performance declared") in the Declaration of Performance. 

Probably the emissions of products into indoor air will be declared in the form of performance classes, summarizing the many emissions parameters into a set of short codes. These will be defined by the EU Commission in a so-called "delegated act". This will be the basis of a harmonized specification in the harmonized product standards, and then a harmonized declaration of performance of this property.

VOC emissions from products and CE marking

VOC emissions (volatile organic compounds) are an important element of occupants' protection. The plan of European Commission to handle this is:

  • Product groups with major potential impact on indoor air quality shall include hygiene and health aspects, namely the emission of regulated dangerous substances, after next revision of the harmonized product performance standards that are used for CE marking and the related declaration of performance (DoP).
    • This will happen on the basis of mandates to prepare a harmonized product standard issued to CEN by the European Commission; the first mandates were delivered in 2013.
    • The requirements in terms of limit values are specified not for the whole European Union, but as national regulation per Member State.
  • All such product specific harmonized product performance standards shall make use of a horizontal VOC emissions testing method EN 16516, to make comparable this declared property for all product types. The product standards just add on product specific issues such as how to select samples, how to make a test specimen for VOC testing, etc. These standards will also specify which verification system will be applied, and which role external surveillance will play in that procedure
  • The horizontal testing method has been developed in CEN TC 351 WG 2. The resulting standard CEN/TS 16516 was published in October 2013, and Eurofins Product Testing A/S is ISO 17025 accredited and notified for such testing. You may want to see a publication describing CEN/TS 16516, also in comparison with ISO 16000 and EN 717-1 testing (in English) - in Gefahrstoffe Reinhaltung der Luft 74 (2014) 3, 62-68, see www.gefahrstoffe.de. After additional validation steps, this is expected to published as EN 16516 in 2017.
  • Products with always low or even no VOC emissions into indoor air can be subject to CE marking on the basis of a "without testing" (WT) option - or a "without further testing" (WFT) option if an initial testing project showed that any emissions always will be in the best available VOC emissions class. this conclusion can be linked to certain frame conditions, such as maximum thickness of a product.

 Food Packaging Directives

The European regulation (EC) 1935/2004 defines fundamental requirements of food packaging for EU market.

According to this, packaging material shall neither transfer their ingredients into food in quantities that may impair human health, nor deteriorate aroma or taste.

Besides these very general rules some materials are regulated more in detail. Plastics and polymers are regulated in the Regulation (EU) No 10/2011 of 14 January 2011, superseding EU Directive 2002/72/EC. The regulation contains restrictions, migration limit values, and specifications for testing - for safety of food when in contact with plastic materials. While the earlier EU Directive 2002/72 had to be adopted by each Member State in EU with the option of national modifications, this new regulation will become law in all EU Member States directly.

Many links to further information are available from the website of the EU Commission.

Eurofins Offer

Eurofins Product Testing Service and Consultancy on food packaging helps you with:

Further information

Information also is available in Danish,in German, and in Italian.

For further information please contact our specialists:

Packaging Competence Center Denmark
Packaging Competence Center Germany
Packaging Competence Center Italy

+45 70 22 42 76
+49 40 492 94 6900
+39 335 747 02 87

or contact our national organisation in your country.

 European Toys Directive

Toys safety directive 2009/48/EC together with EN 71 norm series specifies the minimum safety requirements for legally selling toys in the member states of the European Union.

For original text of toys safety directive 2009/48/EC, published on June 30, 2009, please click here for EnglishFrenchGerman and Danish version. Earlier version of this directive was 88/378/EEC.

Since 2011 the EU Directive 2011/65/EU - known as RoHS II - requires:

  • One of the important changes is that toys with at least one intended electrical function (electrical power/electromagnetic field) is covered. This means that all electrical toys have to fulfill RoHS II Directive.
  • CE mark is required for all electrical equipment covered by RoHS II. Thus, CE labeled electrical toys have to comply with RoHS II Directive.

Eurofins provides testing, consulting and CE marking by a notified body for showing compliance with the Toys Directive 2009/48/EC

Further information

Contact a Toy Testing expert today !

Toy Testing Competence Center Germany, Hamburg

+49 40 492 94 69 00

or via eMail: toys@eurofins.com
or contact our national organisation in your country.

 VOC in Paints "Decopaint" Directive

Decopaint Directive

European "Decopaint" Directive (2004/42/EC) is limiting the total content of VOCs in certain paints and varnishes and in vehicle refinishing products, with the goal to reduce VOC emissions and thus to limit the generation of ozone in lower atmosphere. Next revision is assumed to include more product groups. Timeline of that revision is unclear.

Any paint, varnish and vehicle refinishing product must not exceed the maximum VOC content limit values as specified in the Directive. The limit values are valid for the ready to use product. And the product must carry a label showing the type of product as given in the Directive, and the contents of VOC in g/l of the product in a ready to use condition.

For more details, please see our information in English, in French, and in German.
See here for German law adopting that regulation.

Testing

VOC content is tested in Europe by injection into gas chromatograph (ISO 11890-2) after dilution. Reactive products are allowed to stand open for 1 hour after mixing before start of test to allow first curing to happen, then VOC content is determined as total volatiles by monitoring weight loss during 1 hour heating at 110 °C (ASTM D2369, in analogy to most recent version of ISO 11890-1). In both cases no subtraction of neither water nor exempt compounds is performed, in contrast to corresponding US test methods.

Since 2010, ISO 11890-1 method is accepted as alternative method (determination of total volatiles by monitoring weight loss during 1 hour heating at 110 °C) besides ASTM D 2369 for products containing 15% solvents or more. Use of ISO 11890-2 continues to be possible as well. Only in the presence of reactive dilutents, ASTM 2369 shall be used and no other standard is accepted for Decopaint purposes for such products - see (Directive 2010/79/EU of 19 November 2010).

CEPE website contains helpful guidance documents on how to group paints into Decopaint categories - e.g. by paint subcategory, or by country and national paint categories.

Testing is different from US SCAQMD and other VOC limitations of coatings.

Eurofins provides testing and consulting for showing compliance with VOC limits as specified in Decopaint Directive, but also for US VOC limitations, e.g. in SCAQMD rules 1113 and 1168 and similar.

SVOC

Upon demand to show compliance with SVOC limits (semi-volatile organic compounds) of the EU ecolabel for paints and coatings, work was started to include a SVOC determination in ISO 11890-2.

European National Legislation

Eurofins may provide support in dealing with national regulations on products. Some examples are:

Please see as well:

For further information and other regulations please contact our national organisations or our specialists.

Pan-European VOC testing package

VOC emissions testing is more and more harmonized across Europe, but still different in detail

In Europe, VOC emissions testing of construction products is harmonized to a large extent via the testing standard prEN 16516. But this regards only the way of testing, not the requirements and limit values. These are specified in a different manner by each relevant regulation, and by several voluntary low VOC labels and certifications.

Some technical differences continue to exist, especially for products that are applied in wet form (coatings, adhesives, sealants and more). Some specifications require more material in the test chamber, other specifications require testing with less material. Some specifications allow some days of separate pre-conditioning before start of test. Other specifications do not accept that. And Germany still uses a different TVOC calculation than other countries.

Eurofins harmonizes most of this into one Europe-wide test setup

Most European low VOC programs go for testing after 3 and/or 28 days storage in a ventilated test chamber. The test results are calculated into air concentrations in the harmonized European Reference Room for most purposes.

This allows to design one single test set-up and obtain the test data that are needed for the very most regulations and voluntary labels in Europe. We just test all relevant parameters at both points of time and then we can report compliance with any existing limit values. Then it can be read with which regulations and labels the product will comply.

This is a Eurofins service that is marketed under the brand "Indoor Air Comfort EU test".

This can cut up to 50% or more of testing costs, compared to separate testing for each program.

The challenge with remaining technical differences is solved by applying the worst-case conditions, meaning the highest amount of product required by any ingoing program. And if not all programs allow a pre-conditioning phase then we skip it for the combined test. This worst-case approach includes that the test result can only be equal or lower, but not higher, for the specific testing conditions per program.

This implies the risk that the product could have complied with a specific label using the test parameters as defined there, but it may fail the test under the worst-case conditions. But on the other hand, if a product passes the worst-case conditions test, then it will pass as well under any easier conditions.

Next level: Indoor Air Comfort product certification

The Eurofins product certification program Indoor Air Comfort and Indoor Air Comfort GOLD goes beyond that. While using the same test data, the lowest limit values of all VOC regulations in European countries are copied together as criteria for the Indoor Air Comfort label. On top of that, the Indoor Air Comfort GOLD label copies together the lowest limit values of most of the voluntary low VOC labels in Europe.

In addition to that, the label is granted only on basis of a certification process with regular factory inspections and re-testing. All this makes the Indoor Air Comfort GOLD label the "Best-of-the-class" label with the most stringent requirements across Europe.

Included programs

Below list describes which programs are included or can be included in the "Indoor Air Comfort EU" testing program.

Harmonization has proceeded recently, but it is far from being complete. Therefore the list also highlights remaining technical differences that can limit the harmonized evaluation for certain products and programs, and what can be done about it.

Programs included are:

1. Always included

  • Belgian VOC regulation
  • French VOC regulation, and proposal of the appropriate VOC emissions class
  • German VOC regulation
    • For DIBt application, two separate test reports are required on top, one version as PDF and one digital report in a special format ("ADAM" report).
    • DIBt wants to be involved in the selection of representative test samples for DIBt application.
    • For parquet coatings, the "Indoor Air Comfort EU" test includes two options.
      • First and generic option is to apply the maximum recommended application amount and the maximum recommended number of layers on a glass plate, but minimum 150 g/m², as specified in EN 16402, and as required in Belgium and in France. 
      • This test will not be accepted for German DIBt application, where it is mandatory to apply the coating on a special oak wood substrate to cover the German regulation. The interaction with the oak support results in a significantly different emissions behaviour, and both methodologies cannot be directly compared.
      • If all regulations are targeted with the test, including Germany, then the German way of testing can be selected. That test can be seen as less-worst-case for the 3 days test results in all cases, and as worst-case for the 28 days test results in many cases. If the test results are very clearly below all limits then the German way of testing can be used also to show conformity with the Belgian and the French regulations.
      • For parquet coatings, the test option needs to be selected explicitly when ordering a test.
  • Indoor Air Comfort product certification
    • Eurofins certification body wants to approve the selection of representative test samples for IAC certification.
    • Additional requirements need to be fulfilled where appropriate, such as VOC content, or use of EMICODE label.

The combined test report includes an evaluation of the VOC emissions against the limits set in the above programs, if desired. The test report delivers information that can be used for an additional evaluation of the VOC emissions against the limits set in the following programs, but such evaluation needs to be ordered explicitly.

2. Optionally included

  • Draft Lithuanian VOC regulation
    • Formaldehyde testing is foreseen by use of EN 717-1, which is inappropriate for non-wooden products and different from the other national VOC regulations.
    • The TS / EN 16516 that is applied for the Indoor Air Comfort EU test showed to deliver similar test results as EN 717-1; it is assumed that such test results will be accepted in Lithuania as well.
    • A response from Lithuanian authorities to our request for clarification is outstanding.
  • Draft Swedish VOC regulation
  • EMICODE
    • For flooring adhesives, the "Indoor Air Comfort EU" test includes the maximum recommended application amount, to cover the German regulation. This may be a significantly higher sample amount than required for EMICODE only.
      In few such cases it may happen that the results do not comply with the targeted EMICODE class, but the product could have complied if the original EMICODE test conditions would have been applied. In those cases, only an additional separate EMICODE test can decide.
    • For parquet coatings, please see the discussion higher up on this page. The EMICODE way of testing parquet coatings is close to the harmonized European way of testing.
  • GUT
    • The combined test is without the GUT odour test, but this can be ordered separately.
  • Several product criteria of
    • EU ecolabel
    • Blue Angel
      • Special issues with the Blue Angel RAL UZ 113, flooring adhesives:
        • The "Indoor Air Comfort EU" test includes the max. recommended application amount, to cover the German regulation. This may be a much higher sample amount than required for Blue Angel RAL UZ 113 only.
        • In few such cases it may happen that the results do not comply with Blue Angel RAL UZ 113, but the product could have complied if the original Blue Angel RAL UZ 113 test conditions would have been applied. In those cases, only an additional separate Blue Angel RAL UZ 113 test can decide.
        • In the case of SMP adhesives, methanol needs to be included in the VOC test.
          This has to be ordered on top of the "Indoor Air Comfort EU" test.
    • Austrian ecolabel
  • M1 in Finland
    • The M1 test cannot be integrated into the Indoor Air Comfort EU test for small and very small surfaces, such as sealants. But this is possible for larger products.
    • The combined test is without the M1 odour and M1 ammonia tests, but these can be ordered separately.
    • Application for M1 label requires that all involved tests are perfomed with the same sample and are reported in the same M1 specific test report.
    • The RTS organization behind the M1 label wants to be involved in the selection of representative test samples.
    • The RTS organization behind the M1 label reserves the exclusive rights to declare conformity with the M1 specifications.
    • The new M1 test method defined different testing conditions for several wet-applied products (adhesives, coatings, sealants). This makes it a challenge to include the Finnish M1 label in a combined test for these products. But we can handle that upon specific request.
  • E1 formaldehyde class for wood-based products
    • The assignment of the E1 class to a wooden product requires different testing methods.
    • The TS / EN 16516 that is applied for the Indoor Air Comfort EU test showed to deliver similar test results based on the 28 days formaldehyde emissions.
    • Therefore an appropriately low formaldehyde test result after 28 days can give an indication that the E1 class can apply. But it is no formal proof.

Not yet included are:

A "Classification System for VOC Emissions of Construction Products used in the Indoor Environment" is under development on European level. The EU Commission wants to establish this as a binding so-called delegated act. Then the EN product standards shall refer to that classification scheme to describe the emissions into indoor air in the Declaration of Performance for CE marking. And the national regulators shall use the same scheme of emissions classes and specify for construction products which levels/classes are accepted in their respective country and which ones are not.

Once established, the "Indoor Air Comfort EU" testing program will allow to assign these EU emissions classes.

Not included are:

The above tests should be ordered separately if needed. It is still cheaper to include these tests into the above described testing program than ordering everything separately.

Not included is as well:

  • Any furniture testing

 The TVOC Issue

The TVOC (Total Volatile Organic Compounds) indicates the total emissions of volatile organic compounds (VOCs). This term

  • TVOC summarizes the emission of substances of very different nature;
  • TVOC therefore is not a parameter of toxicological relevance;
  • TVOC can nevertheless indicate the order of magnitude of all emissions of VOCs, to be used for hygienic purposes;
  • TVOC is a limitation besides the substance specific limit values ("LCI"); the TVOC limit includes the VOCs without LCI value as well.

The term TVOC likewise the underlying term VOC is defined in very different manners across the globe. When running a pan-European or even a global emission test, then the existing test data can be calculated in different manners such that the different TVOC definitions are met.

To compare TVOC emissions values, it can be valuable to understand the most important issues within that definition.

Read more: Coverage of the term VOC

Read more: Calculation of TVOC

Summary

The state-of--the-art of TVOC determination in Europe is to sum all test results of any organic compound

  • that are listed in Annex G of prEN 16516, and/or those
  • that appear within the interval between and including n-hexane and n-hexadecane on a slightly polar gas chromatographic column (which separates a mixture of VOCs into its individual ingredients),
  • using the individual results when they are expressed in toluene equivalents.

The German approach of TVOC determination ("TVOCSPEZ") is to sum all test results of any organic compound

  • that appear within the interval between and including n-hexane and n-hexadecane on a slightly polar gas chromatographic column (which separates a mixture of VOCs into its individual ingredients),
  • using the individual results for all VOCs with a German LCI value when they are calculated with their authentic standards,
  • and using the individual results for any VOCs without a German LCI value (including the non-identified VOCs) when they are expressed in toluene equivalents.

Both calculations can be made from the same set of test data, but they are not inter-comparable and deliver systematically different results.

Coverage of TVOC

Back to TVOC - main page

  • The dominating European definition comes from prEN 16516. It shall be used in any new national regulation on VOC emissions, as well as for CE marking. It is used in Belgian and French national regulations, and in several voluntary labels, such as EMICODE, M1, and Indoor Air Comfort.
    • Traditionally, in ISO 16000-6 and part 9 standards, all measured emissions are VOCs that appear within the interval between and including n-hexane and n-hexadecane on a non-polar gas chromatographic column (which separates a mixture of VOCs into its individual ingredients). For experts: This is a 100 % methyl polysiloxane capillary GC column.
      • This corresponds somehow (but not to 100%) to a volatility range of boiling points between and including 68°C and 287 °C at normal pressure (1013 hPa).
    • prEN 16516 developed the ISO 16000 standards further in many aspects. To improve the detection of many VOCs, the analysis shall be run not on a non-polar gas chromatographic column, but on a slightly polar gas chromatographic column. For experts: This is a 5 % phenyl / 95 % methyl polysiloxane capillary GC column.
    • In prEN 16516, the same limits of the VOC range are applied as for the non-polar column. This means that now all measured emissions are VOCs that appear within the interval between and including n-hexane and n-hexadecane on a slightly gas chromatographic column.
    • As few substances that would be a VOC earlier now may fall out of that range on the slightly polar column, prEN 16516 contains an Annex G with a positive list: Any substance on that list is a VOC even if it lies outside the analytical VOC range when using the new GC column, the slightly polar one.
      • This complication was necessary to obtain comparability with historical test results obtained on the non-polar GC column.
    • Any substances that cannot be detected with the specified testing method are exempted by nature from the above definitions. The testing method includes adsorption of any emissions from the air on Tenax TA, thermal desorption and GC/MS (gas chromatography with mass spectrometric detection).
  • CDPH method in California applies a broader VOC range: All measured emissions are VOCs that appear within the interval between and including n-pentane and n-heptadecane - without detailing a specific gas chromatographic column.

Calculation of TVOC

Back to TVOC - main page

European approach

  • In prEN 16516, all VOCs are calculated with the same surrogate calibration reference, namely in toluene equivalents. Then all VOCs are summed up to obtain the TVOC.
    • Other than in the ISO 16000 standards, only distinct VOCs are included in TVOC summation. ISO 16000 TVOC definition calculates the total signal area within the specified range, including all even smallest VOC emissions.
      • In prEN 16516, the contribution of these smallest VOC traces is not wanted because these VOC traces are prone to very high analytical uncertainty.
      • The VOCs are summed up as toluene equivalents, and not with their authentic result, obtained with substance specific calibration. The reason is that different labs will identify some VOCs in a different manner and with different results. This will influence the applied calibration and quantification. Then the TVOC will show systematic differences between the different testing labs and make this term hardly comparable. But comparability of test results is essential for making use of them.
      • Applying a uniform calibration reference, the toluene equivalents, to TVOC calculation should make TVOC test results better comparable between labs and between products.
    • Californian CDPH method uses a similar calculation approach.

German approach

  • In German AgBB principles and DIBt regulation, another procedure is used that leads to the parameter TVOCSPEZ.
    • In a first run, the approach is very similar to how prEN 16516 is doing.
    • But all VOCs with a German LCI limit value are quantified with their authentic standards, not in toluene equivalents. This is the core difference from prEN 16516.
    • And all VOCs not having a German LCI limit value (including the non-identified VOCs) are quantified in toluene equivalents for the reasons explained just above.
      • This TVOC calculation delivers systematically different results than those obtained with prEN 16516.
      • Scientifically, this calculation method is closer to reality then the procedure in prEN 16516.
      • This can work on a national level. But as soon as you want to compare TVOC values from different countries, e.g. for CE marking, this could work only if all involved countries have the same list of limit values.
      • Once all concerned countries agree on a Europe-wide harmonized list of LCI values, this procedure could be established for whole Europe.
      • Within Europe, this is not yet the case. If we made the calculations with the respective national lists of limit values, then we would end up with a Belgian TVOC, a French TVOC, a German TVOC etc. That would be totally confusing.
    • That is why both prEN 16516, and also the regulators in Belgium and in France, selected to report TVOC in toluene equivalents. Also the Swedish proposal for such a regulation includes that approach.
    • More and more voluntary labels, such as EMICODE, M1, Indoor Air Comfort, European ecolabel etc., select the prEN 16516 approach for the same reason.

Belgian Regulation on VOC emissions

Belgian regulation on VOC emissions from construction products was published on 18th August 2014, first only in Dutch and in French language. See below a summary in English.

The regulation is an interpretation of the European Construction Products Regulation regarding VOC emissions from construction products into indoor air. It is the third such national regulation after those in France and in Germany.

The regulation contains

  • Maximum emission limits for VOCs, TVOC and TSVOC, aldehydes after 28 days testing duration (no test needed after 3 days),
  • See a separate list containing the LCI limit values.
  • Please note that there are NO limits for VOCs without LCI value, different from the German regulation.
  • In Belgium, the VOCs without assigned limit value are regulated via the limit values of the total VOCs and total SVOCs.

The regulation applies to

  • All products used as flooring, or as support, or for installation of floors.
  • This includes coatings, adhesives and screeds. Tiles adhesives also are included.
    Levelling compounds are not included.
  • Exempted are products made of 100% natural stone, ceramics, glass and steel.
  • See the Frequently Asked Questions in English.

The regulation is in force since 1st January 2015 with a sell-through period (non-conform products put on the market before 1st September 2014 can be sold until 1st January 2016).

There are no approval bureaucracy and no labeling requirements. Any manufacturer and distributor needs to have available a "product emissions file" substantiating conformity, based on earlier or actual emissions tests, in a format specified in detail in the regulation. This documentation shall be presented to the authorities upon request only. And there will be market controls.

Eurofins testing offer

Eurofins delivers testing for showing compliance with the Belgian regulation. If a test report is available

  • for German ABG and DIBt regulation,
  • for German ecolabels such as Blue Angel,
  • or for European ecolabels such as EMICODE, GUT or Indoor Air Comfort,

then the data in that test report can be used without new testing, just with new interpretation. Please note that test reports for the French VOC classes do NOT include sufficient data for this purpose.

 Limit values in Belgian VOC emissions regulation

Parameter Limit value after 28 days                             
R value ≤ 1
TVOC ≤ 1 000 µg/m3
TSVOC  ≤ 100 µg/m3
CMR compounds EU categories 1A and 1B  ≤ 1 µg/m3
Acetaldehyde  ≤ 200 µg/m3
Toluene  ≤ 300 µg/m3
Formaldehyde  ≤ 100 µg/m3

Determination: CEN/TS 16516 and relevant CEN product standards.
Calculation of TVOC etc.: CEN/TS 16516.
Calculation of R value: The sum of all ratios Ri (concentration / LCI values) using the European harmonized LCI values (JRC); for substances without such LCI assigned, the German LCI list shall be applied. See the list of LCI values for use in Belgium and the Frequently Asked Questions in English.

See also www.eurofins.com/lci-cli-nik-crel.

Danish MAL Code

The Danish MAL code was established for promoting protection of workers dealing with paints, coatings and similar products.

Any covered product, if used for professional purposes in Denmark, has to show the MAL code on the package and in the Safety Data Sheet.

These products are relevant for the MAL code:

  • Paints, car varnish, similar coatings
  • Glues (adhesives and organic solvents used with glues) for fixing parts:
    • for construction works
    • in car finishing and car repair
  • Fillers, joint sealings and putty used:
    • for construction works
    • in car finishing and car repair
  • Printing inks and similar products used in printing processes
  • Thinners used for above working processes
  • Cleaners, degreasers and more products used for cleaning up after above working processes

A MAL code consists of 2 figures with a hyphen in between, e.g. 3-5.

The figure on the left of the hyphen characterises the necessary protective measures regarding protection against inhalative exposure and is calculated from composition of the product, volatility of the ingredients and their occupational exposure limit values.

The figure on the right of the hyphen characterises the necessary protective measures regarding protection against other routes of exposure such as skin exposure, eye exposure or ingestion.

Click here for more information.

Eurofins offers to perform the calculation and, if necessary, testing for that purpose. Eurofins also can help to find your way towards Danish Product Register for chemical products.

The MAL served as inspiration for similar systems, such as German GISCODE for construction products.

For further information please contact our specialists.

French Regulation on VOC emissions

Compulsory VOC emissions labelling

A French regulation was published on 25 March 2011 with details published on 13 May 2011 regarding a mandatory labelling of construction products installed indoors, floor and wall coverings, paints and lacquers with their emission classes based on emission testing.

This regulation foresees that since 1. Jan. 2012, any covered product placed on the market has to be labelled with emission classes based on their emissions after 28 days, as tested with ISO 16000 and calculated for European reference room - similar to the two other French regulations on emissions of CMR substances.

As this is the same reference room as used in Germany and in Belgium, existing test data for German or for Belgian regulation can be used for assigning an emissions class, without new tests and without conversion of the test results. The same holds true for EMICODE, GUT and Blue Angel. Also other valid information can be used as basis for this assignment of class, such as tests based on ISO 16000, but with shorter testing duration.

The emissions class will be assigned by the manufacturer or the distributor in his self-responsibility.

Concerned products

Click on the headline to read more.

VOC emissions classes

Click on the headline to read more.

CMR emissions

Click on the headline to read more.

"Grenelle Environnement"

Both above initiatives of French government, running under the French name "Le Grenelle Environnement", go for implementing the goals of the national environment and health action plan PNSE 2.

AFSSET guideline (today ANSES)

Click on the headline to read more.

Is the French A+ class sufficient to show LEED compliance?

Click on the headline to read more.

Important links and graphic files

You will find the original texts in two documents - Decree no 2011-321 as publishedArrêté as published.

The graphic files are available for download from an official French website for downloading these files.

The French ministry offers more information on a specific webpage in French language, including a non-exhaustive list of covered and non-covered products (in French language). Should the link not work - search for "Liste indicative des produits décret 2011-321". You will find there also precisions and instructions for testing paints and varnishes, and doors and windows, for their VOC emissions classes (both in French language).

Eurofins offers testing 

  • either just an ISO 16000 test for showing compliance with French regulations, or with AFFSET guideline, or with both
  • or the same test but supplemented with another test method with lower detection method for DEHP and DBP.
  • Background for that differentiation is the fact that there are doubts whether that the specified test method cannot detect such low levels of DEHP and DBP.

Further Information

A technical sheet with more information is available for download in English, in French and in German.

A similar information for Chinese customers is available in Chinese and in English.

Eurofins Product Testing A/S offers all relevant testing. The test programme can be expanded such that the same test can be used also for other regulations and labels in Europe - this will be much cheaper than if you order both tests separately. Reporting is possible in French, in English or in German, or in other languages upon request.

 Concerned products

Walls, ceiling, floor coverings and coatings,

  • Panels for rooms partition and suspended ceiling
  • Insulation products,
  • Doors and windows,
  • All products used for the installation of the products listed above.

The regulation does not cover

  • untreated metal or glass,
  • lockers, iron, screws etc,
  • products used only outside.

For more details, please see a non-exhaustive list of covered and non-covered products (in French language), published by the ministry. Should the link not work - search for "Liste indicative des produits décret 2011-321".

 French VOC classes

Concerned products that are in French market need to be labelled since 1. September 2013. The limit values for the emission classes are listed below.

Classes

C

B

A

A+

TVOC

>2000

<2000

<1500

<1000

Formaldehyde

>120

<120

<60

<10

Acetaldehyde

>400

<400

<300

<200

Toluene

>600

<600

<450

<300

Tetrachloroethylene

>500

<500

<350

<250

Xylene

>400

<400

<300

<200

1,2,4-Trimethylbenzene

>2000

<2000

<1500

<1000

1,4-Dichlorobenzene

>120

<120

<90

<60

Ethylbenzene

>1500

<1500

<1000

<750

2-Butoxyethanol

>2000

<2000

<1500

<1000

Styrene

>500

<500

<350

<250

The label on the products includes a letter indicating the highest (worst) emissions class of the listed individual substances and the TVOC.

There are detailed rules on how the label has to look like. An example is given below. Minimum dimensions are 15 mm × 30 mm. The additional sentence below always shall be placed on the packaging in readable letter size.

CMR emissions

Since 1. Jan 2010, construction products may be sold in France only if they show 28 days emission of CMR substances trichloroethylene, benzene, DEHP and DBP below 1 µg/m³ each, tested with ISO 16000 and calculated for European reference room.

 AFSSET / ANSES guideline

French AFSSET agency (later  called ANSES) published the guideline "Protocole AFFSET", updated in 2009, for limiting VOC emissions into indoor air. It specifies chamber emission testing and limit values after 3 and after 28 days of storage in a ventilated test chamber - the 28 days test is regarded as representative for long-term emissions. This guideline is not binding and there is no procedure for showing compliance, but AFSSET agency recommends to base evaluations of VOC emissions from products on this guideline.

This guideline must not be confused with the French regulation on VOC emissions. AFSSET guideline is NOT the regulation. It is a non-binding guidance that you may use or not, depending on what the market requires.

 A+ and LEED

LEED and US Green Building Council recognize a number of programs and rating systems as sufficient to show LEED compliance. One option is to show compliance with German AgBB criteria; but the formaldehyde emissions accepted by AgBB are higher than approved by US GBC and LEED. Therefore, on top of AgBB compliance, low formaldehyde emissions of 10 µg/m³ after 28 days in a ventilated test chamber must not be exceeded - one way to prove this is that a product is A+ labelled.

But A+ alone is valid to show LEED compliance only for Composite Wood (wood based panels). For floorings, ceilings, walls and insulation, A+ and AgBB compliance are needed.

This can be read from the list of compliant rating systems on the LEED webpages of US Green Building Council - see this extract:

LEED compliance can been shown easily by labelling a product with a certification or labelling program that was approved by US Green Building Council for LEED compliance, and that is shown in the list - such as Indoor Air Comfort GOLD - or Indoor Air Comfort (because this includes AgBB compliance), if the formaldehyde emissions are low enough for French class A+. But also other programs are accepted.

Exception: LEED for Homes in Italy - floorings

For LEED Italia GBC Home V2, credit QI 3, you need to show compliance of floorings with either French class A, or with German AgBB. Please note that this is the weekest requirement of any LEED program across the world. A flooring compatible with LEED Italia GBC Home V2 credit QI 3, based on the French class A, can have much higher VOC emissions than accepted for any other LEED program at any place in the world. LEED compliance is only gien for LEED Italia GBC Home V2 in that case.

 German VOC regulation

Germany has specifications of maximum acceptable VOC emissions from construction products into indoor air in buildings. The background to this is the EU Construction Products Regulation, requiring that no construction product should cause any harm to the occupants of a building. As the EU did not specifically detail this requirement, national regulations may interpret this in different manners.

A German task force of public health authorities, the AgBB, presented an approach for implementing this part of the EU regulation in its AgBB specifications. A comparison with limits in other countries can be seen at www.eurofins.com/lci-cli-nik-crel, and a summary of European regulations at www.eurofins.com/eu-voc-limits.

German regulation and its changes

German DIBt agency took these requirements, added some of their own requirements, and established a system of approval of construction products before entry into the German market.

  • After a decision of the European Court, this can no longer be applied to products that subject to CE marked, meaning for which a harmonized EN standard exists. Please read our special page where we explain the transition period.
  • For other products, meaning those for which no harmonized EN standard exists and therefore CE marking is not possible, the DIBt approval scheme will continue to be required, if it was applied before. DIBt may also add more products to the scope of its regulation.
  • You are not sure whether your product follows a harmonized EN standard and thus can be CE marked? Then please look into the list of harmonized standards (as of November 2015).

ABG - rules after the EU court decision

The German ABG regulation is planned to be in force in on the basis of a modified model building regulation ("Musterbauordnung") on the Federal level and in the States (Länder).

The construction regulation is amended by an ordinance "Verwaltungsvorschrift Technische Baubestimmungen (VV TB)" that indicates for which products there will be requested what additional documentation in Germany. This ordinance superseeds the earlier "Bauregellisten". The link leads to a draft document that was notified to the EU Commission on 21 July 2016 with the notification number 2016/0376/D. This ordinance superseeds the earlier "Bauregellisten".

After several comments from EU members earliest possible date of publication was the 23 January 2017 after implementation of the comments. Publication of the modified and final version is expected in 2017 without explicit date given by German DIBt. The individual states will decide when they will set this into force.

Compliance

Proof of compliance with the draft regulation depends on which set of regulations applies:

  • Products that still can be DIBt approved must show compliance by being labelled with the Ü mark, and by showing the certificate of conformity upon request.
  • Products that no longer can be DIBt approved can show compliance by other means, where details are not yet specified.
    • DIBt recommends showing a valid abZ approval as proof of compliance that is under annual surveillance until its maximum validity. Maximum possible validity of an abZ is April 2020.
    • Many manufacturers are using this possibility. They plan to use their valid abZ as a marketing argument against competing products without an abZ.
    • New products no longer have this possibility.
    • This unequal treatment of old and new products will give severe problems, but nevertheless these are the present plans of the German authorities.
  • Other programs will need to be accepted as well.
  • The Eurofins operated Indoor Air Comfort certification program can be a good choice for that purpose.
  • Attention:
    The Ü mark MUST NOT BE affixed to products and packaging carrying a CE mark after 15 October 2016.

Please see our special page where we explain the transition period between old and new German regulation.

Please read more:

  • Details of the new German ABG regulation.
    As of July 2016, only drafts exist. For further developments please follow our VOC Blog.
    We also explain the transition period between old and new German regulation, and we give some recommendations.
  • The AgBB specifications.
  • The DIBt approval system.
  • The Ü mark. Please note:
    An Ü mark MUST NOT BE affixed to any product that carries a CE mark after 15 October 2016!
  • Testing programs that include the German and the other European requirements:
    www.eurofins.com/voc-europe
  • product certification that includes the German and the other European requirements, adding annual surveillance (factory inspections and re-testing):
    www.indoor-air-comfort.com
    Such a certification program allows to use test results of one product for a whole group of similar products on a reliable basis. And it increases the credibility of low VOC statements with its surveillance program.

Details of ABG regulation

After abolition of the U-mark for CE labelled construction product in Germany, DIBt provided new German requirements called ABG within the administrative regulation MVV TB) on low emitting construction products.

This administrative regulation MVV TB (Muster-Verwaltungsvorschrift Technische Baubestimmungen) was published on 31st August 2017 and next step would be that each single of the 16 federal states in Germany are adapting that regulation into their federal building laws. This will happen step by step and the plan is that all federal states are going to implement this by the end of 2018.

This regulation is targeted at indoor air quality and health in buildings and defines specifications of products that show low VOC emissions, and it limits a number of hazardous ingredients. The ABG regulation is valid for all construction products used in regularly occupied rooms ("Aufenthaltsräume") that contain significant portions of organic nature and that therefore have a disposition to release volatile organic compounds.

These products are specifically mentioned:

  • Floor coverings, incl. floor coatings, screeds and mortars made of synthetic resin, artificial stone made of plastic, sport floorings
  • Flooring adhesives and adhesives for compound structures,
  • Underlays,
  • Coatings for wood floorings and for resilient floorings,
  • Decorative wall coverings made of plastic,
  • Ceiling coverings and constructions with significant portions of organic nature,
  • Insulation material with significant portions of organic nature, e.g. in-situ foams based on phenol resin or on urea-formaldehyde,
  • Treated or glued wood,
  • Fire protective coatings, for steel construction, or on-site applied

Depending on the type of product are several ways of showing compliance with:

Products without product standard (CE mark):

For products without CE mark, the German approval AbZ (Ü-mark) still will be required and can be used as proof of compliance.

Products with product standard (CE mark):

Detailed definitions of the product types and how to test and show compliance with the requirements are only given for textile floor coverings in a technical guideline. For this product group notified laboratories can perform testing according to the technical guideline and the ABG requirements. These laboratory reports can be used as proof for ABG. But there are not definitions concerning the frequency of testing or possible surveillance of the factory production control.

According to DIBt no further technical guidelines will be developed. DIBt proposes to the manufacturers of other CE marked products to purchase a “voluntary approval report” from DIBt defining the product range and testing program followed by a surveillance procedure with annual testing and inspection of the production site. A contract with a surveillance body like Eurofins will be mandatory in that case.

Another option would be to apply for an ETA (European Technical Assessment), but here manufacturers need to make sure, that this will also cover the ABG requirements. This is possibly a more complicated way to show proof with the ABG requirements.

Having a technical guideline only for textile floor coverings and no described mandatory surveillance procedure for textile floorings would mean that textile floorings and other floorings are not going to be treated in the same way. This circumstance might open the door for possible claims against that regulation.

How far other voluntary certification and surveillance systems like Indoor Air Comfort Gold will be accepted as proof of compliance, is not clearly defined in the MVV TB or ABG, but not excluded either. This depends on how far the federal building authorities or tendering company/authority will accept this. Eurofins is going to evaluate the possibilities for this.

Indoor Air Comfort Gold and voluntary DIBt approval reports:

The testing requirements of ABG are already included in the Indoor Air Comfort Gold specifications and will be tested automatically. Eurofins is a notified testing lab for DIBt and for the surveillance procedure as well. If a manufacturer choses to purchase a voluntary approval by DIBt followed by a surveillance contract, then this can be combined with an Indoor Air Comfort Gold Certification. For existing Indoor Air Comfort Gold clients no additional annual costs for testing or inspections will occur, only the costs for the voluntary DIBt approval.

For textile floor coverings Eurofins as a notified laboratory can perform the necessary products groupings, testing of the representative worst case and deliver the necessary documentation according to the technical guideline for textile floor coverings. This can happen without involving DIBt and the voluntary DIBt approval.

What to do now?

DIBt is already offering the voluntary approval reports. If this is a way a manufacturer wants to go then this can be applied to at DIBt with a surveillance contract by Eurofins. We are ready to help manufacturer with this!

If manufacturers do not want to be the early birds in this matter, they can await implementation of the federal laws within 2018 and then react on requests from their clients.

Indoor Air Comfort Gold certification will provide all necessary documentation for the voluntary DIBt approval.

TR Textile Floorings

The draft German regulation on low emitting construction products (ABG) which has been developed on the basis of a modified German model building regulation is intended to be released  in October 2016 (see pages 231-244 of the Draft of an ordinance "Verwaltungsvorschrift Technische Baubestimmungen (VV TB)" (available in German only)). In the mean time an updated draft of the ABG regulation was notified to the EU for commenting with the notification number 2016/0376/D since July 2016 (in German language). There were no changes regarding VOC emissions compared to the second draft.

The ABG regulation specifies requirements regarding emissions from construction products into regularly occupied rooms, and limits of certain hazardous ingredients.

These requirements and their documentation are intended to be substantiated in product specific Technical Rules. A draft Technical Rule on textile floorings ("Technische Regel Textile Bodenbeläge", TR TB) was made available for comments in March 2016 as a first example. See pages 245-251 of the draft of an ordinance "Verwaltungsvorschrift Technische Baubestimmungen" (VV TB, available in German only). There were no changes regarding VOC emissions in the notified version, compared to the second draft.

Technical Rule "Textile Floorings"

The essentials of the specifications in the draft TR TB are:

  • Definition of the scope of the Technical Rule.
  • Definition that emissions of hazardous substances are determined and evaluated by an emission chamber test by a qualified "sachverständige Prüfstelle".
  • Criteria for grouping of similar products, to restrict the testing burden to representative samples.
    • The product with the expected highest emissions is regarded representative - normally this is the heaviest or the thickest product, where the thickest product shall be selected in case of doubt.
  • Sample collection, transport and storage of a sample for testing.
    • A model sampling protocol is available in an annex.

Other regulations concern:

  • Preparation of the test specimen.
  • Test chamber conditions (loading factor, testing climate).
  • Emissions testing after 3 and 28 or 3 and 7 days. A stop of the test after just 3 days no longer is accepted.
  • Determination of PAH content in the case of bitumen backing.

Acceptance criteria are specified for a qualified "sachverständige Prüfstelle". Both ISO 17025 accreditation and notification for EN 16516 will be required - Eurofins Products Testing A/S qualifies for both criteria.

AgBB 2015 limits / Grenzwerte

Below table summarizes the limit values of AgBB 2015 scheme for emissions from construction products. It also indicates which parameters are different from the European harmonized approach as in prEN 16516.

Table 

Parameter Unit

Limit value

Deviation

Emissions after 3 days

     1
TVOCspez mg/m³  10  1
Each carcinogen substance EU Category C1A or C1B mg/m³  0,01  1
Emissions after 28 days      
TVOCspez mg/m³  1,0  2
Each carcinogen substance EU Category C1A or C1B mg/m³  0,001  
Sum of SVOC mg/m³  0,1  3
VVOC *      4
Sum of the VOC without German LCI value mg/m³  0,1  5
R value based on German LCIs -  1  
Ammonia ** mg/m³  0,1 6
Nitrosamines ** mg/m³  0,2 6
Limited within the list of LCI values, example:      
Formaldehyde mg/m³
µg/m³
 0,1
100
 

Abbreviations 

TVOC: Total volatile organic substances
TVOCspez: TVOC calculated as specified by AgBB 

SVOC: Semi-volatile organic substances 
VVOC: Very volatile organic substances 

R value / R-Wert: ∑ Ri = ∑ (Ci / LCIi) / ∑ Ri = ∑ (Ci / NIKi)
LCI: Lowest concentration of interest = assessment  value for the emissions of an individual substance

*:  Individual VVOC may be limited by LCI values.
   

**: Only for products from which these substanes could be emitted. Not in AgBB, but in draft German regulation (2016).
    

Deviations from European harmonized approach as in prEN 16516:

  • 1. Emissions after 3 days are limited only in Germany, in no other European country. But prEN 16516 allows to test such emissions.
  • 2. The TVOCspez is calculated in a different manner in Germany than the TVOC in prEN 16516, and in any other European country, see the explanations at www.eurofins.com/TVOC-issue.
  • 3. The sum of SVOC is calculated in a different manner in Germany than the TSVOC in prEN 16516, and in any other European country, because all SVOC with an LCI value are taken out of the "Sum of SVOC" value only in Germany.
  • 4. Any VVOC (but a limited number of VVOCs only) are limited only in Germany, in no other European country. But EN 16516 allows to test such emissions, even though without giving specific detailed instructions on how to test these.
  • 5. Outside Germany, the substances not having been assigned an LCI value are restricted only with the TVOC and the TSVOC limits. In Germany, they are additionally restricted with this value.
  • 6. Ammonia and Nitrosamines are restricted only in Germany, in no other European country. But EN 16516 allows to test such emissions, even though without giving specific detailed instructions on how to test these. An amendment of prEN 16516 with details of testing ammonia is under preparation in CEN TC 351.

DIBt-ABG - transition period - Transition from DIBt to ABG regulation in Germany

DIBt informed about a draft of the German ABG requirements on low emitting construction products on 6 January 2016 in German language with a third version from 29 June 2016. The new regulation is planned to be in force in 2017 without explicit date. It is targeted at indoor air quality and health in buildings. The regulation gives specifications of products that show low VOC emissions, and that are free of a number of hazardous ingredients, and it says that such products shall be used to obtain a healthy indoor environment. The limit values are mostly the same as under the DIBt regulation.

No Ü mark together with a CE mark

At the same time DIBt will stop its approval system with abZ approvals and Ü mark for all products that can be CE marked, meaning for which a harmonized EN standard exists. Deadline also is 15 October.

For other products, meaning those for which no harmonized EN standard exists and therefore CE marking is not possible, the DIBt approval scheme will continue to be required, if it was applied before. DIBt may also add more products to the scope of its regulation.

You are not sure whether your product follows a harmonized EN standard and thus can be CE marked? Then please look into the list of harmonized standards (as of November 2015).

Transition period for CE marked products 

The following applies to all products that can be CE marked, meaning for which a harmonized EN standard exists, and that were within the scope of the DIBt abZ approval system:

  • Any existing abZ approval and the related surveillance (factory inspections, re-testing) is required on the German market until 15 October 2016.
  • Applications for new approvals, and for a change of any existing approval, are no longer accepted since end of January 2016. Any applications reaching DIBt before that deadline will need to be decided until 15 October 2016.
  • After 15 October, an abZ approval cannot be required by German authorities any longer.
  • The Ü mark MUST NOT BE affixed to products and packaging carrying a CE mark after 15 October 2016 any longer.
  • DIBt cannot prescribe how to show compliance with the new German ABG regulation after 15 October 2016 for products that can be CE marked.
    • DIBt recommends to show a valid abZ approval as proof of compliance that is under annual surveillance until its maximum validity. Maximum possible validity of an abZ is April 2020.
      • Many manufacturers are using this possibility. They plan to use their valid abZ as marketing argument against competing products without an abZ.
      • New products do not have this possibility any longer.
      • This unequal treatment of old and new products will give severe problems, but nevertheless these are the present plans of the German authorities.
  • Other programs must be accepted as well.
  • The Eurofins operated Indoor Air Comfort certification program is another good choice for that purpose.

No change will occur for other products, those that cannot be CE marked. They may need to apply for an abZ approval and an Ü mark, if they are covered by the DIBt regulation.

Recommendations

If a product can be CE marked, no new German abZ approval and no update of an existing approval is possible any longer (if not an application had been sent in before February 2016).

But Eurofins offers an alternative:

  • The Indoor Air Comfort (IAC) label and product certification allows to show compliance with any VOC regulation across Europe in one run, among that the forthcoming German ABG regulation.
  • The Indoor Air Comfort GOLD label is the best-of-the-class independent label on the market.
    It includes the VOC requirements of most of the voluntary ecolabels, on top of the regular IAC label.
  • The surveillance with inspections and re-testing is handled in a pragmatic and targeted manner, but they are on the same quality level as the present DIBt requirements.
    If you continue surveillance of existing DIBt approvals, then both can be done in one run with only small additional costs.
  • The certificates can be downloaded for free from our website: www.eurofins.com/iac-certified.
  • The related lab tests are accepted by many voluntary programs, such as EMICODEBlue AngelM1FloorScore, …

 German AgBB / DIBt

Germany published restrictions of VOC emissions from construction products. The background to this is the EU Construction Products Regulation, requiring that no construction product should cause any harm to the occupants of a building. As the EU did not specifically detail this requirement, national regulations may interpret this differently.

A German task force of public health authorities, the AgBB, presented an approach for implementing this part of the EU directive. The AgBB used and updated an earlier project on assessment of emissions from carpets (ECA no. 18), for producing its AgBB specifications.

Situation changes for some product groups

German DIBt institute in Berlin, a public agency for construction products, used the AgBB approach for implementing an approval system for several construction products installed in regularly occupied interior spaces, based on documentation of low VOC emissions.

This regulation will be terminated and substituted by a new ABG regulation on 15 October, but still required until that date, for the following product groups:

  • Floor coverings (EN 14041, EN 14342), DIBt group #156
  • Liquid floor coatings (EN 13813), DIBt group #156
  • Sport floorings (EN 14904), DIBt group #154
  • Combined floorings, DIBt group #150
  • Decorative wall coverings (EN 15102), DIBt group #159
    • Wall coverings are included only if
      • these are not made entirely of paper; this covers vinyl, textile, cork products etc.;
      • paper-made wallpapers only if they are photo-printed.

No change for some product groups

This regulation will continue to be required on the German market also after 15 October for the following product groups:

  • Adhesives (excluding tile adhesives), DIBt group #155
  • Coatings for floor coverings, DIBt group #157
  • Underlays, DIBt group #158

A separate area covers:

CE marked products from the above list can be sold in Germany. But for being installed in German buildings, these have to be approved by DIBt after fulfilling the supplementary AgBB requirements on emissions and carry the Ü mark. External surveillance with yearly factory inspections and re-testing is required for most of these products, but not for coatings and adhesives. For these, re-testing every five years will do.

Please find here latest notified version of DIBt regulation (2009 / 0162). Detailed and updated documents (some of them also in English) can be seen and downloaded from the webpages of German DIBt Section II 4.

Most recent list of NIK / LCI values

LCI values are limit values for Volatile Organic Compounds (VOCs), to be applied to VOC emissions test results after 28 days.

AgBB published the 2015 list of its NIK (LCI) values that can be downloaded from German EPA (UBA). Compared to the 2012 version, it contains significant changes, see our VOC Blog. Firstly, the LCI values are harmonized with the European LCI values, as far as such limits are available. And several VVOCs now have an LCI limit, such as formaldehyde (100 µg/m³), acetaldehyde (1200 µg/m³), butanal (650 µg/m³), and acetone (1200 µg/m³).

Another new LCI limit was assigned by AgBB to the SVOC "Other saturated aliphatic hydrocarbons C17 to C22" (1000 µg/m³); earlier these were subsummized under the TSVOC (100 µg/m³). Now having an LCI value, these substances shall not be included in the TSVOC any longer for AgBB, but in the TVOC. That change leads to a fairer and more appropriate evaluation of mixtures of aliphatic hydrocarbon mixtures than before.

The AgBB limits are explained in a list here: www.eurofins.com/agbb2015-limits.

Please see also a comparison of the different limit values in different countries and programs: www.eurofins.com/lci-cli-nik-crel.

When to apply which NIK (LCI) list for DIBt testing?

  • Tests for new approvals, or for renewals:

AgBB 2015 LCI limits.

  • Test within surveillance during validity of the approval:

During tests from inspections, the main goal is to show that the approved product and the inspected products are the same in terms of emissions into indoor air. For that reason, the same test conditions apply as for the test that was the basis of the respective approval - and therefore, earlier versions of the AgBB LCI limits may apply.

Procedures

Successful application for the approval and the Ü mark is a prerequisite for entering ther German market - but only for the above listed covered products. Please see our special page describing the application procedures.

 German Ü mark

The German Ü mark for construction products is administered by DIBt (German Institute for Construction Technology) and shows that the Ü marked product conforms with the approved product - on the basis of additional German specifications, on top of European CE marking.

Ü stands for "Übereinstimmung" (conformity).

Successful application for the approval and the Ü mark is a prerequisite for entering ther German market - but only for the covered products. Please see our special page describing the application procedures.

Barrier to trade?

German DIBt agency lost at European Court where the European Commission claimed that Germany raised "barriers to trade" with its current rules and practices (Bauregellisten) concerning a specific German approval of construction products. This was said to "breach of EU Single Market rules". See our special page for reading what this will mean for the Ü mark in the future.

According to a recent communication by DIBt (on 06 January 2016):

  • new regulation "ABG" will be in force after 15 October 2016.
  • Products that still can be DIBt approved must show compliance by showing that approval and carrying the Ü mark.
  • Products that no longer can be DIBt approved can show compliance by other means, where details are not yet specified.
    • The Ü mark MUST NOT BE affixed to products and packaging carrying a CE mark after 15 October 2016 any longer.
    • DIBt recommends to show a valid abZ approval as proof of compliance that is under annual surveillance until its maximum validity. Maximum possible validity of an abZ is April 2020.
      • Many manufacturers are using this possibility. They plan to use their valid abZ as marketing argument against competing products without an abZ.
      • New products do not have this possibility any longer.
      • This unequal treatment of old and new products will give severe problems, but nevertheless these are the present plans of the German authorities.
    • Other programs will be accepted as well.
    • The Eurofins operated Indoor Air Comfort certification program is a good choice for that purpose.

Please follow our VOC Blog to stay updated on this issue.

DIBt and German Ü mark - Procedures

Application for approval of a product by DIBt and for granting of the Ü mark requires a number of steps.

Application, Approval, Surveillance

  • Check the DIBt webpage for whether the product needs an approval.
  • Read from the DIBt webpage how to apply and which documents must be delivered. Instructions can be found here:https://www.dibt.de/en/Approvals/abZ.html.
  • Normally the recipe of the product will be required.
  • Collect the requested information, send it to DIBt, best try to make an appointment.
  • DIBt will evaluate the delivered information and select sample(s) out of the product portfolio that are regarded as being representative for testing, after grouping similar products in classes.
  • You can ease this step by delivering a qualified proposal. You can also deliver existing VOC emissions test reports, if available.
  • Order DIBt conform VOC emissions testing from a DIBt approved testing lab. Best from Eurofins Product Testing A/S.
  • DIBt will supply you with a list of accepted labs. Eurofins Product Testing A/S in Denmark is one of the mostly used labs on that list.
  • You will receive a German General Approval (ABZ) that will contain additional duties and specifications.
    Any change compared to the content of the ABZ approval shall be notified to DIBt. Such changes of the ABZ cost money another time.
  • This approval runs under the condition that you sign a surveillance and certification contract with a "ÜZ" certification body - except for adhesives and parquet coatings that do not need such external surveillance.

Please be aware that it can take a long time before DIBt reacts.

Eurofins can supply you with contacts to experienced consultants who support you in communication with DIBt if you need support.

VOC emissions testing

A DIBt approved testing lab will perform VOC emissions tests following the specific DIBt testing requirements. These details are not public, but the DIBt approved labs are instructed how to do.

Emissions are tested by placing a test specimen in a ventilated test chamber during 28 days. In some cases, shorter testing duration can be accepted by DIBt.

The test chamber represents the European Reference Room of prEN 16516 in a small scale, typically with 119, 238 or 1000 litres volume. Air samples are collected at the outlet of the test chamber for analysis and evaluation.

The 3 days test is representative of a building renovation case with early re-occupancy and prohibits excessively high initial VOC emissions and the presence of carcinogens. The 28 days test is seen as representative of long-term emissions.

The limits are specified for:

  • Carcinogens after 3 and 28 days
  • Total VOC after 3 and 28 days
  • Total SVOC after 28 days
  • Single VOC compounds with "LCl" limit values (also called NIK in German) after 28 days.
    (More than 170 NIK values have been published)
  • Single VOC compounds without such LCI limit values (including the non-identified VOCs) after 28 days.

Approval

The German General Approval (ABZ) by DIBt normally is valid for 5 years and entitles to use the Ü mark, but only after a contract between the manufacturer and a DIBt approved independent surveillance and certification body ("ÜZ body") has been signed, and the surveillance has started. Only adhesives and parquet coatings do not need such external surveillance.

The product will be listed by DIBt in its public database with the number of the ABZ approval and its validity period.

Continuous external surveillance

The surveillance goes for monitoring that the product properties as described in the ABZ approval do not significantly change, compared to the approved product.

The inspector of the ÜZ body will inspect the quality management system (as far as VOC emissions into indoor air are concerned) at the manufacturing site - typically on an annual basis. This is not restricted to German or European manufacturing sites, it can be performed anywhere in the world.

The inspector then will take samples for spot checking whether the manufactured product conforms to the approved product within an acceptable range. Re-testing can be a simpler and shorter test than the initial test, if the ABZ approval allows that explicitly. The decision is not taken by the inspector, bnor the manufacturer, it only follows the wording in the ABZ approval.

The ÜZ body will issue a surveillance report and a conformity certificate if this corresponds to the findings of the inspection and the re-testing.

Adhesives and parquet coatings do not require such external surveillance. Re-testing every 5 years will do.

After 5 years the approval can be renewed upon application, including a full test.

When to apply which NIK (LCI) list for DIBt testing?
  • Tests for new approvals, or for renewals:

AgBB 2015 LCI limits.

  • Test within surveillance during validity of the approval:

During tests from inspections, the main goal is to show that the approved product and the inspected products are the same in terms of emissions into indoor air. For that reason, the same test conditions apply as for the test that was the basis of the respective approval - and therefore, earlier versions of the AgBB LCI limits may apply.

Recent News

According to a recent communication by DIBt (on 06 January 2016):

  • new regulation "AGB" will be in force after 15 October 2016. CE marked products no longer will need an abZ approval and an Ü mark after 15 October 2016.
  • Products that still can be DIBt approved must show compliance by showing that approval and carrying the Ü mark.
  • Products that no longer can be DIBt approved can show compliance by other means, where details are not yet specified.
    • The Ü mark MUST NOT BE affixed to products and packaging carrying a CE mark after 15 October 2016 any longer.
    • DIBt recommends to show a valid abZ approval as proof of compliance that is under annual surveillance until its maximum validity. Maximum possible validity of an abZ is April 2020.
      • Many manufacturers are using this possibility. They plan to use their valid abZ as marketing argument against competing products without an abZ.
      • New products do not have this possibility any longer.
      • This unequal treatment of old and new products will give severe problems, but nevertheless these are the present plans of the German authorities.
    • Other programs will be accepted as well.
    • The Eurofins operated Indoor Air Comfort certification program is a good choice for that purpose.

Please follow our VOC Blog to stay updated on this issue.

DIBt approval - barrier to trade?

German DIBt agency lost at European Court where the European Commission claimed that Germany raised "barriers to trade" with its current rules and practices (Bauregellisten) concerning a specific German approval of construction products. This was said to "breach of EU Single Market rules".

This special decision referred to combustion properties, where DIBt requested national approval because DIBt deemed it necessary that additional testing parameters are declared, on top of CE marking.

The court confirmed that it is not allowed to establish a national approval system for properties of products that are dealt with in CE marking and the related harmonized EN standard.

Please see more details here:

Will this decision affect the DIBt approval system and Ü mark, regarding VOC emissions?

The court statement clearly said that Germany must not establish a national approval system on top of CE marking.

As soon as a product is CE marked, no Ü mark must be required in the future - even before the declaration of performance for CE marking has to include a statement on emissions of hazardous substances into indoor air, and before the related CE standard (e.g. EN 14041, EN 14342 etc.) includes a statement on the emissions and specifies how to declare that performance.

According to a recent communication by DIBt (on 06 January 2016):

  • new regulation "AGB" will be in force after 15 October 2016.
  • Products that still can be DIBt approved must show compliance by showing that approval and carrying the Ü mark.
  • Products that no longer can be DIBt approved can show compliance by other means, where details are not yet specified.
    • The Ü mark MUST NOT BE affixed to products and packaging carrying a CE mark after 15 October 2016 any longer.
    • DIBt recommends to show a valid abZ approval as proof of compliance that is under annual surveillance until its maximum validity. Maximum possible validity of an abZ is April 2020.
      • Many manufacturers are using this possibility. They plan to use their valid abZ as marketing argument against competing products without an abZ.
      • New products do not have this possibility any longer.
      • This unequal treatment of old and new products will give severe problems, but nevertheless these are the present plans of the German authorities.
    • Other programs will be accepted as well.
    • The Eurofins operated Indoor Air Comfort certification program is a good choice for that purpose.

Please follow our VOC Blog to stay updated on this issue.

Lithuanian Regulation on VOC emissions

The draft Lithuanian Hygiene Norm HN 105:2014 ‘Polymer construction products and polymer furniture materials’ was notified to the EU commission in 2014. This draft regulation was an interpretation of the European Construction Products Regulation regarding VOC emissions from construction products into indoor air. The regulation contained emissions limits for VOC, TVOC and TSVOC including a list of LCI values in a chamber test after 3 and 28 days. It was intended that this regulation applies to all construction products and furniture having a polymer organic compound (large molecular) as a main material or a binder. This was not limited to solid products, it also includes wet-applied products.

However the EU emission did not approve this draft, because it was contravening the REACH regulation. As a consequence the Ministry of Health of the Republic of Lithuania decided to put the procedure on hold and the Hygiene Norm HN 105:2014 will not be published. The former (existing) Hygiene Norm HN 105:2004 ‘Polymer construction products and polymer furniture materials’ remains valid. This regulation limits the content of heavy metals in wall coverings and formaldehyde release of wooden panels according to the E1 and E2 classes.

 Swiss VOC tax

The VOC tax in Switzerland aims at reducing VOC emissions from products by applying financial disadvantage to high VOC products. This concerns VOC emissions during manufacture, and VOC contents in the product. But the limit values werre specified for VOC content. Testing is not necessary, self-declaration is good enough, but random control by Swiss customs may occur.

Products concerned are those with more than 3% by weight VOC - but only those products and those VOC, that are on a substances positive list and a products positive list. The tax is CHF 3 per kg VOC since 1st January 2003, to be paid at place of manufacture if in Switzerland, else when importing.

Eurofins services

Eurofins offers documentation by testing of compliance with above listed specifications as regards VOC content of products.

Swedish Regulation on VOC emissions

The Swedish Chemical Agency, Kemikalieinspektionen, had received the task to investigate a Swedish regulation limiting the VOC emissions from construction products. A report was published in 2015.

It proposes a regulation specifying that all products used at interior floors, walls and ceilings shall comply with a list of limit values when tested after 28 days storage in a ventilated test chamber.

Both the limit values and the documentation duties are very much in line with the existing Belgian regulation, but with some exceptions:

  • The proposed Swedish regulation covers all interior floors, walls and ceilings, while the Belgian regulation today is applied to flooring products only (the application to walls and ceilings still is under preparation).
  • The proposed Swedish regulation does not contain limits for sum parameteres, such as TVOC, TSVOC and R value.
  • The proposed Swedish regulation does not contain limits for formaldehyde and acetaldehyde, and it does not include an especially low limit for toluene, other than the Belgian regulation.

If the regulation is adapted by the Swedish government, then it could be in force from early 2018 on.

The proposed regulation could harmonize with the plans to include a declaration of performance regarding VOC emissions into the regulations on CE marking. Compliance with the proposed regulation could also be shown with an Indoor Air Comfort or an Indoor Air Comfort GOLD certificate which combines the regulations in all EU Member States into one documentation and one certification program.

For further reading:

Please follow our VOC Blog if you want to be updated with any further News on this subject.

US legislation

Eurofins may provide support in dealing with national regulations on products. Some examples are:

For further information and other regulations please contact our national organisations or our specialists.

CPSC / CPSIA

CPSIA and CPSC

CPSIA stands for "Consumer Product Safety Improvement Act", an American regulation that aims to improve safety of consumers with main focus on children's products. CPSC stands for U.S. Consumer Product Safety Commission.

Who is affected by CPSIA ?

Any party manufacturing or exporting toys to the USA must show a general certificate of conformity, based on testing.  ASTM F963 testing, the US equivalent to EN71, has always been necessary.

CPSIA currently focuses on the total amount of lead in paints. This must be tested and certified by a CPSC accredited Lab (e. g. Eurofins, see accreditation details for Europe and for China - both serve the US market, too).

Regulated products

  Third-Party Testing required since
Lead in Paint December 21, 2008
Cribs and Pacifiers January 2009
Small Parts February 2009
Metal Jewellery March 2009
Baby Bouncers, Walkers and Jumpers June 2009
300 ppm Lead Content August 2009
CPSC Children's Product Safety Rules September 2009

 

Sources of original information

Toys safety in Europe

Please follow these links for toys safety in Europe:

Further information:

For further information and for requests for testing please contact our national organisations or our specialists.

California Proposition 65

California Proposition 65, the Safe Drinking Water and Toxic Enforcement Act of 1986, constitutes the basis for a legislation on transparency of exposure for consumers before they purchase a product - not limited at all to water safety as the titel might pretend. Prop 65 often is used as reference for specifying carcinogenic compounds in other regulations and specifications as well, e.g. in CDPH Section 01350 regarding emissions from products into indoor air.

Any consumer product, if manufactured, handled or sold in California by a business with more than 9 employees, is covered by this regulation. Example products are toys, furniture, paints, cosmetics, glass, ceramics, textiles, electrical devices, and many more.

Chemicals involved are those that can cause cancer or reproductive harm such as birth defects (CMR). Examples of listed compounds comprise formaldehyde, benzene, lead, crystalline silica, some heavy metals, Bisphenol A etc.

A warning must be placed on the product if any CMR chemical is contained in the product and can lead to health risk by exposure during its use. This is the case if the exposure level is assumed to cause a risk of 1 additional case of any such harm per 100.000 people.

Exposure can be calculated from composition with the worst-case assumption that the whole amount of the chemical is released. Another option is to determine average release rates, such as emission into indoor air or migration into drinking water or food. Exposure is calculated over 70 years life duration.

Risk is estimated from exposure pathways and quantity in comparison with limit values (if available). As an example, release of particles from painted wall can occur in very small quantities and the particles can be dispersed in indoor air. If e.g. lead is contained in that paint then this small release can already make a Proposition 65 warning necessary.

Prop 65 Warning - is it needed?

If a manufacturer wants to identify the need for placing a warning then the following steps need to be followed:

  • Identify whether any chemical in your product is on the Prop65 list of chemicals. Beware of possible updates not yet reflected here with this link.
    Involve your suppliers for the components that they deliver.
  • If any chemical in your product is present, then you either place the warning, or you identify whether consumer exposure is lower than the respective Safe Harbor Level - taking into account all routes of exposure during whole lifetime. Beware of possible updates not yet reflected here with this link.
  • If the exposure assessment confirms the risk, place the warning; else you can do without.

There are no specifications available of the formal path for showing compliance. At the end of the day, in case of a litigation suit against a non-labeled product a court will decide whether a delivered documentation of no risk is regarded convincing.

As many lawyers are very active on this field, many businesses prefer to place a Proposition 65 warning even if there is severe doubt that their products really may show human exposure that causes any health risk. This over-cautious attitude may protect the individual business, but it counteracts the intention of Prop 65 regulation if all products carry a warning, and nobody can distinguish between real and non-real hazards.

Prop 65 warnings

If a Prop 65 warning is necessary, then it must have one of these text examples, as appropriate:

  • WARNING: This product contains a chemical known to the State of California to cause cancer.
  • WARNING: This product contains a chemical known to the State of California to cause birth defects or other reproductive harm.
  • WARNING: This product contains a chemical known to the State of California to cause cancer and birth defects or other reproductive harm.

The warning must be placed such, that a consumer easily recognizes it before purchase, e.g. on product packaging, in marketing material, in advertisements, on homepages etc.

Eurofins services

Eurofins can provide you with

  • Survey whether your product and its formulation are concerned by Proposition 65 limit values
    • Perform a literature and experience study on similar products if you do not know the chemical composition of your specific product
  • Analyze the content of such chemicals in your product, e.g.
    • content of phthalates, lead, mercury, arsenic, formaldehyde
    • release of such chemicals from your product, e.g. VOCs, formaldehyde
  • Specify and use an exposure model for concluding with a good risk estimate

In any case it is strongly recommended to search legal advice before any final conclusions.

Further information

Contact to Eurofins Support and Laboratories

Eurofins proposes consulting and testing for solving your Prop 65 issues. Please contact our specialists.

 

 CARB VOC in consumer products

California Air Resources Board (CARB) issued regulations on limitation of VOC content in consumer products, namely antiperspirants and deodorants, aerosol coating products, hairsprays, cleaners, air fresheners, adhesives, and many more.

The intention is to reduce the amount of smog-forming volatile organic compounds (VOC), toxic air contaminants, and greenhouse gases that are emitted from the use of chemically formulated consumer products. California ARB reports that its consumer products regulations have resulted in reduction of emissions of nearly 50 percent since 1990. The latest amendments to the regulation intend to further reduce the amount of air pollutants emitted from various categories of consumer products.

  • Article 1 covers antiperspirants and deodorants.
  • Article 2 is the "general consumer products regulation."
  • Article 3 covers categories of aerosol paints and coatings.

The above three regulations affect 115 consumer product categories by setting 150 volatile organic compound (VOC) limits.

  • Article 4 is a voluntary emissions trading program for consumer products, and aerosol paints and coatings, called the Alternative Control Plan (ACP) regulation.
  • Article 5 is a voluntary program, the Hairspray Credit Program Regulation.

The regulation is complex, therefore you will find a number of valuable links to more information:

Eurofins services

For the time being, Eurofins Product Testing A/S in Denmark does not offer related testing.

 CARB VOC in architectural coatings

CARB regulations on VOC in architectural coatings

In California, VOC regulations are released by district. The most well-known regulation is issued by the Californian South Coast Air Quality Management District (SCAQMD), based in Diamond Bar and covering Orange County and parts of Los Angeles, Riverside and San Bernadino counties.

The state-wide agency California Air Resources Board (CARB) released kind of a model for such regulations in California districts. This is known as Suggested Control Measure (SCM) in its version of 2007.

Principles

Purpose of this limitation is to protect urban outside air against smog, especially against formation of ground level ozone. California Air Resources Board ARB offers a list with different VOC Limits for Architectural Coating categories that are valid in different California Districts, and a VOC calculator for achieving VOC content in agreement with their rules, on a separate webpage. Another overview of the different regulation in different districts is containing links to the original regulation texts.

Testing

Testing is different from what Europeans are used to in conjunction with European Decopaint Directive. For a detailed discussion, please see the page dealing with SCAQMD.

SCAQMD VOC limitations

SCAQMD rules

SCAQMD is the Californian South Coast Air Quality Management District, based in Diamond Bar and covering Orange County and parts of Los Angeles, Riverside and San Bernadino counties.

SCAQMD limitation of VOC content in adhesives, sealants, and architectural coatings has gained importance even outside California because it is referenced by LEED and other sustainable building ranking schemes in the world.

Principles

The purpose of this limitation is to protect urban outside air against smog, especially against formation of ground level ozone. California Air Resources Board ARB offers a list with different VOC Limits for Architectural Coating categories that are valid in different California Districts, and a VOC calculator for achieving VOC content in agreement with their rules, on a separate webpage. Another overview of the different regulation in different districts is containing links to the original regulation texts.

Use of that VOC content limitation for evaluating of emissions of VOC into indoor air is not the best idea because there is no direct correlation between VOC content and the emission into indoor air over time. For that reason, LEED v4 of the US Green Building Initiative specifies limit values both for VOC content and for VOC emission into indoor air, mainly based on California Section 01350 specification, with alternative European pathways.

SCAQMD limit values

SCAQMD regulations cover a.o.:

  • SCAQMD Architectural coatings, see rule 1113.
  • SCAQMD Adhesives and sealants, see rule 1168.

The Suggested Control Measure (SCM) in its version of 2007 is a model regulation proposed by CARB for Californian districts.

LEED relevant VOC content limit values are summarized in tables for adhesives and sealants, and for paints and coatings. Most of these rely on SCAQMD limit values and use SCAQMD rules and test methods.

Any testing request should clearly identify the category to which the tested product belongs.

Testing

Testing is different from what Europeans are used to in conjunction with European Decopaint Directive.

While Europeans measure VOC content mostly by direct injection into gas chromatograph (ISO 11890-2), SCAQMD testing methods 304 and 303 are based on a different principle:

Total volatiles are determined by monitoring weight loss during 1 hour heating at 110 °C. Reactive products are allowed to stand open for 1 hour after mixing before start of test for allowing first curing to happen. Here you can download an illustration.

"VOC minus Water"

Total volatiles will comprise both total volatile organic compounds, but also water. Therefore water fraction is subtracted from the result. VOC content is related only to the non-aqueous fraction of the coating. Products containing a large amount of water will show higher VOC content in California than under European Decopaint Directive. As a consequence, modern water-based dispersion coatings and adhesives are treated more stringently than old solvent-based formulations.

"... minus Exempt Compounds"

A number of exempt compounds are subtracted because these are known NOT to contribute to ground level ozone formation. There are different lists with exempt compounds available from different authorities in the USA, but for this purpose only the Californian list of exempt compounds on pages 4 - 6 of SCAQMD rule 102 is accepted. Products containing a large amount of exempt compounds will show lower VOC content in California than under the European Decopaint Directive.

Technical problems with testing

Earlier, only the above mentioned testing methods are accepted, even though not optimal, especially not for reactive coatings and for coatings with low VOC and high water content. But in the meantime SCAQMD started accepting also GC testing (ASTM D6886 or SCAQMD method 313 (revised in 2016)), to stop delivery of non-reliable or even erroneous results for a number of low VOC products. Most recent information is available on a "VOC Working Group" section of the SCAQMD homepage.

Such testing could easily be combined with a test for European Decopaint Directive and is preferred by Eurofins VOC labs.

Testing of products for which the test method is not optimal

The earlier specified testing methods are prone to errors for a number of modern products, such as 2 component reactive coatings and adhesives, and concrete based tile adhesives. If required then Eurofins can try to apply these test methods to test such products and do its best, but Eurofins cannot guarantee that it works well.

US formaldehyde act

US formaldehyde regulation

US congress released a regulation on formaldehyde emissions from composite wood products, the Formaldehyde Standards for Composite Wood Products Act, for:

  • Hardwood Plywood (Veneer or Composite core)
  • Particleboard
  • Medium Density Fiberboard

Both composite wood panels and down-stream products containing such panels are involved, such as wooden flooring, furniture and more.

The regulation is not yet in force. The draft regulation is complex, therefore here is a number of valuable links to more information:

  • Summary
  • Text of the regulation: "Search for 40 CFR Part 770".

This is intended to expand the California CARB on formaldehyde emissions from composite wood (ATCM 93120) to the whole USA.

The related testing shall be performed in large-scale test chambers (ASTM E1333), or in mid-scale test chambers (ASTM D6007) that are calibrated against an approved large-scale test chamber. Testing is performed at 25 °C which is in contrast to emissions testing in most other parts of the world (where 23 °C is the temperature at test). That is the reason why Eurofins does not offer these tests, at present our test chambers are running at 23 °C only. Eurofins recommends using the CARB approved Third-Party Certifier Scientific Certification Systems SCS, California.

Contact VOC Testing Laboratories

Please see here contact information of Eurofins VOC testing laboratories in Europe, USA and China:
www.eurofins.com/voc-contacts.

CARB formaldehyde ACTM

CARB formaldehyde regulation

California Air Resources Board (CARB) released a regulation on formaldehyde emissions from wood-based panels and from composite wood products, the Airborne Toxic Control Measure ATCM 93120 for:

  • Hardwood Plywood (Veneer or Composite core)
  • Particleboard
  • Medium Density Fiberboard

Both composite wood panels and down-stream products containing such panels are involved, such as wooden flooring, furniture and more. Certification goes for the manufacturing process and the products.

This regulation served as model for a draft regulation for the whole USA which is not yet in force.

The regulation is complex, therefore here is a number of valuable links to more information:

Less stringent requirements are valid for manufacturers of

CARB approved Third-Party Certifiers TPC are certifying the mills producing composite wood panels. There is a list of certified mills, and a list of TPC presently approved.

The certification process includes formaldehyde emission testing in large-scale test chambers (ASTM E1333) or in mid-scale test chambers (ASTM D6007) that are calibrated against an approved large-scale test chamber. Testing is performed at 25 °C which is in contrast to emissions testing in most other parts of the world (where 23 °C is the temperature at test). That is the reason why Eurofins does not offer these tests, at present our test chambers are running at 23 °C only. Eurofins recommends using the CARB approved Third-Party Certifier Scientific Certification Systems SCS, California.

Contact VOC Testing Laboratories

Please see here contact information of Eurofins VOC testing laboratories in Europe, USA and China:
www.eurofins.com/voc-contacts

Formaldehyde and Indoor Air

Formaldehyde is the mostly discussed indoor air contaminant, and the mostly regulated one as well.

Sources

Formaldehyde is a naturally occurring gas. Small amounts of formaldehyde are present in outside air in urban areas and even in the countryside. Higher concentrations occur in indoor air, caused by numerous uses in products. Examples for sources are oxidation of methane in the atmosphere, combustion processes, automotive traffic, tobacco burning, but also certain manufactured wooden products, or some preservatives in liquid products.

Formaldehyde release from glued wooden products (plywood, MDF and more) are a special challenge because the most popular binder for such boards decomposes slowly in contact with water from normal air humidity. After an elevated initial emissions level, an equilibrium concentration is reached within some weeks that remains more or less constant over a longer period. The same binder is used in some mineral wool products. Newer binders are available that release less or no formaldehyde, but these have other draw-backs.

Formaldehyde is part of human metabolism as well and can be found in human blood, but also in several fruits. See Wikipedia for more details.

Toxicological relevance

At low air concentrations, formaldehyde can irritate eyes and the respiratory system. It is known to cause nasal cancer. There were reports indicating a potential risk that formaldehyde could contribute to leukemia. More symptoms can be caused at significantly higher air exposures that will not occur in residential indoor environment.

Formaldehyde is classified as class C1B carcinogen in Europe. While some scientific agencies recommend to reduce formaldehyde exposure as much as possible on that background, other serious and independent agencies report that formaldehyde air concentrations below 124 µg/m³ (= 0.1 ppm) will not result in significant cancer risk. Formaldehyde is reported to be one of the few carcinogenic substances that have a hygienic threshold below which the human body can defend itself and exposure will not lead to cancer. See Wikipedia for more details, as well as an overview of formaldehyde product emissions limit values and a summary of German UBA.

Read more:

Using synergies

If a manufacturer needs formaldehyde and VOC emission testing for markets in several countries, then Eurofins can try to help saving money by combining all required testing into one test setup, and by selecting the worst-case test method to obtain test data covering all requirements. This service is unique in the whole world. No other testing laboratory is approved for emission chamber testing by the same number of both US and European specifications and regulations for low-emitting construction products.

If it comes to formaldehyde, this combination of different test methods into one test setup requires a certain pragmatic creativity. The different test methods deliver more or less different test results for the same product sample. But in two cases this does not matter for product evaluation:

  • If a product complies with a test method that gives systematically higher values than the reference test method, then it will comply with that test method as well.
  • And if a product gives test results far below the limit values, much lower than the discrepancy between the test methods, then it will comply with the reference test method as well.
  • Nevertheless, these considerations might be rejected by regulators and programs that are run by non-experts; administrative staff may want to stick to the printed letter and not accept such analogy conclusions. This has to be clarified in each single case.

Formaldehyde - limit values

The scientific controversy, whether there is a hygienic exposure threshold below which the human body can defend itself and exposure will not lead to cancer, or whether any additional exposure to formaldehyde must be avoided even at lowest levels, leads to different limit values for product emissions of formaldehyde.

Mostly used limits in Europe are:

  • 120 µg/m³ for E1 formaldehyde class, wood-based and other products
    (reported as equilibrium concentration, or as test result after 28 days ventilated storage).
    Some European countries have a national regulation that only E1 conform wood-based panels must be distributed on their territories: Austria, Denmark, Germany, Italy, Sweden.
  • 100 µg/m³ after 28 days ventilated storage as European harmonized LCI value,
    used for product regulations in Belgium and in Germany.
  • 24 or 30 or 50 µg/m³ after 28 days ventilated storage (depending on the concerned program) for voluntary labels that favour the precautionary principle with a higher safety margin(EMICODEIndoor Air ComfortBlue AngelM1 and more).
  • 10 µg/m³ after 28 days ventilated storage for French A+ class, and for LEED v4 outside North America, and Indoor Air Comfort GOLD.

Mostly used limits in the USA are:

  • Between 60 and 150 µg/m³ for Californian CARB phase 2 regulation, differentiated for different types of wood-based products (reported with a special US testing methodology).
  • 9 µg/m³ after 14 days ventilated storage for California CDPH method, and for LEED v4 globally.
  • 60 µg/m³ after 7 days ventilated storage for office furniture, workstations, ANSI/BIFMA X7.1 and ANSI/BIFMA e3.

Japan has another classification system for formaldehyde releasing products. The lowest formaldehyde class, F****, allows maximum 5 µg/m²h emissions, but tested with a special Japanese technology.

Using synergies

If a manufacturer needs formaldehyde and VOC emission testing for markets in several countries, then Eurofins can try to help saving money by combining all required testing into one test setup, and by selecting the worst-case test method to obtain test data covering all requirements. This service is unique in the whole world. No single other testing laboratory is approved for emission chamber testing by the same number of both US and European specifications and regulations for low-emitting products.

If it comes to formaldehyde, this combination of different test methods into one test setup requires a certain pragmatic creativity. The different test methods deliver more or less different test results for the same product sample. But in two cases this does not matter for product evaluation:

  • if a product complies with a test method that gives systematically higher values than the reference test method, then it will comply with that test method as well; and
  • if a product gives test results far below the limit values, much lower than the discrepancy between the test methods, then it will comply with the reference test method as well;
  • nevertheless, these considerations might be rejected by regulators and programs that are run by non-experts; administrative staff may want to stick to the printed letter and not accept such analogy conclusions. This has to be clarified in each single case.

Contact VOC Testing Laboratories

Please see here contact information of Eurofins VOC testing laboratories in Europe, China and Japan:
www.eurofins.com/voc-contacts.

 Formaldehyde - testing

On this page:

Emissions or content testing

  • A formaldehyde content test produces information on, how much formaldehyde is in the product.
  • A free formaldehyde content test tells about how much formaldehyde can be released during lifetime of the product.
  • An emissions chamber test shows the contribution of the product to indoor formaldehyde air concentration after a certain elapsed time.

Content testing

  • Some liquid products contain preservatives in bounded form from which formaldehyde is released slowly until the product is spread out on a surface.
  • Total formaldehyde tests set free all potentially formed formaldehyde at once.
  • Free formaldehyde determines actual formaldehyde concentrations in the product.
  • The details of the testing protocol (pH value, extraction agent etc.) determine to which extent formaldehyde is captured and analyzed, or hidden, with such testing methods.

Emissions testing

  • Case 1:

If formaldehyde is brought into the product and diffuses out slowly, then the normal VOC emissions test protocols can be applied to formaldehyde accordingly. Just the air sampling and analysis method has to be specific for formaldehyde (e.g. the acetyl acetone method, as in EN 717-1) or for volatile aldehydes in general (the DNPH method, as in TS / EN 16516, ISO 16000-3, CDPH method, ASTM D5197 and more).

An emissions chamber test shows the contribution of the product to formaldehyde air concentration after a certain elapsed time - in Europe after 3 and/or after 28 days, and in the USA after 14 days, or after 7 days for furniture, or after 20 hours for wood-based panels in a large test chamber. All these approaches serve as indicator for long-term indoor air exposure.

  • Case 2:

If formaldehyde is produced continuously, e.g. by hydrolysis of a binder in contact with normal air humidity, then a steady-state-concentration will be reached in a test chamber, typically after some days or weeks. Several test methods determine the steady-state-concentration by taking air samples almost every day to establish the decay curve. Then it is calculated which concentration will be the stable one, and when this will be reached, from that decay curve (EN 717-1, ISO 12460-1, ASTM D6007).

In most cases, the steady-state-concentration and the emissions test result after 28 days correlate well, as long as the testing parameters are similar.

Parameters influencing the emissions test

  • Temperature:
    • For most products, higher temperature will increase the formaldehyde concentration early during the test. Later during the test it cannot be predicted whether higher temperature increases or decreases the test result. 
    • Higher temperature will increase the steady-state-concentration in the case of continuous formation of formaldehyde in the product.
    • The impact of temperature cannot be predicted or calculated, except for products containing urea-formaldehyde binders where such calculation models exist (the "Anderson formula", as in ASTM D6007 and ASTM E1333).
  • Air humidity:
    • For most products, within the standard range of 45 - 55 % RH, there is no large impact on the test result. This was shown during validation of CEN/TS 16516, see below.
    • Higher relative humidity will increase the steady-state-concentration in the case of continuous formation of formaldehyde in the product.
    • The impact of air humidity cannot be predicted or calculated, except for products containing urea-formaldehyde binders where such calculation models exist (the "Anderson formula", as in ASTM D6007 and ASTM E1333).
  • Ventilation:
    • Higher ventilation dilutes any emissions that are determined in a test chamber with more clean air.
      • In terms of air concentration, the result will be lower with higher ventilation, due to dilution.
      • But in terms of emissions rate per area and hour, the result should be the same for most products.
      • Validation of CEN/TS 16516 showed that a recalculation of air concentrations between different ventilation rates is possible in a range of 0.25 - 1.5 air changes per hour.
    • In the case of continuous formation of formaldehyde in the product, higher ventilation can expose the test specimen to more water from air humidity than with lower ventilation. In that case, the above stipulated constancy of the emissions rate of formaldehyde might be challenged.
  • Loading factor
    • The loading factor determines the size of the test specimens to be tested, relative to the volume of the test chamber or of the reference room. The loading factor is expressed as m²/m³ in most cases.
    • Higher loading factor includes larger source of the emissions and thus gives higher emissions.
      • In terms of air concentration, the result will be higher with higher loading factor, due to larger emissions source.
      • But in terms of emissions rate per area and hour, the result should be the same for most products.
      • Validation of CEN/TS 16516 showed that a recalculation of air concentrations between different ventilation rates is possible in a range of 0.004 - 2.0 m²/m³.

Correlation between TS / EN 16516 and EN 717-1 / E1 class

EN 717-1 (which is the basis of E1 formaldehyde class), in comparison with TS / EN 16516 and ISO 16000, operates with

  • the same testing temperature;
  • 1.0 air change per hour (EN 717-1) instead of 0.5;
  • a fixed loading factor of 1.0 (EN 717-1), instead of loading factors depending on the application scenario, such as floor, wall etc.;
  • and EN 717-1 prefers air sampling and monitoring with the acetyl acetone method, but it allows the use of the DNPH method (ISO 16000-3 and TS / EN 16516) as well, as these are known to be equivalent for formaldehyde.

As outlined above, these differences should be not significant for most products. It could be shown during the validation of CEN/TS 16516 that EN 717-1 and the CEN/TS 16516 give the same results after 28 days in test chambers within the measurement uncertainty, when the emission rates are compared. Different ventilation rates during testing then are leveled out by calculation of the final test result from the emission rate. See www.centc351.org/ and the validation report, clause 5.2 on page 48.

In that study, this held true also for the tested wood-based panel. But it can be imagined, that some panels might show differences in the emission rate and thus would need more detailed investigation.

Can TS / EN 16516 and ISO 16000 tests be used to determined E1 class compliance of a product?

Yes and no.

It cannot be used if you read the letters of the standards alone, because TS / EN 16516 and ISO 16000 do not determine the steady-state concentration.

But TS / EN 16516 and ISO 16000 test results obtained after 28 days can be used if the following considerations can be accepted:

  • The steady-state concentration is assumed to be stable after some days or weeks. Then the 28 days emissions are the same as the steady-state concentration.
  • The differences in ventilation rate and loading factor can be re-calculated via the emission rate, as described in TS / EN 16516. And if a product complies after being tested at a lower ventilation than specified in EN 717-1 even without re-calculation, then it complies in any case.
  • The higher relative air humidity in TS / EN 16516 and ISO 16000 (50% RH) will lead to higher test results; if the product still complies with E1 class limits, then it will certainly do so when tested at 45% RH as in EN 717-1.

Can US and ASTM tests be used to determined E1 class compliance of a product?

Also here, it is possible if the following considerations can be accepted:

  • The ventilation rate during testing is close to EN 717-1 ventilation rate for all these standards.
  • Some US standards (ASTM E1333, ASTM D6007) operate at a higher test temperature than the other standards which gives higher test results (25 °C versus 23 °C in Europe).
    • If a product nevertheless fulfills the requirements, then it would also comply with EN 717-1 tests (which is the basis of E1 formaldehyde class).
  • Several of the US standards (ASTM D5116, ASTM D6670, CDPH, ANSI/BIFMA M7.1) have a shorter testing duration than EN 717-1 (which goes for testing until equilibrium, but not longer than 28 days). This may lead to higher test results if equilibrium is not reached when the US test was stopped.
    • If a product nevertheless fulfills the requirements, then it would also comply with EN 717-1 test.

Correlation of emissions tests with simpler secondary test methods

A number of simpler tests are in use for daily factory production control, and sometimes even for evaluation of formaldehyde product emissions:

  • Gas analysis: EN 717-2, ISO 12460-3;
  • Flask test: EN 717-3;
  • Perforator test: EN 120, ISO 12460-5;
  • Desiccator test: ISO 12460-4, ASTM D5582, JIS A1460.

All these tests can be applied if a correlation between the emissions chamber test and the secondary test method is applied. But these correlations are not universal. They have been established for some types of wood-based panels. But the correlation is different as soon as the top layer changes, a different binder is used, or the density of the material deviates.

Therefore equivalency between EN 717-1 and the other tests (such as EN 120) is valid only for a certain, well investigated product type, and you will see the name of the product type in any comparison tables that deliver correlation factors, as e.g. in EN 13986 for different groups of wood-based panels.

Using synergies

If a manufacturer needs formaldehyde and VOC emission testing for markets in several countries, then Eurofins can try to help saving money by combining all required testing into one test setup, and by selecting the worst-case test method to obtain test data covering all requirements. This service is unique in the whole world. No single other testing laboratory is approved for emission chamber testing by the same number of both US and European specifications and regulations for low-emitting products.

If it comes to formaldehyde, this combination of different test methods into one test setup requires a certain pragmatic creativity. The different test methods deliver more or less different test results for the same product sample. But in two cases this does not matter for product evaluation:

  • If a product complies with a test method that gives systematically higher values than the reference test method, then it will comply with that test method as well; and
  • If a product gives test results far below the limit values, much lower than the discrepancy between the test methods, then it will comply with the reference test method as well;
  • Nevertheless, these considerations might be rejected by regulators and programs that are run by non-experts; administrative staff may want to stick to the printed letter and not accept such analogy conclusions. This has to be clarified in each single case.

Contact VOC Testing Laboratories

Please see here contact information of Eurofins VOC testing laboratories in Europe, China and Japan:
www.eurofins.com/voc-contacts.