July 2004
List of Declarable Materials in Automobile Manufacturing
Substances in Components and Construction Materials VDA
232 – 101
1 Objective
In automotive manufacturing a large number of construction, operational and processing
materials are used whose selection and proper use affect the vehicles’ quality, safety and
environmental friendliness through their entire life.
In order to optimise these characteristics, it is necessary to cultivate the exchange of
information, as well as the dialogue within the value-creation chain – starting with raw
material extraction, continuing with the manufacturing of pre-products, components, the
construction of motor vehicles up to their usage, and finally re-utilisation or waste disposal.
Legal requirements, which provide the basis for passing along information within the
supplier-customer chain, are already in place. Looking ahead at future development,
information will be constantly expanded and a dialogue about all possible risks for humans
and the environment will be introduced. Co-operation based on mutual trust is imperative for
reaching goal-oriented solutions. Thus, joint evaluation procedures, which have the ability to
weigh out benefits and potential risks involved in the application of materials, need to be
introduced.
As the result of this co-operation the List of Declarable Materials in Automobile
Manufacturing - Substances in Components and Construction Materials has been attached.
2 Bases
In this List of Declarable Materials in Automobile Manufacturing – Substances in
Components and Construction Materials publication, substances and substance categories
are listed, which may be present in automotive construction materials, and which, based on
current knowledge, present potential risks for humans and the environment during the
vehicle’s usage, as well as during the recycling and disposal processes.
The composition of the list is based on:
• Legal requirements
• Environmental protection and occupational safety requirements, which take precautionary
measures in order to help prevent possible risks to humans and the environment, which
may be caused by construction, operational and processing materials.
• Our responsibility to humans and the environment based on the motto: We act in an
environmentally conscious manner.
Particular consideration was given to substances which may cause higher risks, such as:
continued page 2 to 11
VERBAND DER AUTOMOBILINDUSTRIE E. V. (VDA) Westendstraße 61 60325 Frankfurt
Distribution: DOKUMENTATION KRAFTFAHRWESEN e.V. (DKF) - Ulrichstr. 14 - D-74321 Bietigheim-Bissingen, Germany
Page 2 VDA 232 - 101 (July 2004)
• Carcinogenic substances
• Substances which affect fertility
• Mutagenic substances
• Sensibilizing substances
• Slightly and highly poisonous substances
• Environmentally damaging substances
3 Application and explanations
All the substances and substance groups listed in the List of Declarable Materials in
Automobile Manufacturing - Substances in Components and Construction Materials must be
recorded with the Initial Sample Test Report VDA - Constituents in Purchased Parts (Material
Data Sheet), if they are present in the products, or if they run the risk of being released. Mass
limitations i.e. content limitations for individual substances have been specified. If the content
level falls below these limitations, it does not have to be declared. These limitations are
0.1g/100g (weight %), unless otherwise indicated.
Substances on the list marked with “D” must be declared if their amount exceeds the set
limitation. These specifications form the basis for dialogue between the supplier and the
customer, in order to provide a safe and environmentally friendly operation. The declared
substances should not be automatically substituted, but a joint effort should be made to
carefully weigh out advantages/benefits as well as potential risks, while taking the specific use
of the substance into consideration. After this has been done, a final decision concerning the
substance of choice will be made. This procedure may also make it necessary to test
alternative substances. In doing so, one must make sure that all of the possible substances
are tested in the same way, taking all technical, economic and ecological aspects into
consideration.
The substances on the list marked with “P” are prohibited for certain application purposes by
law. They may not be contained in amounts, which exceed the set limitations. Impurities
caused by these substances must be recorded qualitatively and risk estimates should be
discussed in a dialogue.
4 Extent of validity
Should the content of the English, French, Spanish and Italian versions of the List of
Declarable Materials in Automobile Manufacturing - Substances in Components and
Construction Materials interpreted differently from the German text, the German original issue
is authoritative!
The contents of the List of Declarable Materials in Automobile Manufacturing - Substances in
Components and Construction Materials and its application does not relieve any of the parties
involved in process chain from their obligation to comply with all the government regulations
regarding hazardous materials and any resulting additional prohibitions or application
limitations. It is intended that this List of Declarable Materials replaces the company specific
declaration lists (specifications, regulations etc.)
Page 3 VDA 232 - 101 (July 2004)
5 Further Development
The List of Declarable Materials in Automobile Manufacturing - Substances in Components
and Construction Materials - was drawn up on behalf of the VDA Materials Committee (VDA-
Werkstoffausschuss) by the VDA-Material Contents Working Group (VDA AK Inhaltsstoffe)
and completed in co-operation with the Chemical Industry Association VCI (Verband der
Chemischen Industrie). It will be updated annually (January 31st) according to increasing
knowledge and developing requirements in order to continuously improve product safety and
environmental protection. This work will - as with the preparation of the list- continue in co-
operation with all partners.
For any comments and questions please contact directly:
Verband der Automobilindustrie e.V. (VDA)
Technical Department
Westendstr. 61
D-60325 Frankfurt
Germany
taeubl@vda.de
6 General Definitions
Products Substances or preparations, which during production, have taken
on a specific shape, surface or form, which has a greater influence
on their function than their chemical composition does.
Substances Chemical elements or chemical compounds as they exist naturally
or are produced, including stabilising agents and production-related
impurities, with the exception of solvents, which can be separated
without any effects on stability or change in composition.
Preparations Mixture or solutions, composed of two or more substances
Page 4 VDA 232 - 101 (July 2004)
7 Abbreviations Used
ChemG Chemicals Act - law for protection against dangerous substances
ChemVerbotsV Chemical Prohibition Regulation – regulation on bans and restrictions
regarding hazardous substances, preparations and products being
brought into service
EU-D European Directive including amendment and adaptation directives:
EU-D 67/548/EEC: Directive on the approximation of laws, regulations
and administrative provisions relating to the classification, packaging and
labelling of preparations made from dangerous substances
EU-D 76/769/EEC: Directive on the approximation of the laws, regu-
lations and administrative provisions of the Member States relating to
restrictions on the marketing and use of certain dangerous substances
and preparations
EU-D 2000/53/EG: Directive on end-of life vehicles
EU-R EU Regulation including amendment and adaptation regulations:
EU-R 594/91/EEC: Council Regulation on substances that cause the
depletion of the ozone layer
GefStoffV Regulation on Dangerous Substances – regulation on the protection from
dangerous substances
StrlSchV Regulation on Radiation Protection
CX*) Carcinogenic, classification according to EU-D 67/548/EEC or TRGS 905
MX*) Mutagenic, classification according to EU-D 67/548/EEC or TRGS 905
REX*) Substances which are embryotoxic (EU-D 67/548/EEC or TRGS 905)
RFX*) Substances which affect the fertility (EU-D 67/548/EEC or TRGS 905)
T Toxic (according to ChemG and GefStoffV; EU-D 67/548/EEC)
T+ Very toxic (according to ChemG and GefStoffV; EU-D 67/548/EEC)
TRGS Technical rules for hazardous substances
*) X = 1: proven to affect humans; effects known
*) X = 2: proven to affect animals; effects apply to humans as well.
*) X = 3: supposed effects of the substances on man
Page 5 VDA 232 - 101 (July 2004)
8 Notes for the user on the information in the table’s columns
Substance The column contains chemical compounds or substance
groups, respectively. Substance groups are normally
referred to by their root substance.
CAS No. Chemical Abstracts Services, numbering system for
chemicals. For the groups of chemical compounds (e.g.
benzidine or its salts) the CAS No. of the root chemical is
noted and put into parentheses.
Declaration Limit * For “prohibited substances” the maximum concentration
of the specified substance allowed to be present in a
material is noted. “Declarable substances” have to be
reported if their concentration exceeds the specifications
above. The actual concentrations have to be reported in
each case.
VDA classification D: duty-to-declare substances - with dialogue
P: prohibited substances; valid for specific usage
Type * This row contains information concerning usage or
material classification
Source Listed here are laws, regulations and rules containing
usage prohibitions or restrictions. Supplementary and
amendment directives should also be observed.
Danger/risks Remarks on classification according to chemical
legislation or concerning usage in materials of cars and/or
car manufacturing
Examples of use and
presence of a substance
The examples show typical automotive related usage for
environmentally relevant hazardous substances.
Substances contained in construction materials and
substances used during production, which can be present
as residues, are listed as well.
Remarks / comments This column contains information on detailed usage
prohibitions and specific details, including industry
specific restrictions.
* This information is currently being revised for the next edition
List of Declarable Materials in Automobile Manufacturing
Substances in Components and Construction Materials Valid only with explanation
VDA 232-101 (July 2004)
VDA AK Inhaltsstoffe
taeubl@vda.de
1
Substance CAS-No. VDA- Classi-fication
Source
(Legal requirements, regulations)
Danger/
Risk Examples for usage / existence
Remarks and Comments
(contents, deviation from 0,1%)
2 Acetaldehyde 75-07-0 D EU-D 67/548/EEC C3 Emitted substances from auto components
3 Acetamide 60-35-5 D EU-D 67/548/EEC C3 Solvent additive, stabilizer for softening agents
4 Acrylamide 79-06-1 D EU-D 67/548/EEC C2,M2 Production of polyacrylamide (residual monomer)
5 Acrylonitrile 107-13-1 D EU-D 67/548/EEC C2
Production of plastics,
resins and rubbers eg. ABS (residual monomer)
6
Aliphatic chlorohydrocarbons
refer to Chlorinated hydrocarbons
7
4-Aminobiphenyl and its salts (92-67-1) D P
EU-D 76/769/EEC
EU-D 67/548/EEC,
ChemVerbotsV.
GefStoffV incl. Annex IV No. 2
C1 Impurities in textile and leather paints, antioxidants in lubricants, rubber/latex, plastics
Restriction for substances and preparations
according to German ChemVerbotsV
8 Ammonia emitting substances (7664-41-7) D Emitted substances from auto components
Odour problem in car interior, refer to
introduction
9 Aniline and its salts (62-53-3) D EU-D 67/548/EEC ( C3 ) Pigments, sulfonamides, isocyanate - plastics
10
Antifouling dyes components;
refer to:
Arsenic
Hexachlorocyclohexane
Mercury
Organo-tin-compounds
D GefStoffV incl. Annex IV Nr. 5
Mainly used as protective coating
- contained in collophony, resin esters or modified
vulcanized resins in combination with tar or bitumen,
small amounts chlorine latex, chlorinated
Polypropylenes and Vinyl resins
Restriction for substances and preparations
according to German ChemVerbotsV
11
Antimonytrioxide (Diantimonytrioxide) 1309-64-4 D EU Annex 67/548/EEC C3 Flame retardant for plastics and rubber/latex, opacifier in smelting coverings, friction lining in vehicle assembly
12
Aromatic amines or their salts:
4-Aminobiphenyl or its salts
Benzidine or its salts
2-Naphthylamine or its salts
4-Nitrobiphenyl or its salts
(92-67-1)
(92-87-5)
(91-59-8)
92-93-3
D P
EU-D 67/548/EEC
EU-D 76/769/EEC
ChemVerbotsV
GefStoffV incl. Annex IV Nr. 2
C1 Possible impurities in certain colours for natural textiles (production prohibited in Europe)
Restriction for substances and preparations
according to German ChemVerbotsV
13
Arsenic or its compounds (7440-38-2) D P
EU-D 67/548/EEC
EU-D 76/769/EEC
ChemVerbotsV
GefStoffV incl. Annex IV Nr. 3
T
Paints and smelting coverings, wood preservative,
leather and textile finishes, water treatment, plane
glass, metal glue, pyrotechnic objects, metal finishes,
wood impregnation
If used as a component in metals the
declaration limit is 500 ppm.
Restriction for substances and preparations
according to German ChemVerbotsV
14
Asbestos 1332-21-4 P
EU-D 76/769/EEC,
ChemVerbotsV
GefStoffV incl. Appendix IV Nr. 1
C1 Friction pads, gaskets, insulations Restriction for substances and preparations according to German ChemVerbotsV
15
Azo-dyes as defined by TRGS 614
containing carcinogenic amine components D P EU-D 67/548/EEC C 1 - 2 In dyes Restricted for use in textiles
16
Barium compounds (organic or water
soluble) except Ba-carboxylate (7440-39-3) D
EU-D 67/548/EEC
TRGS 614, 905
Xn
Colour pigments, stabilizers for PVC,
lubricant additives Declaration-limit: 1 %
17
Benzidine or its salts (92-87-5) D P
EU-D 67/548/EEC EU-
D 76/769/EEC
ChemVerbotsV
GefStoffV incl. Annexx IV No. 2
C1
Kongo dyes (benzidine dyes: mainly azo dyes)
textile and leather dyes, antioxidants in rubber and
elastomers
Substitute materials TRgA 603
Declaration limit: 0,01 %
Restriction for substances and preparations
according to German ChemVerbotsV
D = duty to declare- commence dialogue; P = legally prohibited for certain application purposes (version: 034e) page 6 of 11
List of Declarable Materials in Automobile Manufacturing
Substances in Components and Construction Materials Valid only with explanation
VDA 232-101 (July 2004)
VDA AK Inhaltsstoffe
taeubl@vda.de
1
Substance CAS-No. VDA- Classi-fication
Source
(Legal requirements, regulations)
Danger/
Risk Examples for usage / existence
Remarks and Comments
(contents, deviation from 0,1%)
18
Benzo(a)pyrene or other corresponding
PAH´s (50-32-8) D P
EU-D 67/548/EEC
EU-D 76/769/EEC
ChemVerbotsV
GefStoffV incl. Annex IV No. 13
(C2, M2),
RF2, RE2
Mineral oils, soot, tar
Incomplete burning of organic substances.
Differing declaration limits:
in wood preservatives: 50 ppm
in lubricants: 10 ppm (16 PAHs to EPA) i.e.
1 ppm for Benzo(a)pyren. Restriction for
substances and preparations according to
German ChemVerbotsV
19
Benzene 71-43-2 D P
EU-D 76/769/EEC
ChemVerbotsV
GefStoffV incl. Appendix IV Nr. 4
C1, M2 Fuel, solvent for latex enamels, raw material for other chemicals
declaration deviation limit: 0,01%;
Restriction for substances and preparations
acc. to ChemVerbotsV.
20 Beryllium or Beryllium alloys (7440-41-7) D EU-D 67/548/EEC C2 Electric contacts, relays and switches
must be declared if used as component in
metal
21 Beryllium salts or -oxides (7440-41-7) D EU-D 67/548/EEC C2 Ceramic materials in electric insulators
25
Butadiene
( 1,3 - Butadiene ) 106-99-0 D EU-D 67/548/EEC C1, M2
manufacturing of synthetic rubber for tyres, as
homopolymerisate (BR), as copolymerisate
with Styrene (SBR) or Acrylonitrile (NR), starting
product of Sulfolane, Chloroprene, Hexadiamine,
softeners, Tetrahydrophthalic acid anhydride, residual
monomer in ABS
26 Butylbenzylphthalate (BBP) 65-68-7 D EU-D 67/548/EEC RE2 Softening agent in plastics e.g. PVC
27
Cadmium or it's compounds (7440-43-9) D P
EU-D 2000/53/EEC
EU-D 67/548/EEC
EU-D 76/769/EEC
(C2) Surface protection of metals, stabilizers in polymers, pigments, in paints and plastics
Cd-impurities up to 75 ppm are tolerated.
Cd in alloys and warnings signs are
excluded from ban; observe exception
pertaining to EU End-of-life-vehicle directive
in Annex II! Restriction for substances and
preparations according to German
ChemVerbotsV
57
Carbondisulfide emitting substances 75-15-0 P EU-D 67/548/EEC RF3, RE3 Emitted substances from vulcanized elastomers
Restriction for substances and preparations
according to German ChemVerbotsV
56
Ceramic Fibers D EU-D 67/548/EEC C2 Friction lining, screens, re-enforcement, insulation, cables
Danger caused by dusts,
KI-values in TRGS 90;
mind WHO criteria
28 Chloroaniline 106-47-8 D EU-D 67/548/EEC (C2)
Hardener or cross linking agent for polymers and epoxy
resins
29
Chlorepoxypropane (Epichlorhydrine)
see: 1-Chloro-2,3-epoxy-propane
30 1-Chloro-2,3-epoxy-propane 106-89-8 D EU-D 67/548/EEC C2 residual monomers in epoxy resins
49
Chloro-fluoro-carbons (CFC)
or other Ozone depleting substances - D P EU-R 594/91/EEC
Coolants, propellants, cleaners,
solvents, impregnating agents,
blowing agents (PU production)
prohibited substances: see CFC-Halone-
Prohibition Regulation,
all others: D
31
Chlorinated Biphenyls
see: Polychlorinated Biphenyls (PCB)
32
Chlorinated or brominated Dioxines or
Furanes P ChemVerbotsV T Impurities in products
Possible formation of Dioxines and Furanes
during recycling processes, in cases of fires
or re-use
1 ppb, 5 ppb, 100 ppb
- up to the grade of halogenation
D = duty to declare- commence dialogue; P = legally prohibited for certain application purposes (version: 034e) page 7 of 11
nre
Highlight
List of Declarable Materials in Automobile Manufacturing
Substances in Components and Construction Materials Valid only with explanation
VDA 232-101 (July 2004)
VDA AK Inhaltsstoffe
taeubl@vda.de
1
Substance CAS-No. VDA- Classi-fication
Source
(Legal requirements, regulations)
Danger/
Risk Examples for usage / existence
Remarks and Comments
(contents, deviation from 0,1%)
33
Chlorinated hydrocarbons:
Tetrachloromethane (Tetrachlorocarbon)
1,1,2,2 - Tetrachloroethane
1,1,1,2 - Tetrachloroethane
Pentachloroethane
Trichloromethane (Chloroform)
1,1,2 - Trichloroethane
1,1 - Dichloroethylene
1,1,1 - Trichloroethane
56-23-5
79-34-5
630-20-6
76-01-7
67-66-3
79-00-5
75-35-4
71-55-6
D P
EU-D 67/548/EEC
EU-D 76/769/EEC,
ChemVerbotsV
GefStoffV incl. Annex IV Nr. 11
C3 Cleaners, solvents impregnating/proofing agents, fungicides, pesticides
Restriction for substances and preparations
according to German ChemVerbotsV
34
Chlorinated hydrocarbons (CHC),
see as well: Chloroparaffines, unbranched
35
Chloroparaffines, unbranched
(C10-H22nCln to C30-H62nCln; n = 1-28)
D P EU-D 76/769/EEC Flame retarding substances Chlorine paraffine with a chain length of
C10-C13 are prohibited (P)
36
Chromium(VI)-compounds (14977-61-8) D EU-D 67/548/EECEU-D 2000/53/EEC C2
Chromium pigments (Lead chromate: Chromium
Yellow, Barium chromate, Baryte Yellow), chromated
surfaces e.g. Chromium Yellow, corrosion inhibitors,
residues from dying and tanning.
Observe EU End-of-life-vehicle directive with
Annex II! Impurities tolerated up to 0,1%
37 Cobalt or Cobalt compounds; Co alloys (7440-48-4) D EU-D 67/548/EEC C3 Hard metal Galvanic Zn-Co-pl
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