Prohibited and Restricted Substances | Carter Industrial Company
Carter Industrial Company Restricted Substances List (RSL)
The objective of the Carter Industrial Company Restricted Substances List (RSL) is to communicate our chemical requirements, reflecting our commitment to human health, environmental responsibility, and meeting the increasing demands of our customers.
The Carter Industrial Company RSL is an integral part of our efforts to ensure product quality, safety, and sustainability while reducing the environmental impact and health hazards associated with our rPVB leather products. This list applies to all materials supplied to Carter Industrial Company, including raw materials, components, finished goods, and packaging materials.
Our RSL is updated regularly to align with evolving regulations and industry best practices. It includes both general requirements applicable to all material categories and specific requirements for certain materials or categories. The Carter Industrial Company RSL specifies banned or limited chemical substances in our products and provides clear references to relevant chemical legislation. This ensures that our list of requirements for undesirable materials and substances is continuously updated and readily available to our employees, suppliers, and customers.
Purpose:
Carter Industrial Company aims to be a leading GRS-certified manufacturer, offering innovative and high-quality rPVB leather products that contribute to a more sustainable world. The Carter Industrial Company Restricted Substances List (RSL) serves as a means to communicate our chemical requirements for materials and products, ensuring compliance to achieve our goals. The RSL includes both legal requirements and our own stringent standards, reinforcing our commitment to responsible chemical management.
Scope and Application:
All materials and products supplied to Carter Industrial Company must comply with the requirements listed in the Carter Industrial Company RSL at all times. The RSL applies to the intentional use of substances or chemical products in the manufacturing process, regardless of whether the substances remain in the finished materials or products. The RSL distinguishes between Prohibited and Restricted substances, with detailed definitions provided in the clause.
The RSL consists of general requirements applicable to all products and materials, including legal-based requirements and substances that could be present in various materials. Additionally, specific material sections outline additional substances or limits for products containing those materials or applications.
Validity and Changes:
The Carter Industrial Company RSL is subject to regular review and updates to ensure compliance with applicable laws and proactive chemical management. It may contain requirements that go beyond legal obligations. Suppliers must comply with the latest version of the RSL for all materials and products supplied to Carter Industrial Company, regardless of the original approval date. It is the responsibility of suppliers to stay informed about any changes to the RSL and maintain compliance with the latest version.
Liability and Responsibility:
Carter Industrial Company reserves the right to conduct random testing of materials and products at any stage of production. Test results must be performed by accredited laboratories approved by Carter Industrial Company. We also reserve the right to grant or revoke authorization for the use of substances limited by the RSL in materials and products supplied to us. Suppliers must provide necessary documentation upon request, including Safety Data Sheets (SDS), safe use instructions, and material certificates. Suppliers are also required to inform Carter Industrial Company of any listed declarable substances present in the supplied materials. If available, suppliers may provide Full Material Declarations (FMD) to Carter Industrial Company.
Definitions:
Article
An object which during production is given a special shape, surface or design, which determines its function to a greater degree than does its Chemical composition.
CAS No.
Chemical abstract services registration number. Each CAS number is specific to each chemical substance. Note that some substances may have multiple CAS numbers
Complex object
A product that consists of several components, their subcomponents and material they contain.
Declarable
If a declarable substance is present in materials/articles, this shall be reported to and approved by Carter Industrial Company before purchase.
Defection limit
The lowest concentration detectable by the test equipment.
Limit value
The maximum amount of chemical substances permitted in the articles for usage ranges A, B and C. If the substance is prohibited, the limit value indicates the maximum amount permitted in form of contamination
Materials and products
Refer to all finished goods, articles, components, materials, and packaging supplied to Carter Industrial Company.
PBT
Substance that is Persistent, Bioaccumulative, and Toxic
ppm
Parts per million, equal to mg/kg: 1000 ppm=0.1 wt%=1 g/kg= 1000 mg/kg= 1000000 g/kg
Prohibited
The substance is prohibited from use in the production or from being added to the product. Carter Industrial Company acknowledges that low concentrations of the material or substance may in any case be found due to impurities. Authorization from Carter Industrial Company is required if no alternative is available e.g., in raw materials, production processes.
Restricted
A substance is permitted to be used in production or added to the product within the specified limit value.
Several
When a substance group is not defined by a single CAS number, these will be listed as several. The CAS numbers included in the substance group will often be defined in an appendix.
Substance group
A collection of substances with similar chemical structure, composition, or function.
SVHC
Substances of Very High Concern, legally defined by the REACH Candidate list.
Usage range
Usage ranges classify materials and products according to their foreseeable use. The usage for materials and products is defined in the specification prepared by Carter Industrial Company. The three usage ranges (A, B, C) are defined:
Usage range A: Intended for use in the mouth, or prolonged skin contact, intended for children 0-3 years.
Usage range B: Coming into long-term skin contact (>30seconds) or short-term repetitive skin contract during intended or foreseeable use.
Usage range C: Coming into short-term skin contact (up to 30 seconds) during intended or foreseeable use.
Testing
Carter Industrial Company expects supplied products and materials to be compliant with the RSL and suppliers should be prepared to provide evidence of product/material compliance. The test methods used shall have a detection limit lower than the limits defined by the RSL. When a legal requirement specifies a certain test method, this test method shall be used. Appropriate test methods can be discussed with Carter Industrial Company.
General requirements for all types of materials and products
The following requirements must be fulfilled for all types of materials and products at all times. NOTE: the specific requirements applicable to the material and/or product category must also be fulfilled. See material specific requirements in the subsequent sections of the document. The limit value(s) for a substance may be stricter for specific material and/or product categories.
If applicable, SCIP reporting must be completed 1000 mg/kg in each part of the product, except if lower limit applies for substance in other part of this document.
Material, substance, and article specific restrictions must be held. Also, for suppliers outside the EU
The list provided indicates the actual requirement per entry (substance/group) as an embedded document
Biocides (Biocidal Product Regulation (EC) No 528/2012)
All substances with a biocidal function must be declared as well as be approved within EU as an active substance for the use/material according to Biocidal Products Regulation (EU) No 528/2012 (or until 2024 under evaluation) even if no claim of biocidal action is made.
RoHS directive applies to all parts intended for use in electrical and electronic equipment
Nanomaterials
Suppliers have the duty to inform the Carter Industrial Company representative about the intentional use of nanomaterials.
Yes
For the purpose of product assessment, the following information might be requested: benefit or added values of the nanomaterial compared to the conventional material/product, evidence of the nanospecific effects, technical specification (e.g., size, structure), risk assessment regarding humans, animals and the environment
Substance requirements
Group of substances or legislation
Substance
CAS
Limitation type
Limit value (mg/kg)
A
B
C
Declarable
Carter Industrial Company requirements / comments
Alkylphenols (APs) and Alkylphenolethoxylates 7(APEOs)
Information on specific flame retardant treatment shall be documented and shared with Carter Industrial Company Minimum information:
• Flame retardant trade name
• Manufacturer • Active ingredients and their concentrations • Safety Data Sheet
Metals and metal compounds in nonmetallic materials and products
Antimony
Several
Restricted
5
10
50
As total extractable content of metal Metals and metal compounds in metallic materials and products are exempted – see Metals specific requirements Exemption: Antimony trioxide used as flame retardant
Arsenic
Prohibited
10
Barium
Restricted
100
Cadmium
Prohibited
40
Chromium III
Restricted
60
Yes
Chromium VI
Prohibited
3
Cobalt
Restricted
1
4
4
Yes
Copper
Restricted
25
50
50
Yes
Lead
Prohibited
40
Mercury
Prohibited
0.02
Nickel
Restricted
1
4
4
Silver
Restricted
0.1
Yes
Organotin Compounds
Appendix IV
Prohibited
Appendix IV
Polycyclic Aromatic Hydrocarbons (PAH)
Several- see appendix V
Appendix V
Prohibited
Appendix V
AfPS GS 2019:01 PAK
Polymers / Monomers
PVC (Polyvinyl chloride)
9002-86-2
Prohibited
ND
Carter Industrial Company reserves the right to allow exemptions
REACH Regulation (EC) No 1907/2006 article 33 puts a demand on informing customers if an article contains a substance on the Candidate list in a concentration greater than 0. 1wt% (1000 ppm) in any of the components of a complex object.
The EU Waste Framework Directive (WFD) 2008/98/EC has been updated to serve in the transition to a circular economy. The WFD requirement supplements the information demand in REACH article 33. Companies that produce, import or supply articles containing Candidate List substances must submit information on these articles placed on the EU market to the SCIP database, as from 5 January 2021.
Requirement for suppliers within the European Union
For suppliers within the European Union, Carter Industrial Company requires a SCIP number for any article(s) /component(s) containing SVHC substances above 0.1 wt.% and safe use instructions according to REACH Article 33, at latest at delivery.
Non-EU suppliers should provide necessary information and safe use instructions, so that Carter Industrial Company can fulfil their legal obligations regarding REACH article 33 and successfully register products to the SCIP database.
For a list of requirements for non-EU suppliers, see Appendix VIlI.
California Proposition 65 reporting requirement
Suppliers shall notify Carter Industrial Company of the use of all known chemicals found in California Proposition 65. Any California Proposition 65 chemicals either used in the manufacture of raw materials or found in the finished product must be disclosed. California Proposition 65 chemicals are not prohibited or restricted, but must be disclosed by providing a warning to consumers.
Conflict minerals
Carter Industrial Company requires all suppliers to annually provide information on the use of Conflict minerals, actions taken to verify the origin of used Conflict minerals and due diligence activities performed using the newest version of the CRT (available here: https://www.responsiblemineralsinitiative.org/reporting-templates/cmrt/)
PFAS
Carter Industrial Company supports the elimination of PFAS substances. Legacy use of PFAS in DWR fabric treatments is actively being phased out.