The Committee on Product Safety (AfPs) adopted a new polycyclic aromatic hydrocarbons (PAHs) document on 4th of August 2014, which is taken into account within the GS mark certification. The PAHs requirements are largely revised.
New requirements will apply from 1st of July 2015 and replace the previously valid PAHs-document (ZEK 01.4-08).
Link to the new PAHs document:

Main Amendments

New PAHs requirement is listed in table 1 with amendments as below:

1. The PAHs document introduces new product classification. Both REACH Annex XVII restriction on PAHs and Directive 2009/48/EC on toys are considered. Category 2 & 3 are further classified into two scopes (toys covered by Directive 2009/48/EC and other products);

2. Limits on Benzo[e]pyrene, Benzo[a]anthracene, Benzo[b]fluoranthene Benzo[j]fluoranthene, Benzo[k]fluoranthene, Chrysene, Dibenzo[a,h]anthracene, Benzo[g,h,i]perylene, lndeno[1,2,3-c,d]pyrene and Naphthalene as well as sum of Acenaphthylene, Acenaphthene, Fluorene, Phenanthrene, Pyrene, Anthracene and Fluoranthene are added in the new requirements;

3. Benzo[a]pyrene limit for materials in category 2 & 3 is much lower than that of ZEK 01.4-08;

4. Limit of 18 PAHs is much lower than that of ZEK 01.4-08.


PAHs restriction for GS certification has been in effect since the 1st of April 2008. The German Board for Technical Work Equipment and Consumer Products (AtAV) requires that all products with GS marking must fulfil the requirements of the US EPA on 16 PAHs. The PAHs restriction was updated by ZEK 01.4-08, which became mandatory from 1st of July 2012. The list of PAHs was expanded from 16 to 18 by including benzo[j]fluoranthene and benzo[e]pyrene.

The EU published (EU) No 1272/2013 on the 7th of December 2013, amending Entry 50 of Annex XVII to the REACH Regulation regarding PAHs. If rubber or plastic components that come into direct and prolonged contact with the human skin or the oral cavity contain of any of the listed PAHs above the defined limitat, under normal or reasonably foreseeable conditions of use, toys and articles shall not be placed on the market for supply to the general public. The new restriction shall apply from the 27th of December 2015.

Our recommendation

The new document has largely revised the PAHs limits in GS-mark certification,which is much stricter than that of before and will sharply impact the industry. The GS-mark is a well recognized safety certification in the EU and PAHs testing is a must to get the certificate. CTI therefore recommends that manufacturers and importers test for the listed PAHs to increase their access to European markets. Supply chain survey and production procedure review are also needed to decrease the risk.

We can provide testing, inspection, audit and certification services to consumers. We can also provide professional and comprehensive quality solutions to improve the competitiveness of your products in the global market.

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Table 1 New requirement of PAHs (mg/kg) in GS-Mark Certification