All Collections
How To Guides and Use Cases
Product Compliance How To
Composing and Verifying Restricted Substance Lists
Composing and Verifying Restricted Substance Lists
G
Written by Grzegorz Kossobudzki
Updated over a week ago

RSLs Purpose

Regulators all over the world create Restricted Substance Lists (RSLs) related to harmful chemical ingredients and demand that manufacturers comply with such lists when making products. The idea is to ensure that the end product is not harmful to the consumer or to the environment due to the presence of toxic or non-biodegradable substances. To name a few examples:

  • Certain refrigerants used in fridges or air conditioning systems were once restricted due to the ozone layer depletion problem, now they are restricted due to a problematic end-of-life phase.

  • Certain substances are banned entirely, such as the DDT insecticide.

  • Certain substances are restricted based on the context of their usage, for example lead.

RSLs are represented as data objects in Makersite and serve as the foundation for compliance verdicts.

Import an RSL

Typically, RSLs are imported into Makersite, which already has a lot of RSLs available. See Import a Compliance List for details on how to import an RSL.

Compose or Verify an RSL

You can either compose a new list (which is not something you typically would do), or use the Compose page to check or edit the RSL data. To edit RSL data, you need to have the appropriate access level.

  1. In Makersite, select Compose > RSL or open an existing RSL and go to Compose mode.

  2. Fill in the form if you're composing a new RSL. If you're editing existing RSL, this data is available under the Description tab if you have the necessary access rights.

Field

Description

List Name

Name identifying your RSL

Source

Source of data

Calculate compliance?

Should this list be used when you run the next compliance check on a Product?

Compliance calculation method

  • Worst case - if any subcomponent in the product verified against this list exceeds the allowed substance limit, the entire product is treated as non-compliant.

  • Substance aggregate - restrictions are checked against the total composition of the final product, not its subcomponents.

Region

Geographical region where these restrictions apply.

Add/Check Substance Restrictions

You can now see your RSL's definition, but the RSL doesn't mean anything without substances. Let's add/check them now.

  1. Open the Restrictions tab on your RSL.

  2. Select Create New and fill in the form.

  3. Confirm your choice. Now, your RSL has some meaning. Whenever a product is checked for compliance against this RSL, it is checked against the substances in the Restrictions list.

Field

Description

Substances

Substance restricted by this list

Limit [%]

Maximum substance concentration allowed. Defaults to 0 if not entered.

Introduced on/Phased out on

Dates defining when this restriction is valid.

Add/Check Exemption Statements

Your RSL now has substance restrictions, but there are cases where regulators allow manufacturers to declare certain substances as exempt from the compliance check, for a specific reason. To cover such cases on the RSL level, Makersite defines Exemption Statements. These are the only exemptions justified directly by this RSL.

Exemptions are typically based on:

  • Context of use (as in, it's OK to have lead in a battery as long as the battery is made for a car)

  • The product itself (as in, it's OK to have lead in a car)

Note that getting exemptions wrong can result in a fine for the manufacturer.

  1. Open the Exemption Statements tab on your RSL.

  2. Select Create New and fill in the form.

  3. Confirm your choice. Now, it is possible to assign exemptions on Products for this RSL based on defined Exemption Statements. Note that if Exemption Statements are not defined on an RSL, you can still mark a Product as exempt without a Statement, at your own responsibility.

Field

Description

Name

Exemption statement name

Substance/Substance group

Substance (or group) for which we're declaring an Exemption Statement.

Regulation

The act of law legitimizing this exemption statement.

Description

The explicit statement explaining why a certain substance can be declared exempt from normal restrictions applied by this RSL.

Expires on

Exemption statement is no longer valid after this date.

Notes

Anything extra you want to add

Add/Check Regulatory Declarations

Regulatory Declarations provides a list of declarations which can be used on the Product level to state compliance with the entire RSL, unlike exemptions which are defined per restricted substance. If Regulatory Declarations are defined on the RSL, you can only use these declarations as Regulatory Statements on the Product Group.

  1. Open the Regulatory Declarations tab on your RSL.

  2. Select Create New and fill in the form.

  3. Confirm your choice.

Field

Description

Declaration ID

Reference to a specific regulation

Statement

Regulatory statement considered legitimate by this RSL for product compliance or non-compliance when someone wants to overrule a normal substance check.

Compliance Status

Should this statement make a product compliant or non-compliant?

Notes

Anything extra you want to add

What's Next?

When you have your RSLs in order, you can run compliance checks against your Products. There are several places where you can check compliance:

  • Check the Exemptions on the Product Group, which show the possible compliance issues Makersite found based on the chemical composition of the products (i.e. the exemptions necessary to achieve compliance, hence the name of the tab).

  • Add Regulatory Statements on Product Groups.

  • Run the Compliance Status Overview report to get a compliance status for multiple products against multiple RSLs.

  • Run the Compliance Status Report to get a complience status for a product against one or more RSLs.

Did this answer your question?