A review of the SDS should be done by the Certifier to check the following:
1. Any intentional addition in the formulation of a substance listed in the ZDHC MRSL V3.1 or listed under Archived List. This can be done by reviewing the information given in Section 3 of a GHS conformant SDS on the hazardous ingredients, using the CAS numbers declared by the formulator therein and checking in the ZDHC e-MRSL.
2. Correct the name of the product and the formulator name through the details given in Section 1 of the SDS to issue the final certification.
3. Any physical hazards (flammable, combustible, etc.) mentioned in Section 2 of the SDS to ensure safe storage and handling of the sample in the laboratory.
4. Chemical stability and reactivity information is given in Section 10 of the SDS.
5. Information on toxicological parameters in Section 11, such as skin/eye irritation/corrosion/ damage or acute oral or dermal toxicity, to ensure the use of proper PPE when handling the chemical sample in the laboratory for testing.
6. Information on ecotoxicological parameters in Section 12 for disposal considerations of the chemical sample
A screening methodology is recommended to support the decision on analytical testing of a chemical sample for ZDHC MRSL risks. The Annex A -Smart testing grid given in the ZDHC MRSL Conformance Guidance V2.0 document should be used as the guidance for analytical testing by the ZDHC Certifier. However, wherever there is a requirement to confirm MRSL substances other than those given in Annex A -Smart Testing Grid to support the professional judgment of the ZDHC Certifier, screening methodology can be used. The final certification for ZDHC MRSL Level 1 conformance must be based on analytical testing of the chemical sample.
Section 4.7 of the ZDHC MRSL Conformance Guidance V2.0 document gives details on screening methods that can be followed by a laboratory. However, these are for guidance only, and laboratories can develop their own approach to screening methodology.
The ZDHC Certifier should check the following:
•Is there any new ingredient that is listed in the ZDHC MRSL or in the Archived List as detailed in Section 3 of the SDS by the formulator?
•Is there any impact on ZDHC MRSL risks as per Annex A- Smart Testing Grid due to the change of ingredients in the formulation?
•Can such MRSL risks be confirmed through screening or will it require analytical testing?
•Does the formulation need to be tested for only an additional specific ZDHC MRSL Group/ substance based on the changes in the formulation?
Based on information obtained from the above checks, the ZDHC Certifier can perform the activities required to re-certify the formulation. The validity depends on the policy of the ZDHC Certifier. However, during the validity period, in case of a revision in the ZDHC MRSL version, the formulation should be re-certified to the latest ZDHC MRSL version by the ZDHC MRSL Approved Certifier before the end of the transition period for implementation of the new ZDHC MRSL version.
The implementation of the ZDHC MRSL V3.1 and ZDHC Conformance V2.0 has a transition period till November 2023. After this period, only ZDHC MRSL V3.1 certified products will be accepted in the ZDHC Gateway and all valid ZDHC MRSL V2.0 products will be archived. Hence, even if a product certified for ZDHC MRSL V.2,0 validity is ongoing, the formulator will have to re-certify the product to the ZDHC MRSL V3.1 at the appropriate ZDHC MRSL conformance level as per the ZDHC MRSL Conformance Guidance V2.0 criteria, upload the new certificate in the ZDHC Gateway and publish the same after verification by the ZDHC approved MRSL Certifier on the Gateway.
The substances mentioned in the Candidate List are an advance information to the chemical industry and may be put on the MRSL in the next update. Formulators should take note of the Candidate List substances and take actions to phase out those products in their portfolio which may contain these substances and prepare themselves for the next ZDHC MRSL update by developing safer alternatives. Formulators should also ensure that substances listed in the Archived List are not intentionally used in their formulations. ZDHC approved MRSL certifiers should check the SDS of formulations that they are certifying for ZDHC MRSL conformance levels that the Archived List substances are not used in those chemical formulations. If they find evidence of the same, the formulation does not conform to the ZDHC MRSL V3.1. Substances listed in Candidate List or Archived List do not require any testing to be done.
Principally, all formulations sites should be evaluated for Level 2 or Level 3 criteria through an on-site audit. However, if this is a challenge due to any practical reasons, the ZDHC approved MRSL Certifier may use his discretion and professional judgement to do an onsite audit of at least one main (major) formulation site and assess the other sites through online technology and document review to confirm the implementation of the Level 2 and 3 criteria at the other formulation sites.
Yes, re-certification of the products certified for ZDHC MRSL Level 1 for ZDHC MRSL V2.0 will have to be re-certified for ZDHC MRSL V3.1 and the new ZDHC MRSL Level 1 even if the ZDHC Approved MRSL certifier is the same as for the current certificate.
Formulations whose validity for ZDHC MRSL Conformance Level 1, 2 or 3 have expired will be placed in “Expired” category on the ZDHC Gateway. “Expired” formulations are not considered as a ZDHC MRSL Conformance Level. Such chemical products will be placed under “Expired’ for eight weeks on the ZDHC Gateway. After eight weeks, the chemical product is set back to private ‘products’ tab in the formulator’s account on the ZDHC Gateway. The formulator will be able to publish the product and make it visible under the product tab in their profile in ZDHC Gateway only if they recertify the product with a ZDHC Approved MRSL Certifier at the appropriate ZDHC MRSL Conformance Level. The formulators whose products are nearing the expiry date will be notified via e-mail or through the bell icon on the ZDHC Gateway 6 weeks in advance
The new feature applicable to the ZDHC MRSL V3.1 and the related ZDHC Conformance Guidance V2.0 will be reflected on the ZDHC Gateway as of 01 January 2023. The update will reflect structural changes to the ChemCheck report and the Performance InCheck Report during and after the ZDHC MRSL V3.1 and ZDHC Conformance Guidance V2.0 transition period on the ZDHC Gateway.
The transition period on the ZDHC Gateway starts on 01 January 1st 2023, and end on 31 October 2023. In this transition period, the products can still be verified according to both ZDHC MRSL versions (2.0 and 3.1). As of 01 November, 2023 only products according to the new ZDHC MRSL V3.1 and the related ZDHC Conformance Guidance V2.0 can be uploaded.
The following changes will take place on the ZDHC Gateway from 01 January onwards: - The ZDHC Gateway will only host ZDHC MRSL conformant chemical products with proof of conformance and thus only ZDHC MRSL Level 1,2,3. The “Registered” product status will disappear. - A new product status “Expired” will be introduced. An “Expired” product is a chemical product with an expired ZDHC MRSL Conformance certificate. A product that is expired will still be visible (published) on the ZDHC Gateway for 8 weeks, so the Formulator has time to re-certify the chemical product. Once the 8 weeks have been passed, the chemical product gets unpublished if there is no new ZDHC MRSL Conformance certification. - Upload of Safety Data Sheet (SDS) is mandatory for all ZDHC MRSL Conformant products. - Product that has been certified against ZDHC MRSL V3.1 can be uploaded and published on the ZDHC Gateway. - Product that has been certified against ZDHC MRSL V2.0 can be uploaded and published on the ZDHC Gateway until 31 October 2023. - If there is a certification for both ZDHC MRLS (2.0 and 3.1), the certification for ZDHC MRSL 3.1 prevails. - Product visibility of the prevailing certification in the ChemCheck report and in the Performance InCheck Report.
The following changes will take place on the ZDHC Gateway from January 1st onwards: - Product that has been certified against ZDHC MRSL 2.0 can not be uploaded and published on the ZDHC Gateway anymore from November 1st 2023. - If a product has been only certified against ZDHC MRSL 2.0 and not against ZDHC MRSL 3.1 until November 1, the product will be moved to an “Expired” public product status for 8 weeks. If the product will not be rectified against ZDHC MRSL 3.1 within 8 weeks the product will be automatically unpublished and not be visible on the ZDHC Gateway anymore until a new valid ZDHC MRSL 3.1 certification has been uploaded. - The Performance InCheck Report will still show ZDHC MRSL 2.0 certified products until May 31st 2024.
containing the ZDHC MRSL listed Boron-containing substances for ZDHC MRSL conformance?
The ZDHC MRSL V3.1 document lists the following Boron containing substances and related test
The formulation limits for Boron containing flame retardant substances is 250 mg/kg, and for
other/miscellaneous substances i.e. Borate, Zinc salt and Perboric acid, sodium salt is 1000 mg/kg).
The presence of these substances is through results for total elemental Boron performed by
“Methanol, extraction, ICP” or “Acid digestion, ICP”, which determines the ‘Total Boron’ content.
In case total boron is determined by the laboratory, they should take the following steps to certify the formulation for the boron-containing substances listed in the MRSL 3.1:
1. Discuss with the chemical formulator on the application/use of the formulation to determine
the possibility of boron-based substance in the formulation.
2. Get proper ingredient information based on SDS or any other document review or
consultation with the chemical formulator.
3. Based on this information, the interpretation of total boron can be done through a
the mathematical calculation for the relevant Boron-based ingredient in the formulation. For
example, if the content of Boron determined by ICP is 150 mg/kg and the ingredient in the
the formulation is confirmed as Boric acid (flame retardant finish), then the content of Boric acid
(H 3 BO 3 ) in the formulation can be deduced as follows:
Content of Boric acid (H 3 BO 3 ) = 150 mg/kg X 61.84 (Molecular weight of Boric acid)
10.81 (Atomic weight of Boron)
= 858.1 mg/kg
Since the result as per the calculation is above the MRSL limit value of 250 mg/kg, the
the formulation does not conform to the ZDHC MRSL V3.1. A laboratory should develop its methodology for calculations for each boron-based substance.
Methoxypropyl acetate (CAS No. 70657-70-4)’, there is a general formulation limit of 50 mg/kg
and a formulation limit of 1000 mg/kg specifically for ‘Leather finishing formulations'.
When certifying a sample for the ZDHC MRSL V3.1, how does a laboratory distinguish between a Leather finishing formulation and any other general formulation for leather applicability?
The term ‘leather finishing’ can be defined as the finishing which determines the appearance of the final surface of the leather and the surface properties as well. This covers not only colouring, waterproofing, and wax dressings but also mechanical processing stages such as ironing and embossing of the leather. Typically in the first step of leather finishing, finishing agents are applied to cover the grain defects. Next, the basecoat, which forms the base for the leather design, is applied. Finally, leathers are finished with a topcoat to support the manufacturer's visual and physical specifications. The final colouring is also applied to the topcoat, which levels the colour of the leather.
Out of all the leather finishing agent categories listed in the ZDHC Gateway, only the following leather
finishing categories are granted this exception of formulation limit of 5000 mg/kg:
- Cellulose Derivatives (base coat, top coat, etc.)
- Crosslinkers (Finishing)
- Matting agents - Inorganic
- Matting agents - Organic
- Patent leather
- Protein Binders
- Transfer coating