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German GS Mark Certification

From July 1st, 2020, the voluntary German GS Mark certification requires new evaluation and specifications for the restriction of polycyclic aromatic hydrocarbons (PAHs).

Transition to New GS Mark Standard

Germany Flag - GS Mark

The Committee for Product Safety, or Der Ausschuss für Produktsicherheit (AfPS) in German, published the original GS mark requirements on August 4th, 2014, as standard AfPS GS 2014:01 PAK. Later, they revised it on May 15th, 2019, to make standard AfPS GS 2019:01 PAK, replacing the original.

New Changes for GS Mark Certification

In sort, the GS Mark applies to various product categories, including:


Furthermore, additional consumer products for children fall into the standard’s scope, among other new modifications. As a result, if you manufacture, export, or distribute devices for kids, such as toys, in Germany, you may want to consider the GS Mark specifications.

GS Mark - Toy

What are Polycyclic Aromatic Hydrocarbons?

First, Polycyclic aromatic hydrocarbons (PAHs) are a group of toxic chemicals. They bind to air particles, and breathing them in repeatedly may cause:

  • Cancer
  • Liver Damage
  • Respiratory tract irritation


Moreover, PAHs in the air irritate the eyes. In addition, air particles with PAHs attached to them may pass through our skin.

Finally, another source of exposure is eating burnt meats or food on which the PAH-bonded air particles have settled.

How do PAHs Get in the Air?

Generally, PAHs enter the atmosphere by burning:

  • Wood
  • Tobacco
  • Gasoline
  • Coal
  • Crude oil; and
  • Garbage.
PAH Pollution

Therefore, PAH sources include wood smoke, cigarette/cigar smoke, and motor vehicle exhaust.

PAH Contamination in Materials

Examples of products containing traces of PAHs include:

  • Carbon black (black pigment in plastics, paints, and rubber)
  • Plasticizer oils in flexible plastics and rubber
  • Solvents containing hydrocarbons
  • Various synthetic fibers
  • Natural latex
  • Materials treated with naphthalene
PAH Containing Tire

Procedure for Awarding the GS Mark Certification

First, the GS body for GS Mark certification does a risk assessment to determine which product surfaces to test. In other words, they see to which parts of the product the requirements apply.

GS Mark Requirements

Specifically, the GS requirements pertain to surfaces of the product that the consumer may directly touch. They do not apply to inaccessible areas or regions only accessible with tools.

Second, the GS body examines the product parts considered relevant. The maximum limit of PAH concentration ranges from 0.2 mg/kg to 50 mg/kg, depending on the particular substance and product application.

Third, based on test analysis, the GS body determines whether the product meets the qualifications for a GS mark.

Examples of PAHs

Essentially, PAHs considered in AfPS GS 2019:01 PAK include:

  • Benzo[a]pyrene
  • Benzo[e]pyrene
  • Benzo[k]fluoranthene
  • Chrysene
  • Pyrene
  • Anthracene
  • Naphthalene
anthracene PAH Molecule

PAH Concentration Limits for GS Mark

As mentioned above, the maximum PAH concentration limit depends on the chemical and product usage. For the latter, there are three categories:

touch hand skin
  • Category 1 includes materials intended to be put in one’s mouth or come into contact with the skin for longer than 30 seconds in products for children up to three years old.
  • Category 2 includes materials intended to touch the skin for over 30 seconds or repeated short-term contact.
  • Category 3 includes materials making physical contact with the skin for less than 30 seconds.

More details are available on standard AfPS GS 2019:01 PAK.

Finally, other policies and regulations applicable in Germany include:

  • the Supply Chain Due Diligence Act;
  • Ecodesign;
  • Waste of electrical and electronic equipment;
  • EU RoHS;
  • POP on persistent organic pollutants; and

Should you have any questions or need assistance, don’t hesitate to contact Enviropass.