Product Compliance Resources provided by ProductIP


Chemical numeric identifiers

Disclaimer: This document provides guidance and is not a legally binding interpretation and shall therefore not be relied upon as legal advice.

Navigating chemical compliance in everyday consumer products

In everyday consumer products, there are rules about the use and presence of certain chemicals. Some chemicals cannot be used in specific products, while others are allowed only under certain conditions. These rules vary depending on the type of product, such as toys, food contact materials, electronics, cleaning products, cosmetics, paints, clothing, footwear, tools, medical devices, and more. If chemicals are released from these products, they can be harmful to people and the environment, leading to restrictions or bans. Additionally, there are regulations concerning recycling and ensuring everyone knows what chemicals are present in the products we use. Following all these rules can be challenging because chemicals often have different names. That is why special numeric codes or identifiers are used in chemical databases.

What are chemical numeric identifiers?

Chemical numeric identifiers are crucial for accurately identifying and managing chemicals listed in a Bill of Materials (BOM) or a Bill of Substances (BOS), ensuring chemical product compliance, and helping quality and regulatory assurance managers communicate clearly within the supply chain.

For chemical product compliance two chemical identifiers are used in Europe's ECHA database.

  1. CAS - Chemical Abstracts Service numbers
    • Format xxx-xx-x (e.g. 7732-18-5 for water)
  1. EC - European Community numbers
    • Format xxx-xxx-x (e.g. 231-791-2 for water)

Unfortunately there are sometimes multiple CAS or EC-numbers for the same chemical substances due to scientific and/or commercial reasons.

Understanding the basics

Bill of Materials (BOM):

This is a list of all the parts, components, and materials present in a product. Think of it as a recipe for a product.

Bill of Substances (BOS):

This is a detailed list of all the chemical substances that are present in the materials listed in the BOM. It shows what the materials are made of at a chemical level.

ECHA Database:

This is the European Chemicals Agency’s database. It contains information about chemicals that are regulated in Europe. It is the best place to check if the substance used is compliant with European regulations.

A common problem when checking a BOM and BOS

You have numeric identifiers (CAS numbers or EC numbers) on your BOS or BOM, but these are not found in the ECHA database. Please be aware that not all numbers have been listed in the ECHA database.

The steps to deal with this problem are:

  1. Double-check the numbers. Ensure that there are no typo's or mistakes in the numeric identifiers. It is easy to misplace a digit or letter.
  2. Verify the substance’s name. Look up the substance name in the ECHA database directly. Sometimes, identifiers might be incorrect, but the substance name can give you the correct one.
  3. Use other chemical databases. PubChem or ChemSpider are databases might provide additional information or correct identifiers.
  4. Contact suppliers. Reach out to the suppliers of the materials. They should provide you with accurate and compliant substance information. Ask them for the correct numeric identifiers or additional documentation
  5. Consult a Regulatory Expert. If you’re still unsure, consult with a regulatory compliance expert or a consultant. The expert can help you navigate through the regulations and databases.


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