QSOP 3600 Rev.11.00 Heavy Elements 8-20-2021

美泰机密文件/ 商业秘密资料。版权所有。版权 2021年
3600 Heavy Elements

Number Revision Date Assigned Author
QSOP 3600 11.00 2021-08-20 Ying Gao
FOR QUESTIONS CONTACT

QUALITY SAFETY OPERATING PROCEDURE
Ying Gao
Mattel Confidential Information | May Include Trade Secrets | Property of Mattel
1 - SCOPE (3600 )
1.1 - Products and Components Covered
1.1.1 - All toys and child care articles
1.1.2 - Test the following to QSOP 3602, Heavy Elements- Children's Products and General Consumer Products
Non- toy/non-child care article children's products

General Consumer Products
1.1.3 - Test the following to QSOP 3604, Heavy Elements – Jewelry
Jewelry intended to be worn by either a child or an adult

Jewelry ornaments on clothing or shoes intended to be detachable so that they can be attached as a charm
to a jewelry item such as a necklace, bracelet, etc.
1.1.4 - Test the following to QSOP 3606, Heavy Elements – Children’s Apparel, Handbags and Similar Items
Children’s apparel
Handbags and similar items
1.1.5 - Test the following to QSOP 3607, Heavy Elements – Cosmetics
All cosmetics *
*Cosmetic toys shall comply with the requirements in both QSOP 3600, Heavy Elements and QSOP 3607,
Heavy Elements - Cosmetics
1.1.6 - Batteries and Battery- operated products must comply with the requirements in the QSOP 3274, Batteries
and Battery Operated Products.
1.1.7 - All reusable packaging intended to be retained with the finished product
1.2 - Exemptions
1.2.1 - If sample material is <10 mg the material is exempt from soluble method 1 requirements. Total and soluble
method 2 requirements still apply.
1.2.2 - Glass is exempt from total cadmium requirements. Soluble cadmium requirements still apply.
1.2.3 - The following items are exempt from all requirements in this document with the exception of § 2.1 and in
§2.4:
3600 Heavy Elements (rev. 11.00) 1 | Page

Uncontrolled Document, Generated by: Kat Wu on 2021-08-22 22:24 Mattel – Confidential Information
Components that are not accessible after use and foreseeable abuse
1.2.4 - Promotional items intended for adults.
1.2.5 - Items listed in Appendix III are exempt from the total Pb requirements.
1.2.6 - The following items are exempt from total nickel requirement
Stainless steel
Child care articles
Material using nickel for electrical conductivity purpose.
Nickel plated axles on toys suitable for >3 years old where the only accessible portion is the part that
protrudes from the center of the wheel and the diameter of this portion is ≤ 2.0 mm. (Refer to §5 - Q&A 6)
1.2.7 - Items listed in Appendix V are exempt from §2.4.
1.2.8 - Metals are exempt from organotin requirements.
1.2.9 - Products intended for children over 6 years and packaging intended to be retained for children over 6
years are exempt from the organotin requirements unless
they are intended or likely to be put in the mouth or to the mouth. Items considered likely to be put in the
mouth include cosmetic toys or writing instruments.
they are intended for prolonged skin contact.
1.3 - Definitions (Words that are defined are italicized and bolded once per section)
1.3.1 - Accessible: Any area of the product that can be contacted by any portion forward of the collar of the
accessibility probes when inserted to the depth determined in QSOP 3010, Accessibility.
1.3.2 - Art Materials: Any substance marketed or represented by the producer or repackaged for use in any
phase of the creation of any work of visual or graphic art in any medium such as crayons, clay/modeling
compounds, glues (liquid and stick), paints (finger, watercolor, liquid), markers and similar “wet” medium, colored
pencils, chalk, ball point pens and pencils.
1.3.3 - Child Care Article: Any product intended for children to facilitate seating, sleeping, relaxation,
transportation, physical protection, hygiene and feeding or sucking/drinking.
1.3.4 - Composite (Sample): A sample made from combining more than one material or color (e.g. paint: red,
yellow and blue), vacuum metalized coating (silver and gold). It is not considered compositing when colors or
materials that can not be separated (e.g. thin stripes, doll eyes, etc.) are tested together.
1.3.5 - Dry, Brittle, Powder Like or Pliable Materials: Dry, brittle, powder like or pliable materials include solid
toy materials from which power-like materials is released during playing and semi-solid materials that may also
leave residues on the hands during play. The material can be ingested. Refer to the Appendix IV for determining
category.
1.3.6 - General Consumer Product: A consumer product that is not designed or intended primarily for use by
children 14 years old or younger. It is designed or intended primarily for use by consumer older than age 14 or
consumers of all ages.
1.3.7 - Jewelry Items: Ornamental items that are intended to be worn in the hair or on the body. Examples would
include rings, necklaces, bracelets, watches etc. This definition also includes jewelry kits that are intended to
create jewelry items.

1.3.8 - Liquid or Sticky Materials: Liquid or sticky materials include fluid or viscous toy materials, which can be
ingested or to which dermal exposure may occur during playing. Refer to the Appendix IV for determining
category.
1.3.9 - Prolonged Skin Contact: Items are intended to be in direct contact with children’s skin over one hour.
Such as, clothes, jewelry, bedding, and costumes. Items that are intended to be worn over clothing are not
considered as prolonged skin contact. Items that are intended for dolls are not considered as prolonged skin
contact.
1.3.10 - Promotional Items: Items provided to the consumer to promote a product or brand. These items may or
may not be included in, or with, a product. Examples include items such as booklets, catalogs, bookmarks, growth
charts, and posters. In some instances, a promotional item may be an actual product in package that is given
away.
1.3.11 - Scraped-off Materials: Scraped-off materials include solid toy materials with or without a coating, which
can be ingested as a results of biting, tooth scraping, sucking or licking. Refer to the Appendix IV for determining
category.
1.3.12 - Small Part: A part that fits within the truncated test cylinder when evaluated per QSOP 3020, Small Parts,
Small Balls and Marbles.
1.3.13 - Substrate: The base material of an item, regardless of whether or not it has a surface coating. Labels
and electroplating are both considered substrate materials.
1.3.14 - Surface Coating: All layers of materials such as paint or similar materials, that dry to a solid film when
applied to a substrate and that can be scraped off with a sharp blade or washed off with a solvent such as acetone
or ethanol, without removing the substrate (base) material. These are factory applied coatings on products.
1.3.15 - Toy: Any product or material designed or clearly intended for use in play by children less than 14 years of
age.
1.4 - Purpose
Evaluate product for compliance to worldwide safety standards for heavy metals content.
2 - PERFORMANCE REQUIREMENTS
Performance requirements must be met both before and after all applicable Use and Abuse testing.
Products intended to be assembled by an adult should be evaluated for accessibility and for small parts after
assembly.
2.1 - All Products

All inaccessible materials must have ≤ 75 ppm Total Cadmium (Cd) as shown in Table 1.
Table 1 - Heavy Element Limits for Inaccessible Parts of All Products
ELEMENT TOTAL (ppm)
Cadmium (Cd) 75
2.2 - Components Intended for Use Exclusively by Adults
2.2.1 - Surface Coatings

The following must have < the limits listed in Table 2.

All accessible surface coatings
All surface coatings on packaging intended to be retained
Table 2 - Heavy Element Limits for Surface Coatings on Products Used Exclusively by
Adults
ELEMENT TOTAL (ppm)
Cadmium (Cd) 75
Lead (Pb) 90
2.2.2 - Plastics
The following must have < the limits specified in Table 3.
All accessible plastic parts

All plastic in packaging intended to be retained
Table 3 - Heavy Element Limits for Plastics in Products Used Exclusively by Adults
ELEMENT TOTAL (ppm)
Cadmium
75
(Cd)
Lead
90
(Pb)
2.3 - All Toys and Child Care Articles (Including Non-Silkston Collectible Fashion Dolls Intended for Brazil)
2.3.1 - Surface Coatings

The following must have ≤ the limits listed in Table 4
All accessible surface coatings except the ones in §2.3.1.1

All accessible surface coatings on non-paper/paper board packaging intended to be retained
Table 4 Heavy Element Limits for Surface Coatings
ELEMENT TOTAL (ppm) SOLUBLE SOLUBLE

METHOD 1 (ppm) METHOD 2 (ppm)
Antimony (Sb) - 60 1000
Arsenic (As) - 25 1000
Barium (Ba) - 1000 1000
Cadmium (Cd) 75 17 1000
Chromium (Cr) - 60 -
Lead (Pb) 40 23 -
Mercury (Hg) 10 - -
Selenium (Se) - 460 1000

Aluminum (Al) - 28130 -
Boron (B) - 15000 -
Cobalt (Co) - 130 -
Copper (Cu) - 7700 -
Manganese (Mn) - 15000 -
Nickel (Ni) 10000 930 -
Strontium (Sr) - 56000 -
Tin (Sn) - 180000 -
Zinc (Zn) - 46000 -
Chromium (VI) (Cr VI) - 0.053 -
Organic tin - 12 -
2.3.1.1 - The following must have ≤ the limits listed in Table 5
Accessible Surface Coating on Printed Paper and Paper Board including products and packaging
intended to be retained.
Table 5, Heavy Element Limits for Surface Coating on Pri
nted Paper/Paper Board
ELEMENT TOTAL (ppm) SOLUBLE SOLUBLE

METHOD 1 (ppm) METHOD 2 (ppm)
Antimony (Sb) - 60 1000
Arsenic (As) - 25 1000
Barium (Ba) - 1000 1000
Cadmium (Cd) 75 17 1000
Chromium (Cr) - 60 -
Lead (Pb) 40 23 -
Mercury (Hg) 10 - -
Selenium (Se) - 460 1000
2.3.2 - Metal, Glass, Gemstone and Ceramic
2.3.2.1 - Non-Small Parts

Accessible metal, glass, gemstone and ceramic must have < the limits listed in Table 6.
Table 6- Heavy Element Limits for Non-Small Part Metal, Glass, Gemstone & Ceramic
ELEMENT TOTAL (ppm)

Cadmium (Cd) 75
Lead (Pb) 90
Nickel (Ni) 10000
2.3.2.2 - Small Parts Containing Accessible Glass, Ceramic, Metallic Materials

All accessible metal, glass, gemstones, and ceramics must have ≤ the total limits listed in Table 7
Small parts containing accessible glass, ceramic, metallic materials must have ≤ the soluble limits listed
in Table 7
Apply the soluble method to the whole small part.
If the small part contains surface coatings, the surface coating shall be tested according to section
2.3.1. A small part testing shall be performed after removing any of coating.
Table 7 - Heavy Element Limits for Small Part Metal, Glass, Gemstone and Ceramic
ELEMENT TOTAL (ppm) SOLUBLE METHOD 1 (ppm)
Antimony (Sb) - 60
Arsenic (As) 25
Barium (Ba) - 1000
Cadmium (Cd) 75 17
Chromium (Cr) - 60
Lead (Pb) 90 23
Mercury (Hg) - 60
Selenium (Se) - 460
Aluminum (Al) - 28130
Boron (B) - 15000
Cobalt (Co) - 130
Copper (Cu) - 7700
Manganese (Mn) - 15000
Nickel (Ni) 10000 930
Strontium (Sr) - 56000
Tin (Sn) - 180000
Zinc (Zn) - 46000
Chromium VI (CrVI) - 0.053
Organic tin - 12
2.3.3 - All Other Scraped-off Materials


All accessible parts

All other accessible material used in packaging intended to be retained
Printed paper and paper board
Table 8 - Heavy Element Limits for Scrapped-off Materials
Antimony (Sb) - 60
Arsenic (As) - 25
Barium (Ba) - 1000
Cadmium (Cd) 75 17
Chromium (Cr) - 60
Lead (Pb) 90,40* 23
Mercury (Hg) - 60
Selenium (Se) - 460
Boron (B) - 15000
Cobalt (Co) - 130
Copper (Cu) - 7700
Nickel (Ni) 10000 930
Tin (Sn) - 180000
Zinc (Zn) - 46000
Chromium VI (Cr VI) - 0.053
Organic tin - 12
* 40 ppm total lead limits only apply to the child care articles intended to be placed into a child’s mouth.
2.3.4 - Dry, Brittle, Powder-like or Pliable Materials


Table 9 - Heavy Element Limits for Dry, Brittle, Powder-Like or Pliable Materials
Antimony (Sb) - 45
Arsenic (As) - 3.8

Barium (Ba) - 250
Cadmium (Cd) 75 1.3
Chromium (Cr) - 37.5
Lead (Pb) 90 2
Mercury (Hg) - 7.5
Selenium (Se) - 37.5
Boron (B) - 1200
Cobalt (Co) - 10.5
Copper (Cu) - 622.5
Nickel (Ni) 10000 75
Tin (Sn) - 15000
Zinc (Zn) - 3750
Chromium VI (Cr VI) - 0.02
Organic tin - 0.9
2.3.5 - Liquid or Sticky Materials


Table 10 - Heavy Element Limits for Liquid or Sticky Materials
Antimony (Sb) - 10
Arsenic (As) - 0.9
Barium (Ba) - 350
Cadmium (Cd) 75 0.3
Chromium (Cr) - 9.4
Lead (Pb) 90 0.5
Mercury (Hg) - 1.9
Selenium (Se) - 9.4
Aluminum (Al) 560
Boron (B) 300

Cobalt (Co) 2.6
Copper (Cu) 156
Manganese (Mn) 300
Nickel (Ni) 10000 18.8
Strontium (Sr) 1125
Tin (Sn) 3750
Zinc (Zn) 938
Chromium VI (Cr VI) 0.005
Organic tin 0.2
2.4 - Additional Requirements for All Electrical and Electronic Products
2.4.1 - All accessible and inaccessible parts must meet the flame retardant requirements of QSOP 3614, Flame
Retardants.
2.4.2 - All accessible parts must comply with the requirements described from § 2.1 to §2.4 if applicable. All
accessible and inaccessible parts must have ? the heavy element limits specified in Table 11.
Table 11 - Heavy Element Limits: All Parts of All Products
ELEMENT TOTAL (ppm)
Cadmium (Cd) 75
Chromium VI (Cr VI) 1000
Lead (Pb) 1000
Mercury (Hg) 1000
2.5 - Additional Requirements
2.5.1 - Any PVC resin with a tin based stabilizer must be CKT series from Wofoo.
2.5.2 - Surface coatings are not allowed to be applied to PVC using a tin-based stabilizer.
Note: CKT series PVC from Wofoo uses tin-based stabilizers; Clear PVC sheeting uses tin-based stabilizers.
2.5.3 - PVC using a tin-based stabilizer must be tested after being subject to aging test per QSOP 4400, Simulated
Aging and Storage.
3 - PROCEDURE
3.1 - Environment (N/A)
3.2 - Equipment
Use equipment specified in procedures referenced in §3.4
3.3 - General Requirements
3.3.1 - If feasible, samples are to be tested in the same form they appear on the finished product, e.g. paint is
tested in the dry state.
3.3.2 - Coated surfaces require testing of both the surface coating and the substrate (base material) with the

coating removed.
3.3.3 - Colors or materials can be combined if they cannot be physically separated (e.g. overlapping colors of
paint, adhesive on a label). This is not considered composite testing. For example, glues or adhesives that
cannot be physically separated from the substrate (e.g. adhesive on a paper label) should be tested together with
the substrate.
3.3.4 - Composite testing is not permitted for Soluble 1 and 2 testing. This does not apply to Total digestion
testing that is used to satisfy Soluble 1 and 2 limits per §3.4.1.
3.3.5 - The analytical correction factors in the Table 12 should be applied to Soluble 1 results per GLOP 7409,
Data Handling for the ICP. These correction factors should not be applied to total digestion results or Soluble 2
results.
Table 12 - Analytical Correction
Elements Sb As Ba Cd Cr Pb Hg Se
Analytical correction (%) 60 46.8 30 0 30 0 36.2 0
3.3.6 - Composite testing, when permitted, must meet the following criteria:
No more than 3 samples may be used

Equal weights of each sample should be used
Compositing must be done using similar materials with similar properties
3.3.7 - Measures must be taken to ensure a failing result is not masked by the other samples in a
composite. Acceptable methods for calculating the maximum possible concentration of an analyte in a single
sample are detailed in CPSC test method CPSC-CH-E1003-09 and Mattel GLOP 7406, Total Digestion for Heavy
Element Analysis
3.3.8 - Test frequency is per the following:
GQMP 2112, Surface Coatings Material Control

GQMP 2113, Heavy Elements Control on Surface Coatings for Vendors
GQMP 2118, Substrate Material Control
GQMP 2119, Heavy Elements Control on Substrates for Vendors
3.3.9 - Requirements of §2.4

A declaration of compliance must be obtained from each supplier certifying compliance to §2.4. The declaration of
compliance form can be found in GQMP 2115, Supplier Approval Process, Appendix III.
3.3.10 - High risk materials for Cr VI under §2.3 shall be performed Cr VI testing. The compliance of other
materials in §2.3 to Cr VI has been demonstrated by a product chemical safety assessment, therefore Cr VI
testing is not required. High risk materials for Cr VI are leather.
3.4 - Method
3.4.1 - General
3.4.1.1 - Laboratories may use the results from the total test to satisfy soluble 1 and soluble 2 requirements, if
they have demonstrated that the Total digestion and analysis methods they employ are capable of accurately
testing for all analytes of interest (As, Ba, Cd, Cr, Hg, Pb, Sb, Se, Al, B, Co, Cu, Mn, Ni, Sr, Sn, and Zn).

3.4.1.1.1 - For As, Cd, Cr, Hg, Pb, Sb, Se , Al, B, Co, Cu, Mn, Ni, Sr, Sn, and Zn, if the total element test
result is ? the total and soluble limits, soluble test methods 1 and 2 are not required. For Barium (Ba), total
result must be ? 50% of the respective Soluble 1 or Soluble 2 limit. If result is >50% of the respective limit,
then the related soluble test must be performed (e.g. if the result is greater than 50% of Soluble 1
requirement, then the Soluble 1 test must be performed).
3.4.1.1.2 - If the total test result is > the total limit, then the material fails and no further testing is performed.
See Appendix I for examples.
3.4.1.1.3 - Follow Appendix II if sufficient sample to conduct the testing cannot be collected from 12 units.
3.4.1.1.4 - Materials falling into §2.3.4 and §2.3.5 need be tested by the external labs with ICP-MS per the
following methods.
3.4.1.1.5 - For organic tin in scraped - off materials, If total tin ? 12 ppm, soluble 1 testing is not required. If
total tin >12 ppm, soluble 1 testing is required. If soluble 1 tin >2.5 ppm, the further testing is required to
confirm the organic tin content. If soluble 1 tin ? 2.5 ppm, the GC-MS testing is not required.
3.4.2 - Mattel Internal Labs

Mattel internal test laboratories must follow appropriate Global Laboratory Operating Procedure
3.4.2.1 - Total Test Methods
Test Glass and Ceramic at an external laboratory.

Test all other materials per GLOP 7406, Total Digestion for Heavy Element Analysis
Follow Appendix II if sufficient sample to conduct the testing cannot be collected from 12 samples.
3.4.2.2 - Soluble Method 1
Test per GLOP 7408, Soluble Extractions for Heavy Metal Analysis
If 10 mg of sample cannot be collected from 1 sample, do not perform an analysis.
Test per GLOP 7408, Soluble Extractions for Heavy Metal Analysis
Follow Appendix II if sufficient sample to conduct the testing cannot be collected from 12 samples
3.4.3 - External Labs
3.4.3.1 - Total Test Methods
3.4.3.1.1 - External labs shall not check total nickel requirement for finished goods.
3.4.3.1.2 - Use one of the following digestion methods as applicable for all elements:
AOAC Official Method 974.02, Lead in Paint

EPA Method 3051A, Microwave Assisted Digestion of Sediments, Sludge, Soils, and Oils
EPA Method 3052, Microwave Assisted Digestion of Siliceous and Organically Based Matrices
CPSC-CH-E1003-09.1, Standard Operating Procedure for Determining Lead (Pb) in Paint and Other
Similar Surface Coatings
CPSC-CH-E1002-08, Standard Procedure for Determining Total Lead (Pb) in Non-Metal Children’s
Products
CPSC-CH-E1001-08, Standard Procedure for Determining Total Lead (Pb) in Children’s Metal Products

(Including Children’s Metal Jewelry)
3.4.3.1.3 - Use one of the following methods as applicable for RoHS Hexavalent Chromium (CrVI) :
Laboratories may use the results from the total test on Cr to satisfy Cr VI requirement. If total Cr result
is < 1000 ppm, the following Cr VI test is not required.
ISO 3613, Chromate Conversion Coatings on Zinc, Cadmium, Aluminum-zinc Alloys, Zinc-aluminum –
Test Methods or equivalent.
EPA Test Method 3060, Alkaline Digestion for Hexavalent Chromium or equivalent.
3.4.3.1.4 - Variations of these extraction and analysis methods and/or use of an alternate method are
acceptable if, in the expert opinion of the test laboratory, they are declared to be equivalent or better. Analyze
the digestion utilizing any suitable method based on the equipment used (AA or ICP) and the element content
to be determined.
3.4.3.1.5 - Follow Appendix II if sufficient sample to conduct the testing cannot be collected from 12 units.
3.4.3.2.1 - Follow the latest revision ASTM F963 and EN 71-3 for soluble method 1
3.4.3.2.2 - Analyze the solution for heavy elements content using either atomic absorption spectroscopy (AA)
or inductively coupled plasma spectrometry (ICP).
3.4.3.2.3 - The test method on Chromium VI and organic tin (GC-MS) has not determined yet.
3.4.3.3.1 - Test and evaluate for soluble cadmium, barium, antimony, selenium and Arsenic per the latest
revision of Health Canada Book 5 Laboratory Policies and Procedures, Part B, test method “C03-1,
Determination of Leachable Cadmium, Barium, Antimony, Selenium and Arsenic in Applied Coatings”.
3.4.3.3.2 - Follow Appendix II, if sufficient sample to conduct the testing cannot be collected from 12 samples
4 - DOCUMENT HISTORY AND SUPPORTING INFORMATION
4.1 - Significance
Compliance can be assured by using a testing and compliance system that will reduce the risk of finished products
having an excessive amount of heavy elements.
Total Lead testing is required per CFR 1303 and the Consumer Product Safety Improvement Act of 2008 and per
Amendment part II of Schedule I to Canadian Hazardous products Act (Consumer Products Containing Lead –
Contact with Mouth).
Soluble test method 1 is required per ASTM F963-17, EN 71-3-2013, ISO 8124-3, Mexico’s NOM’s, and India’s IS
9873-3.
Soluble test method 2 is required per Canada’s Hazardous Products Act (HPA). The HPA specifies that the test
sample must be stirred in 5% hydrochloric acid for ten minutes at 20°C. A detailed methodology has been supplied
by Health Canada (C03-1, Determination of Leachable Cadmium, Barium, Antimony, Selenium and Arsenic in
Applied Coatings).
Total Cadmium testing is based on European Regulation (EC) No 1907/2006 Restriction, Evaluation, Authorization,
and Restriction of Chemicals (REACH) and Danish Ordinance prohibiting the importation, sale and manufacture of
cadmium containing products (BEK nr 858 of 05 Sept 2009).
The total mercury testing is also required per Canada?s Hazardous Products Act. The Canadian HPA does not
allow mercury to be intentionally added to the surface coating materials (SCM). A test result of ?10 mg/kg (ppm)

total mercury is considered the most reliable way to determine that no mercury has been introduced. No testing
methodology is specified in the HPA.
§2.4 is is required per the Restriction of Hazardous Substances Directive (RoHS). RoHS is an EU directive which
requires electrical and electronic products to meet specific chemical limits and required by California's RoHS as
well. QSOP 3614, Flame Retardants also contain requirements that pertain to RoHS covering PBB and PBDE flame
retardants in electrical and electronic products.
§2.3.1.1 is to reflect the different requirements on surface coating on paper and paper board from EN 71-3 and
ASTM F963.
4.2 - Reason For Revision (3600)
Section Revision11.00 Implementation
Applied to all products manufactured on and after: Aug

1.2.3 Revised to align with the update
21, 2021
Adjusted the sequence of two sections for surface Applied to all products manufactured on and after: Aug
2.3.1
coatings to accommodate LIMS 21, 2021
2.3.2/2.3.3 Removed the requirement on the inaccessible parts Applied to all products manufactured on and after:
/2.3.4/2.3.5 contained in accessible small parts Aug 21, 2021
Revised the requirement for small parts to align with Applied to all products manufactured on and after:
2.3.2.2
ASTM/EN/ISO standards Aug 21, 2021
Revised the Q/A for electroplating to align with the

5.1 Editorial
practice
Applied to all products manufactured on and after:

5.6 Added a Q/A for stainless steel application
Releasing date
Section Revision 10.00 Implementation
2.3.1.1 Revised the requirements for surface coating on paper Applied to all products manufactured on and after: May
and paper board 20, 2020
Table 4 Added the table with the requirements for surface Applied to all products manufactured on and after: May
coating on paper and paper board 20, 2020
2.3.3 Added printed paper and paper board into this group Applied to all products manufactured on and after: May
20, 2020
Section Revision 9.00 Implementation
Table 4, 6, 7, 8, 9 Updated the requirement limit of Aluminum per EU Applied to all products manufactured on and after: May
Directive 2019/1922. 20, 2020
4.3 - Referenced Documents
The following link contains the source documents and requirements related to this procedure:
Detailed Procedure to Source Document Report

4.4 - Identification of Mattel Internal Requirements
Mattel internal requirements are requirements developed internally to minimize the potential for injuries to children
but are not required by law.
4.4.1 - All requirements in this QSOP are based on regulations. This QSOP contains no Mattel internal

requirements.
5 - FREQUENTLY ASKED QUESTIONS
5.1 - Question 1
Question: Should electroplating be tested as a surface coating or a substrate?
Answer: The process of electroplating deposits a layer of material that adheres to the substrate., it is not considered
to be a surface coating and therefore must be tested as a substrate
5.2 - Question 2
Question: Should a label be tested as a surface coating or a substrate?
Answer: Labels are not considered surface coatings because they do not meet the definition of a surface coating in
16 CFR 1303. However, labels may contain surface coatings which should be tested accordingly. If the surface
coating on a label is made inaccessible by way of a permanent seal, such as lamination, then the coating would no
longer be considered a surface coating—the label should be tested as a substrate. The base material of the label
should be tested according to the appropriate section for substrates.
5.3 - Question 3
Question: When testing the inaccessible parts of an electronic product for compliance, is it acceptable to only test
the parts of the product that carry current?
Answer: All inaccessible parts of an electronic product must comply with the applicable limits described in §2.4,
Additional Requirement for Electrical and Electronic Products. This includes not only current carrying components,
but also non-current carrying components such as the inaccessible parts of the plastic housing of the product.
5.4 - Question 4
Question: After screening procedure, if GC-MS testing is triggered, which organic tins shall be tested?
Answer: Methyl tin (MeT), Di-methyl tin(DMT), Di-n-propyl tin(DproT), n-Octyl tin(MOT), Dibutyl tin(DBT), Di-n-octyl
tin(DOT), Diphenyl tin(DphT), Tributyltin(TBT), Triphenyl tin(TphT),Tetrabutyl tin(TeBT), Butyl tin(BuT)
5.5 - Question 5
Question: What kinds of Nickel plated axles are exempt from total nickel requirement?
Answer: Nickel plated axles on toys suitable for > 3 years old where the only accessible portion is the part that
protrudes from the center of the wheel and the diameter of this part is ≤ 2.0 mm are exempt as shown in Figure 1.
Axles with other accessible portion not shown in Figure 1 or the diameter of this accessible portion > 2.0 mm must
comply with the total nickel requirement.
5.6 - Question 6
Question: Stainless steel contains high Chromium content (e.g.: SUS304 contains 18-20% Cr), What shall we do
when stainless steel is used as a small part in toys?
Answer: It is recommended to use low carbon steel with other electroplating as a substitution when stainless steel is
designed in a small part. As stainless steel contains high content of of Cr, it may fail the small part soluble Cr test.
6 - ATTACHMENTS
6.1 - APPENDICES
Appendix I - Total Method Results to Satisfy Soluble Method Requirements

Appendix II - Heavy Element Sample Requirements for Surface Coatings
Appendix III - Exemptions from the Total Method Lead (Pb) Requirements of §2.3.2 and §2.3.3
Appendix IV - Categories of Common Toy Materials
Appendix V - Exemptions for §2.4
Appendix I - Total Method Results to Satisfy Soluble Method Requirement

Example 1: Antimony Result in Surface Coating
Total Result Soluble Antimony Method 1 Soluble Antimony Method 2
Antimony (ppm) limit: 60 ppm limit: 1000 ppm
Less than soluble limit; do not
40 Less than soluble limit; do not test
test
Less than soluble limit; do not
65 Exceeds soluble limit; test
test
1200 Exceeds soluble limit; test Exceeds soluble limit; test
Example 2: Barium Result in Surface Coating

Total Result Soluble Barium Method 1 Soluble Barium Method 2 limit:
Barium (ppm) limit: 1000 ppm 1000 ppm
40 ≤ 500 ppm; do not test ≤ 500 ppm; do not test
250 ≤ 500 ppm; do not test ≤ 500 ppm; do not test
750 Exceeds 500 ppm; test Exceeds 500 ppm; test
1200 Exceeds 500 ppm; test Exceeds 500 ppm; test
Example 3: Lead Result in Surface Coating

Total Result Lead Soluble Lead Method 1
(ppm) limit: 90 ppm
30 Less than soluble limit; do not test
Exceeds total limit; sample fails,

100
no further testing
Appendix II - Heavy Elements Sample Size Requirements

Considerations:
Applicable for finished goods testing (Reference GQMP 2112, Surface Coating Material Control and GQMP
2113, Heavy Elements Control on Surface Coatings for Vendors).
Applicable for surface coatings and substrates
Limit of 12 units applies to initial testing for Total digestion if ≥10 mg individual color is obtained from12 units
maximum
If the results indicate that Soluble 1 and/or Soluble 2 testing is required, then additional samples should
be used to perform those tests (1 sample for Soluble 1 testing and a maximum of 12 units to perform
soluble 2 testing).
If all three tests are needed, a maximum of 25 units should be used: twelve (12) for Totals, one (1) for
Soluble 1, and twelve (12) for Soluble 2.
Composite testing should not be used when performing Soluble 1 or Soluble 2 testing.
Limit of 200 units applies to the initial testing for total digestions if ≥10 mg individual color is not obtained from
12 units maximum following the above flow chart. When less than 10mg of individual color is obtained from
200 units combine this color with another similar material to obtain 10mg of total sample weight. Calculate the
concentration using the sample weight of the combined sample.
Any facility that manufactures products that Mattel sells as finished goods to a wholesale or retail customer is
considered a vendor. Vendor is also known as Mattel Original Equipment Manufacturer (Mattel OEM). There
are 2 Vendor categories

Major Vendor: A manufacturer that has demonstrated acceptable finished goods manufacturing
capabilities to supply Mattel’s on-going needs, and who typically produces a significant quantity of
Mattel product.
Specialty Vendor: A manufacturer that fulfills unique finished goods needs, and that typically produces a
small quantity of Mattel product with infrequent production runs.
Appendix III - Exemptions from the Total Lead (Pb) Requirements of §2.3.2 and §2.3.3
The following materials, when untreated or unadulterated by the addition of materials or chemicals and which has
not undergone any processing which could introduce lead are considered exempt from Total Method lead (Pb)
testing:
Precious gemstones: diamond, ruby, sapphire, emerald.

Semiprecious gemstones and other minerals, provided that the mineral or material is not based on lead or
lead compounds and is not associated in nature with any mineral based on lead or lead compounds
(excluding any mineral that is based on lead or lead compounds including, but not limited to, the following:
aragonite, bayldonite, boleite, cerussite, crocoite, galena, linarite, mimetite, phosgenite, vanadinite, and
wulfenite).
Natural or cultured pearls.
Wood.
Paper and similar materials made from wood or other cellulosic fiber, including, but not limited to, paperboard,
linerboard and medium, and coatings on such paper which become part of the substrate.
CMYK process printing inks (excluding spot colors, other inks that are not used in CMYK process, inks that do
not become part of the substrate under 16 CFR part 1303, and inks used in after-treatment applications,
including screen prints, transfers, decals, or other prints).
Textiles (excluding after-treatment applications, including screen prints, transfers, decals, or other prints)
consisting of:
Natural fibers (dyed or undyed) including, but not limited to, cotton, kapok, flax, linen, jute, ramie, hemp,
kenaf, bamboo, coir, sisal, silk, wool (sheep), alpaca, llama, goat (mohair, cashmere), rabbit (angora),
camel, horse, yak, vicuna, qiviut, guanaco;
Manufactured fibers (dyed or undyed) including, but not limited to, rayon, azlon, lyocell, acetate,
triacetate, rubber, polyester, olefin, nylon, acrylic, modacrylic, aramid, spandex.
Other plant-derived and animal-derived materials including, but not limited to, animal glue, bee's wax, seeds,
nut shells, flowers, bone, sea shell, coral, amber, feathers, fur, leather.
Surgical steel and other stainless steel within the designations of Unified Numbering System, UNS
S13800–S66286, not including the stainless steel designated as 303Pb (UNS S30360).
Precious metals: Gold (at least 10 karat); sterling silver (at least 925/1000); platinum; palladium; rhodium;
osmium; iridium; ruthenium, titanium
Exemptions for total lead as used in certain electronic components parts in children's electronic devices
include:
(1) Lead blended into the glass of cathode ray tubes, electronic components, and fluorescent tubes.
(2) Lead used as an alloying element in steel. The maximum amount of lead shall be less than 0.35% by weight
(3,500 ppm).
(3) Lead used in the manufacture of aluminum. The maximum amount of lead shall be less than 0.4% by weight
(4,000 ppm).
(4) Lead used in copper-based alloys. The maximum amount of lead shall be less than 4% by weight (40,000 ppm).
(5) Lead used in lead-bronze bearing shells and bushings.
(6) Lead used in compliant pin connector systems.
(7) Lead used in optical and filter glass.
(8) Lead oxide in plasma display panels (PDP) and surface conduction electron emitter displays (SED) used in
structural elements; notably in the front and rear glass dielectric layer, the bus electrode, the black stripe, the
address electrode, the barrier ribs, the seal frit and frit ring, as well as in print pastes.
(9) Lead oxide in the glass envelope of Black Light Blue (BLB) lamps
Appendix IV - Categories of Various Toy Materials - Cross-Reference Table for Determining Category
Dry, brittle,
Liquid or
power-like or Scrapped off
Toy Material sticky toy
pliable toy toy materials
materials
materials
Coatings of paints, varnishes, lacquers, printing X

inks, polymers, foams and similar coatings
Polymeric and similar materials, including X

laminates, whether textile reinforced or not, but excluding other textiles
Paper and paper board X
Textiles, whether natural or synthetic X
Glass, ceramic, metallic materials X
Other materials whether mass coloured or not

X
(e.g. wood, fibre board, hard board, bone and leather)
Compressed paint tablets, materials intended to

leave a trace or similar materials in solid form appearing as such in the X
toy (e.g. the cores of colouring pencils, chalk, crayons)
Pliable modelling materials, including modelling X

clays and plaster
Liquid paints, including finger paints, varnishes,

X
lacquers, liquid ink in pens and similar materials in liquid form appearing
as such in the toy (e.g. glue sticks, slimes, bubble solution)
Appendix V - Exemptions to §2.4
EXEMPTIONS
GUIDANCE
Battery Cells are exempt; however, any wires connected to batteries

are not exempt and any materials used to wrap batteries are not
exempt (e.g., wires and wrapping materials used in battery packs.
Batteries must be tested per QSOP 3274, Batteries and Battery

Operated Products.

1 Battery cells
A compact fluorescent lamp (CFL) is usually defined as a

single-ended fluorescent lamp with a bent discharge tube of
Mercury in
small diameter, of around 10-16 mm, to form a very
compact
compact unit. These lamps can be either integral, whereby
2 fluorescent lamps
the lamp and ballast are combined (also known as self-
not exceeding 5
ballasted or self-supporting), or pin-based.
mg per lamp.
For the purpose of this exemption, CFLs can contain no
more than 5 mg of mercury per lamp.
Mercury in straight
fluorescent lamps for
general purposes not
exceeding: A straight, or linear, fluorescent lamp is a fluorescent lamp
of straight tubular form and bi-pin electrical connections at
10 mg in
either end.
halophosphate
lampls The color properties of straight fluorescent lamps are
5 mg in determined by the phosphors used to coat the inside of the
3
triphosphate tube. Halophospate and triphospate are examples of such
lamps with a fluorescent materials.
normal
Straight fluorescent lamps for general purpose can be defined as
lifetime.
lamps used for general lighting solutions, in contrast to lamps used
8 mg in
for special purposes (see item 4 below).
triphosphate
lamps with a
long lifetime.
Examples of such lamps are LCD back light lamps,

disinfection lamps, medical/therapy lamps, pet care lamps
(e.g. aquaria lamps), lamps with special components (e.g.
integrated reflectors or external protection sleeves), lamps
Mercury in straight
with special ignition features (e.g. designed for low
4 fluorescent lamps for
temperatures), long length lamps (length > 1800 mm) and
special purposes.
amalgam lamps.
In this context, there is no restriction on the quantity of

mercury in these lamps.

Examples of other lamps containing mercury are high intensity
Mercury in other discharge (HID) lamps (e.g. sodium lamps and metal halide lamps),
lamps not specifically circular fluorescent lamps and U-shaped fluorescent lamps.
5
mentioned in this
Appendix. In this context, there is no restriction on the quantity of mercury in
these lamps.
Lead, or more specifically lead oxide, is often used in glass for

electrical and electronic equipment to obtain specific characteristics,
such as radiation protection (CRTs, medical applications), filtering
(photography, image processing) and strengthening purposes (e.g.
Lead in glass of
production of fluorescent tubes). This exemption has been introduced
cathode ray tubes,
because viable alternatives for these applications have not yet been
6 electronic
identified.
components and
fluorescent tubes.
For clarity, the exemption applies to lead as a constituent in the glass
used in cathode ray tubes, lead as a constituent in the glass used in
electronic components and lead as a constituent in the glass used in
fluorescent tubes.
Lead as an alloying
element in steel Lead is often used as an alloying element to obtain specific properties
containing up to 0.35 of a metal alloy. This exemption applies to the use of lead in steel up
% lead by weight, to 0.35% by weight, in aluminum up to 0.4% by weight and in copper
aluminum containing alloys up to 4% by weight. In the context of this exemption,
7
up to 0.4 % lead by “percentage by weight” has to be interpreted as “the percentage of
weight and as a lead per homogeneous material per discreet part”. For example, if the
copper alloy steel housing of a computer consists of two separate parts, each part
containing up to 4% can contain up to 0.35% lead by weight of that part.
lead by weight.
For the purposes of applications 8, 9 and 10 in this Appe/ndix, it is

useful to clarify the term “solder”. In this appendix, “solder” is defined
as “alloys used to create metallurgical bonds between two or more
metal surfaces to achieve an electrical and/or physical connection”. In
this context, the term “solder” also includes all materials that become
part of the final solder joint, including solder finishes on components
or printed circuit boards.
Lead in high melting
temperature type
The high melting temperature type solder exemption has been
solders (i.e. lead
introduced to allow the use of lead in solders for specific applications
8 based alloys
(such as in power semiconductor package manufacturing), for which
containing more than
viable lead-free alternatives have not yet been identified. This
85% by weight or
exemption is permitted as there are no alternative alloys with similar
more lead).
melting point and which are ductile. The high electrical conductivity
and unique mechanical properties of such a high melting point tin-
lead alloy make the material malleable and better able to withstand
both temperature and physical stress. Such properties ensure fewer
defects during manufacturing and high reliability throughout the life of
the component, thereby also resulting in fewer components going into
the waste stream.
See definition of “solder” given for application 8 above.

This exemption has been introduced to allow the use of lead in
solders for professional, high reliability applications, such as servers
and network infrastructure equipment, for which viable lead-free
alternatives have not yet been identified.
In this context, a “server” is seen as a computer that meets one of the

technology criteria that are set out in section (a) below, and the
functional criteria set out in section (b) below.
(a) Technology criteria for a server
1) Designed and placed on the market as a Class A product as per
EN55022:1994 under the EMC Directive 89/336/EEC (intended
primarily for use in the professional environment) and designed and
capable of having a single or dual processor capability (one or more
sockets on board); or
2) Designed and placed on the market as a Class B product
(intended primarily for use in the domestic environment) as per
EN55022:1994 under the EMC Directive 89/336/EEC and designed
and capable of having at least dual processor capability (two sockets
on board).
(b) Functional design criteria for a server

1) Designed and capable of operating in a mission-critical, high-
reliability, high-availability application in which use may be 24 hours
per day and 7 days per week, and unscheduled downtime is
extremely low (minutes per year).
Examples of typical server functions are the provision of network

infrastructure, gateway or switching services, the hosting and
management of data on behalf of multiple users, or the running of
server-capable operating systems (e.g. as for a web server).
It is the view of the UK’s Department for Business Innovation and

Skills (BIS) that this exemption is viewed as applying to lead in the
solder of the whole of the computer and its components including
processors, memory boards, power converters, power supplies,
enclosed housings, modular power subsystems and adapter cards. It
would also seem to apply to the lead in the solder of the components
that are integrated into the whole computer or that are sold separately
for use in an exempt server. The lead in the solder of cable
assemblies, and all connectors and connector assemblies used to
provide interconnections for the server, would also be covered by this
Lead in solders for
exemption.
servers, storage and
storage array
It should be noted that this exemption is not viewed as applying to
systems, network
parts or components that are peripheral to the server, nor does it
infrastructure
apply to parts or components when they are used other than in an
9 equipment for
exempt server.
switching, signaling,
For the purpose of the RoHS Regulations, a “storage or storage array
transmission as well
system” is viewed as any storage device or subsystem that meets
as network
one of the following criteria:
management for
1) Designed and placed on the market as a Class A product as per
telecommunication,
EN55022:1994 under the EMC Directive 89/336/EEC; or

2) Designed and placed on the market as a Class B product as per
EN55022:1994 under the EMC Directive 89/336/EEC and designed
to meet one of the following two criteria: -
a) Any storage device capable of accepting direct or switched input
from more than one computer, for example fibre channel and SCSI
devices, or
b) Any storage fabric or switching device for interconnecting storage
devices to server products.
It is the view of BIS that this exemption is viewed as applying to the
whole of the device or subsystem and their components including
processors, memory boards, power converters, power supplies,
enclosed housings, modular power subsystems and adapter cards. It
would also seem to apply to the components that are integrated into
the whole storage or storage array system or that are sold separately
for use in an exempt storage or storage array system. Cables and
cable assemblies, and all connectors and connector assemblies used
to provide interconnections for the storage or storage array system,
would also be covered by this exemption.
It should be noted that this exemption does not apply to parts or

components that are peripheral to the storage or storage array
system, nor does it apply to parts or components when they are used
other than in an exempt storage or storage array system.
For the purpose of the RoHS Regulations, “network infrastructure

equipment for telecommunication purposes” is viewed by BIS as
equipment meeting one of the two following criteria:
1) Any system used for routing, switching, signalling, transmission, or
network management or network security; or
2) Any system which can simultaneously enable more than one end
user terminating equipment to connect to a network.
It is also any such system in a network, except for end user
terminating equipment such as voice terminals and facsimile
machines.
This would include all servers, power suppliers, display devices and
similar electronic units that are incorporated into network
infrastructure equipment. It would also include all cables and cable
assemblies, and all connectors and connector assemblies used to
provide interconnections for network infrastructure equipment but is
not intended to include desktop or notebook computers, telephones,
fax machines or consumer – type modems or switches etc.
Ceramic materials are used in a variety of electronic devices

including capacitors, insulators, piezoelectrics, magnets and
integrated circuit packages. Some of these ceramic materials contain
Lead in electronic lead, for example lead zirconate titanate and lead magnesium
ceramic parts (e.g. niobate. The specific chemical composition and manufacturing
10
piezoelectronic process of these materials determine their electrical parameters, such
devices). as dielectric constant and the dissipation that is essential for the
functioning of the component in which they are used. Hence, lead
used in the ceramic parts of electronic components in electrical and
electronic equipment is exempt from these Regulations.

Cadmium and its Directive 91/338/EEC amending Directive 76/769/EEC relating to
compoints in electrical restrictions on the marketing and use of certain dangerous
contacts and substances and preparations, gives the following definition of
cadmium plating cadmium plating: “Within the meaning of this Directive, ‘cadmium
except for applications plating’ means any deposit or coating of metallic cadmium on a
banned under metallic surface.” This definition is seen as applying for the purpose
Directive 91/338/EEC of the RoHS Regulations.
(OJ No. L 186, 12 July

Subsequently, the Marketing and Use Directive (as amended) bans
1991, p. 59)
11 the use of cadmium plating in a variety of product sectors.
amending Directive
76/769/EEC (OJ No. As a result, in this context cadmium plating is viewed as being
L262, 27 September permitted for electrical contacts in all the WEEE categories to which
1976, p. 201) relating the RoHS Regulations apply except for products manufactured in the
to restrictions on the household goods and central heating and air conditioning plant
marketing and use of sectors because the latter are restricted by the Marketing & Use
certain dangerous Directive. However, that Directive does allow the use of cadmium
substances and plating for “electrical contacts in any sector of use, on account of the
preparations. reliability required of the apparatus on which they are installed.”
As absorption cooling works on several different types of energy

sources such as gas, kerosene, batteries or electricity, absorption
fridges are often used in recreational vehicles (e.g. motor homes and
Hexavalent chromium
caravans) or remote places where electricity is not available. Another
as an anti-corrosion of
typical application is for minibars in hotel rooms as these fridges are
the carbon steel
12 virtually noiseless.
cooling system in
absorption
The applied heat and use of a water-ammonia mixture results in a
refrigerators.
corrosive environment that warrants the use of hexavalent chromium.
This exemption has been introduced, since viable alternatives for this
specific application have so far not been identified.
Lead-bronze bearing shells and bushes are used, amongst others, in

compressors for stationary refrigeration and air conditioning
equipment. Typical characteristics of such compressors include a
long design life (over 50,000 hours for residential applications and
over 100,000 for commercial applications) and a hermetic sealing to
prevent refrigerant leakage and ensure reliable, uninterrupted
Lead in lead-bronze operation without service for up to 15 years. Combined with the
13 bearing shells and unique technical aspects of the refrigeration cycle (dry-starts,
bushes. miscibility of the lubricant, repeated condensing and boiling, etc.), the
bearings need excellent self-lubrication properties to meet the high
durability and reliability requirements. Due to its lubricious nature, the
use of lead as a bearing constituent is critical in these applications.
This exemption has been introduced because so far no suitable
alternative has been identified, although other materials have been
extensively tested.
Compliant pin contacts are used to attach connectors or components

to a double-sided printed circuit board. This connector system avoids
the need for soldering during manufacturing, thereby avoiding the
overheating of components and damaging the integrity of the

Lead used in connectors and board material and allows separation for repair. Such
14 compliant pin pins are coated with a tin-lead alloy to ensure good electrical
connector systems. conductivity, maintain sufficient spring-back force and facilitate
insertion of the pins into the boards. The use of tin-lead also reduces
the risk of tin whiskers, which may affect reliability.
This exemption has been introduced because suitable alternatives to
the tin-lead alloy have not yet been identified.
A thermal conduction module c-ring serves a specific purpose in the

manufacturing of high performance electronic modules. Such
modules are the key components of a mainframe central processing
Lead as a coating
unit and typically contain multiple chips. The c-ring functions as a
material for the
15 hermetical seal, continuously dissipating heat and preventing
thermal conduction
oxidation of solder joints.
module c-ring.
While substitutes for lead in this application have been investigated,

no feasible alternative has so far been identified.
Lead and cadmium are used in optical glass and filter glass to obtain
specific properties and meet quality standards, for a wide variety of
applications including in the photo industry (e.g. camera lenses), in
Lead and cadmium in
16 projectors, scanners, printers and copiers.
optical and filter glass.
This exemption has been introduced because suitable alternatives for

many of these applications have not yet been identified.
Microprocessors are mounted onto boards or substrates by way of a

socket. Such sockets require that a large number of pins (up to 950)
are mounted onto the microprocessor for completing the necessary
Lead in solders
electrical connections. The high customer quality demands for these
consisting of more
products mean that such packages are extensively tested, which
than two elements for
necessitates high adhesion strength of the pins. This is even more
the connection
critical at higher pin counts and the application of lead in the
between the pins and
17 proportions specified in this exemption is essential to achieve the
the package of
necessary properties.
microprocessors with
a lead content of more
Substitute materials without lead are used by some manufacturers
than 80% and less
but for high pin counts, the development of alternatives before July 1,
than 85% by weight.
2006 would create significant quantities of waste. This exemption has
been introduced to allow for the development of alternative designs
without generating excessive amounts of waste.
Flip chips are attached to their packages or PCBs using very small
solder bumps and many types use solder bumps containing lead.
Lead is used for two main reasons. Its ductility reduces the risk of
damage to brittle parts of flip chip circuitry. Lead also protects against
Lead in solders to
the possibility of thermal fatigue, which results from cyclic
complete a viable
temperature changes and is not well understood with lead-free
electrical connection
solders. High melting point solder bumps are attached using solder
between
18 containing typically 37% – 40% lead to the package because this
semiconductor die
combination has a high resistance to a phenomenon called
and carrier within
“electromigration” which in higher power flip chip packages would
integrated circuit Flip
otherwise cause premature failure of the device. The solder
Chip packages

connections to the chip are known as level 1 and level 1 flip-chip
connections may contain lead. The external solder connections
between packages and PCB known as level 2 are excluded from this
exemption as viable alternatives have been developed.
An incandescent lamp generates light using a glowing filament

heated to white-hot by an electrical current. This light-giving process
is known as incandescence.
Lead in linear
A linear incandescent lamp is a tubular filament lamp with pin
incandescent lamps
19 connectors at either end. The glass is coated on the inside with
with silicate coated
silicate that contains lead. The lead assists in binding the silicate to
tubes.
the glass.
In this context there is no restriction on the use of lead in these

lamps.
High Intensity Discharge (HID) lamps produce light by striking an

electrical arc across tungsten electrodes housed inside a specially
designed inner fused quartz or fused alumina tube. This tube is filled
Lead halide as radiant with both gas and metals. The gas aids in the starting of the lamps
agent in High Intensity and the metals produce the light once they are heated to a point of
Discharge (HID) evaporation.
20 lamps used for

Certain HID lamp types contain lead-iodide (PbI2) as a component in
professional
the filling. These lamps are used in professional U.V. applications: the
reprography
curing, reprography and label printing industries. The lead is used for
applications.
creating the correct lamp emission spectrum and lamp effectiveness.
In this context there is no restriction on the use of lead halide as a

radiant agent in these lamps.
Lead as activator in Discharge lamps work by sending an electric current through a

the fluorescent special gas. Depending on the gas, this either generates light directly
powder (1% lead by or the current generates ultra-violet light, which is converted to visible
weight or less) of light by fluorescent powders.
discharge lamps when
Lead is used as an activator in fluorescent powders for two classes of
used as sun tanning
special fluorescent lamp products: -
lamps containing
1. Sun tanning lamps contain phosphors such as BSP (BaSi 2 O5 :Pb),
phosphors such as
with an emission peak of 350 nm; and
BSP (BaSi2O5:Pb) as
2. Certain specialty lamps (applications: diazo-printing reprography,
21 well as when used as
lithography, insect traps, photochemical and curing processes)
specialty lamps for
contain the phosphors such as SMS ((Sr,Ba)2 MgSi2 O7 :Pb),
diazo-printing
generating a broad emission peak centered at 360 nm.
reprography,
lithography, insect
The presence of lead creates the proper lamp emission spectrum and
traps, photochemical
optimum lamp effectiveness.
and curing processes
containing phosphors This exemption applies to the use of lead as an activator in the
such as SMS ((Sr, fluorescent powder of discharge lamps used in the above applications
Ba)2MgSi2O7:Pb). up to 1% by weight.
There are two main parts to a compact fluorescent lamp (CFL): the
gas-filled tube and the magnetic or electronic ballast. Electrical

energy from the ballast flows through the gas in the tube causing it to
give off ultraviolet light. The ultraviolet light excites a white phosphor
coating on the inside of the tube. This coating then emits a visible
Lead with PbBiSn-Hg
light, which is the final product of the CFL.
and PbInSn-Hg in
specific compositions Very compact Energy Saving Lamps (ESL) with PbBiSn-Hg and
as main amalgam and PbInSn-Hg in specific compositions as main amalgam and PbSn-Hg
22
with PbSn-Hg as as auxiliary amalgam
auxiliary amalgam in
The substances (both main & auxiliary amalgams) control the Hg-
very compact Energy
vapour pressure inside small CFLs, stabilizing the light output and
Saving Lamps (ESL).
lamp effectiveness over a wide temperature range. This makes it
possible to replace incandescent lamps by CFLs in a wide range of
applications, both indoor and outdoor.
In this context there is no restriction on the use of lead in the form of
an amalgam or auxiliary amalgam in these lamps.
Lead is currently used in the glass panel of Liquid Crystal Display

(LCD) screens. Two glass substrates are bonded with high precision
by inserting glass spacers in between, to keep the same gap. Lead is
Lead oxide in glass
used there to prevent overheating of the glass, which would result in
used for bonding front
image distortion and malfunction. It is found in the form of a solder
and rear substrates of
23 with a concentration of 70% lead by weight, used to create a safe
flat fluorescent lamps
electrical contact on the plane glass surface. Lead containing glass
used for Liquid Crystal
solder is also used to assemble the flat-panel glass envelope.
Displays (LCD)

an oxide in the glass.
Borosilicate glass items are printed with scales and warnings in order
to improve usability and ensure consumer safety. These markings
must be permanently readable.
The printing on the glass uses an ink, which is fired and melts
Lead and cadmium in
together with the glass surface, and contains significant amounts of
printing inks for the
24 lead oxide (37%-48% by weight) and cadmium oxide (11% by
application of enamels
weight). Applications using this process to print onto borosilicate
on borosilicate glass.
glass include: coffee jugs; water boilers; electric water kettles; lamp
covers; laser tubes; ozone tubes; and medical devices.
In this context, there is no restriction on the use of lead and cadmium

in the printing inks.
The electrical terminations of virtually all electronic components

(integrated circuits, memory “chips,” diodes, resistors for example)
must be plated with a thin layer of metal to make them capable of
being soldered to the printed circuit board. Today, these terminal
platings are most commonly comprised of a tin-lead (Sn-Pb) alloy.
One of the main reasons lead is included in the plating is to mitigate

the formation and growth of tin “whiskers”. Tin whiskers are
electrically conductive, crystalline structures of tin that sometimes
grow from surfaces where tin (especially electroplated tin) is used as
a final finish.

Lead in finishes of fine
pitch components Tin whiskers have been observed to grow to lengths of several
other than connectors millimeters (mm) and in rare instances to lengths up to 10 mm.
with a pitch of 0.65 Numerous electronic system failures have been attributed to short
mm or less with NiFe circuits caused by tin whiskers that bridge closely-spaced circuit
lead frames and lead elements maintained at different electrical potentials.
25
in finishes of fine pitch Lead is used as a whisker suppresser in electroplated Sn coating.
components other The concentration of Pb in the plating alloy is typically below 20%,
than connectors with and the thickness of the plating is only about 10 micrometers.
a pitch of 0.65 mm or
These tin whiskers can cause functional failure of electronic products
less with copper lead
once they grow long enough to create short circuits between adjacent
frames.
electrical terminations. Fine-pitch parts are the most susceptible to
such failures because the distance between the conductive leads is
small. Modern electronic equipment requires the use of such fine-
pitch parts to meet the computation speed and/or small size
requirements of the market.
For the purpose of this exemption, fine-pitch components are defined

as those with electrical terminations spaced with centers 0.65 mm or
less apart. In such parts, the distance between adjacent leads is
considerably smaller than the centre-to-centre spacing, and is
typically 125 to 300 micrometers.
RFI signal line filters are manufactured by soldering axial leads into
machined ceramic multi layer through hole devices (discoidal
capacitors or planar arrays) and mounting into metal bodies or
connector shells.
Lead in solders for the Due to the novel construction of the capacitor, it is necessary to use
soldering to machined ductile solders to make these solder joints so as to prevent the
through hole discoidal ceramic cracking as a result of tensile stresses generated during the
26
and planar array cooling of the assembly.
ceramic multilayer
capacitors. The solders used contain lead along with other alloys (primarily
indium) to maintain the ductility required. These solders are typically
50% lead and 50% indium.

lead in solders for these components.
Lead oxide in plasma

display panels (PDP) The front substrate consists of the bus electrode and the dielectric
and surface layer for the protection of the bus electrodes. The rear substrate
conduction electron consists of the address electrode, the dielectric layer, the barrier rib
emitter displays (SED) and fluorescent material. By sealing the front and rear substrates
used in structural together, a gas (usually Ne-Xe) is injected into the panel. PDPs emit
elements; notably in light by producing an ultraviolet ray that excites the fluorescent
27 the front and rear material. The main substance of PDP material consists of PbO, SiO2,
glass dielectric layer, B-2 O3, Al2O3, CaO, TiO2, ZnO, etc.
the bus electrode, the

PbO renders the melting point lower with its presence in the paste
black stripe, the
and tends to optimize the sintering characteristics of the material.
address electrode, the

barrier ribs, the seal In this context there is no restriction on the use of lead in the form of
frit and frit ring as well PbO in these components.
as in print pastes
Black light (also Wood's light) is the common name for a lamp
emitting electromagnetic radiation that is almost exclusively in the soft
near ultraviolet range, and very little visible light.
BLB lamps produce black light that peaks in the soft ultraviolet at a
wavelength of 365 nm, with almost no light in the visible spectrum;
they appear deep purple violet to the human eye when operating, and
black when turned off. These lamps are used to excite UV-sensitive
Lead oxide in the
paints and dyes and for other purposes, especially in special effects,
glass envelope of
28 security applications, and medicine.
Black Light Blue
(BLB) lamps. The amount of PbO in the glass envelope is typically 20 wt%, = 18
wt% Pb.
The lead in the form of PbO is essential for creating the proper lamp
emission: optimal optical properties: maximum transmission of UV
light, and minimum visible light transmission.

PbO in these components.
The use of lead in glass leads to a high refractive index (brilliancy), a

strong dispersion and a high transmission of the light. Additionally,
the use of lead in glass introduces further favorable thermal and
mechanical properties in melting, forming, cutting and in post-
processing.
In electric and electronic equipment this form of glass is used in pure

(colorless) or colored form for decorative and/or functional purposes,
such as lamps, chandeliers, decoration of mobile phone covers,
clocks and watches.
Lead bound in crystal
29
glass. According to Council Directive 69/493/EEC, full lead crystal consists
at least of 28% lead calculated as lead oxide (therefore >30% lead
oxide).
Lead is bonded in the silicate matrix of glass and therefore

immobilized and not biologically available. The absolute amount of
lead depends on the mass of the article.
In this context there is no restriction on the use of lead bound in

crystal glass as defined in Annex I (Categories 1, 2, 3 and 4) of
Council Directive 69/493/EEC.
Cadmium alloys as This exemption allows for the use of special high melting point
electrical/mechanical solders that contain about 70% cadmium, to solder the voice-coil
solder joints to wires of a novel design of small and light-weight but high-powered
electrical conductors loudspeakers. The loudspeakers that require this exemption are a
located directly on the patented design and operate at close to 300°C and with very high g-
voice coil in forces due to the vibration of the loudspeaker. Few cadmium-free
30
transducers used in solders have a suitable melting temperature; even so-called high
high-powered melting point solders which are covered by the exemption mentioned
loudspeakers with in paragraph 8 above melt at about 300°C. The light-weight design is
sound pressure levels achieved by the use of aluminum wires and the few cadmium-free
of 100 dB (A) and solders with a suitably high melting point such as zinc/aluminum are
more. too aggressive and dissolve the aluminum.
This exemption permits the use of lead in the material used to form a
gas tight bond for a new type of flat fluorescent lamp that is mercury
free and has an unusually long life. Research has not yet identified a
material that can form a permanent gas tight bond without lead.
Lead in soldering
Although referred to as a “soldering material”, this is a lead based low
materials in mercury
melting point glass with ~70% lead oxide which melts on heating the
free flat fluorescent
lamp assembly to form the bond and seal the lamp. These lamps can
31 lamps (which e.g. are
be used as backlights for LCDs, as well as for lighting and other
used for liquid crystal
applications. They are thicker than the narrowest types of special
displays, design or
straight fluorescent lamps that do need to contain mercury and are
industrial lighting).
used where there is limited space available such as in laptop
computers. Lead in these special lamps is already covered by the
exemption in paragraph 23 above, but this exemption allows lead in
special thin flat lamps but only for LCD.
The optical windows of Argon and Krypton lasers are sealed using
special glass frit materials that contain lead oxide. Frit seals are made
with low melting point glasses in powder form and these form a glass
bond when heated to above their melting point. The optical windows
Lead oxide in seal
and the laser tube are both quartz and only seals made with lead
frit used for making
based glass provide the correct combination of properties that allow
window
32 the vacuum tight bond to be made and precisely align the windows
assemblies for
Argon and Krypton with a high yield.
laser tubes.
Argon and Krypton lasers are used as tools for cutting materials.
They are also used for medical applications such as eye surgery
although medical lasers are in Category 8 of the WEEE Directive and,
therefore, currently outside the scope of the RoHS Directive.
Copper transformer wires are connected to terminals by soldering but

copper dissolves in the liquid solder. In the time taken to make a
solder joint, it is possible for all of the copper to dissolve if the wire is
very thin resulting in weak bonds. The rate at which copper dissolves
depends on the solder composition, the temperature and time at high
temperature. The rate of dissolution is faster in lead-free solder than
in tin/lead solder at the same temperature. The slowest dissolution
rate is achieved with tin/lead solder alloys that also contain ~3%
Lead in solders for the
copper. Standard lead-free solders with <1% copper dissolve the
soldering of thin
copper wire much more rapidly. Another issue is that it can take
33 copper wires of 100
longer to make a lead-free bond than a tin/lead bond so that more
μm diameter and less
copper dissolves. High power transformers use very fine wires and
in power transformers
generate high voltage and so the solder bond must be domed to
avoid arcing and this increases the time required to make the bond.
To burn off the enamel coatings used on fine copper wires requires
the use of a high temperature and this also increases the copper
dissolution rate. Enamel coated transformer wires of 100 μm diameter

or less cannot be soldered with lead-free solders as too much copper
dissolves resulting in a weak bond and so solders containing lead
must be used.
Cermet based potentiometers are electronic components used to

provide an adjustable electrical resistance. This type of potentiometer
is the only type suitable for high current, high humidity or high
temperature operation. The device contains a cermet disc with a
resistive coating of ruthenium oxide with lead oxide that is applied as
a paste which is heated to melt the lead oxide to give a strong, wear-
resistant bond. The lead imparts the necessary wear resistance and a
Lead in cermet-based
stable electrical resistance. Similar coatings of lead with ruthenium
34 trimmer potentiometer
oxide are widely used in chip resistors which are generally regarded
elements
as being covered by RoHS exemption 7c (lead in electronic ceramic
parts) but neither the applicant nor the Commission could determine if
the cermet potentiometer application was covered by RoHS
exemption 7c or by RoHS exemption 5 (lead in glass of cathode ray
tubes, electronic components and fluorescent tubes) and so this
exemption has been granted to allow the use of lead in the resistive
materials of cermet potentiometers.
Most plasma displays on the market, including plasma TVs, are AC

types which do not contain mercury. However this exemption applies
to DC type plasma displays which contain small amounts of mercury.
Mercury used as a DC plasma displays that show information (eg numbers) are quite
cathode sputtering different to AC plasma television displays. Inside the display, DC
inhibitor in DC plasma voltages are applied between anodes and cathodes to generate the
35 displays with a plasma. With DC, the charge flows in one direction so that electrons
content up to 30 mg hitting the cathode slowly erode the surface by a process referred to
per display until 1 July as “sputtering”. Mercury vapour within the plasma display effectively
2010 retards sputtering of the cathodes giving the display an acceptable
life. No alternative materials have yet been found to replace mercury.
The exemption is granted only until 1 July 2010 because research
into substitute materials is underway.
High voltage glass diodes are made with a special type of glass
based on zinc borate with ~2.5% lead. The glass composition is
Lead in the plating designed to match the thermal expansion coefficient of the
layer of high voltage component’s terminals. The terminals are electroplated with a tin
36 diodes on the basis of coating and during assembly, small quantities of lead from the glass
a zinc borate glass diffuse into the tin coating giving it a composition with up to 0.3%
body lead. Although the lead in the glass of the diode is covered by
exemption No. 5 of the RoHS Annex, the lead that has diffused into
the tin coating is not covered by any other existing exemptions.
Hybrid circuits based on alumina substrates are widely used in

electronics but for certain specific and demanding applications,
beryllium oxide substrates are required. The hybrid circuit consists of
a number of layers of insulators, dielectrics and metals that are
applied to create the electrical circuit. Semiconductor dies are
Cadmium and attached to the circuitry commonly with fine aluminium wires that are
cadmium oxide in bonded to the metal conductors of the hybrid circuit using ultrasonic
37 thick film pastes used wire-bonding. The materials of the hybrid circuitry must bond strongly
on aluminium bonded to each other and to the substrate and not de-bond during the thermal
beryllium oxide processing or when aluminium ultrasonic wire-bonding is carried out.
Traditionally, hybrid materials have contained lead and cadmium
oxide to form low melting point glasses that melt during processing to
create a strong bond. RoHS compliant hybrid materials have been
developed that are suitable for the more common alumina substrates
but none are yet available that are suitable on beryllium oxide.
Mattel – Confidential Information

3600 Heavy Elements


QSOP 3600 Rev.11.00 Heavy Elements 8-20-2021

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美泰机密文件/ 商业秘密资料。版权所有。版权 2021年

3600 Heavy Elements

QSOP 3600 11.00 2021-08-20 Ying Gao

FOR QUESTIONS CONTACT

Mattel Confidential Information | May Include Trade Secrets | Property of Mattel

1.1 - Products and Components Covered

1.1.1 - All toys and child care articles

Non- toy/non-child care article children's products

1.1.3 - Test the following to QSOP 3604, Heavy Elements – Jewelry

Jewelry intended to be worn by either a child or an adult

1.1.5 - Test the following to QSOP 3607, Heavy Elements – Cosmetics

3600 Heavy Elements (rev. 11.00) 1 | Page

1.2.4 - Promotional items intended for adults.

1.2.7 - Items listed in Appendix V are exempt from §2.4.

1.2.8 - Metals are exempt from organotin requirements.

3600 Heavy Elements (rev. 11.00) 2 | Page

2.1 - All Products

Table 1 - Heavy Element Limits for Inaccessible Parts of All Products

ELEMENT TOTAL (ppm)

2.2 - Components Intended for Use Exclusively by Adults

2.2.1 - Surface Coatings

3600 Heavy Elements (rev. 11.00) 3 | Page

ELEMENT TOTAL (ppm)

All accessible plastic parts

ELEMENT TOTAL (ppm)

2.3.1 - Surface Coatings

All accessible surface coatings except the ones in §2.3.1.1

Table 4 Heavy Element Limits for Surface Coatings

ELEMENT TOTAL (ppm) SOLUBLE SOLUBLE

Antimony (Sb) - 60 1000

Arsenic (As) - 25 1000

Barium (Ba) - 1000 1000

Cadmium (Cd) 75 17 1000

Selenium (Se) - 460 1000

3600 Heavy Elements (rev. 11.00) 4 | Page

Aluminum (Al) - 28130 -

Boron (B) - 15000 -

Cobalt (Co) - 130 -

Copper (Cu) - 7700 -

Manganese (Mn) - 15000 -

Nickel (Ni) 10000 930 -

Strontium (Sr) - 56000 -

Tin (Sn) - 180000 -

Zinc (Zn) - 46000 -

Chromium (VI) (Cr VI) - 0.053 -

2.3.1.1 - The following must have ≤ the limits listed in Table 5

Table 5, Heavy Element Limits for Surface Coating on Pri

nted Paper/Paper Board

ELEMENT TOTAL (ppm) SOLUBLE SOLUBLE

Antimony (Sb) - 60 1000

Arsenic (As) - 25 1000

Barium (Ba) - 1000 1000

Cadmium (Cd) 75 17 1000

Selenium (Se) - 460 1000

2.3.2 - Metal, Glass, Gemstone and Ceramic

2.3.2.1 - Non-Small Parts

ELEMENT TOTAL (ppm)

3600 Heavy Elements (rev. 11.00) 5 | Page

Nickel (Ni) 10000