EUROFINS MTS TEST PROTOCOL
SUMMARY OF TEST RESULTS FOR
SP - 953 - US - Costco
TSCA Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:
TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS
Pass Fail
ANALYTICAL
In-house * US EPA Persistent, As required under the Toxic Substances
method, GC- Bioaccumulative, and Toxic Control Act (TSCA), as amended by the
MS analysis (PBT) Chemicals under Frank R. Lautenberg Chemical Safety for
TSCA the 21st Century Act, EPA issued five final
rules in December 2020 to reduce
exposures to certain chemicals that are
persistent, bioaccumulative and toxic
(PBT). These chemicals build up in the
environment over time and can therefore
have potential risks for exposed
populations, including the general
population, consumers and commercial
users, and susceptible subpopulations
(such as workers, subsistence fishers,
tribes and children).
US EPA Limit:
Deca-BDE
• March 8, 2021 – manufacturing and
processing of Deca-BDE or Deca-BDE
containing products/articles
Limit – prohibited
• January 6, 2022 – Distribution into
commerce of Deca-BDE or Deca-BDE
containing products/articles
Limit – prohibited
PIP (3:1)
• October 24, 2024– processing and
distribution into commerce of PIP (3:1) or
PIP (3 1) t i i d t / ti l
Latest revision: 26 Apr 2023 Page 1 of 5
EUROFINS MTS TEST PROTOCOL
SUMMARY OF TEST RESULTS FOR
SP - 953 - US - Costco
TSCA Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:
TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS
Pass Fail
* US EPA Persistent, 2,4,6-TTBP
Bioaccumulative, and Toxic • January 6, 2026 – Distribution into
(PBT) Chemicals under commerce of TTBP or TTBP in containers
TSCA with a volume less than 35 gallons.
Limit - ≤ 0.3% by weight in any container
(Continued) with a volume of less than 35 gallons
• January 6, 2026 –processing and
distribution in commerce of 2,4,6-TTBP oil
and lubricant additives
Limit - ≤ 0.3% by weight
TTBP
• January 6, 2026 – Distribution into
commerce of TTBP or TTBP containing
products
Limit - ≤ 0.3% by weight in any container
with a volume of less than 35 gallons
HCBD
• March 8, 2021 – manufacturing,
processing and distribution into commerce
of HCBD or HCBD containing
products/articles
Limit – prohibited
PCTP
• March 8, 2021 – manufacturing and
processing of PCTP or PCTP containing
products/articles
Limit - ≤ 1% by weight
• January 6, 2022 – distribution into
commerce of PCTP or PCTP containing
products/articles
Limit - ≤ 1% by weight
In lieu of testing, approved letter of
guarantee (LoG) dated within one year
Latest revision: 26 Apr 2023 Page 2 of 5
EUROFINS MTS TEST PROTOCOL
SUMMARY OF TEST RESULTS FOR
SP - 953 - US - Costco
TSCA Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:
TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS
Pass Fail
In-house * EPA First Ten Chemicals Under TSCA EPA is now required to
method, GC- for Review Under New TSCA evaluate existing chemicals to determine
MS, HPLC- Legislation whether they “present an unreasonable risk
of injury to health or the environment.” The
DAD, HPLC-
Agency will start the risk evaluation process
MS and/or
for these first 10 chemicals and within six
polarized months release a scoping document for
light each chemical which includes the
microscopy hazard(s), exposure(s), conditions of use,
analysis and the potentially exposed or susceptible
subpopulation(s) the Agency plans to
consider for the evaluation.
Costco limit:
100 mg/kg (each)
US EPA first 10 chemicals under TSCA:
1. 1,4-Dioxane (123-91-1)
2. 1-Bromopropane (106-94-5)
3. Asbestos (-)
4. Carbon Tetrachloride (56-23-5)
5. Cyclic Aliphatic Bromide (HBCD) (-)
6. Methylene chloride (MC) (75-09-2)
7. N-methylpyrrolidone (NMP) (872-50-4)
8. Pigment Violet 29 (Anthra[2,1,9-def:
6,5,10-d’e’f’] diisoquinoline-1,3,8,10(2H,9H)-
tetrone) (81-33-4)
9. Trichloroethylene (TCE) (79-01-6)
10. Tetrachloroethylene
(Perchloroethylene) (127-18-4)
In lieu of testing, approved letter of
guarantee (LoG) can be submitted for
Latest revision: 26 Apr 2023 Page 3 of 5
EUROFINS MTS TEST PROTOCOL
SUMMARY OF TEST RESULTS FOR
SP - 953 - US - Costco
TSCA Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:
TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS
Pass Fail
In-house * EPA High-priority On December 20, 2019, EPA finalized the
method, ICP- substances for risk designation of 20 chemical substances as
OES, GC- evaluation under TSCA a high-priority for risk evaluation under
TSCA. This was the final step of the
MS and/or
prioritization process initiated on March 20,
HPLC-DAD-
2019. These chemicals will move through
MS analysis the process required by TSCA to evaluate
any unreasonable risks they may present to
human health or the environment.
Costco limit:
100 mg/kg (each)
EPA High-Priority chemicals for risk
evaluation under TSCA:
1. p-Dichlorobenzene (106-46-7)
2. 1,2-Dichloroethane (107-06-2)
3. trans-1,2-Dichloroethylene (156-60-5)
4. o-Dichlorobenzene (95-50-1)
5. 1,1,2-Trichloroethane (79-00-5)
6. 1,2-Dichloropropane (78-87-5)
7. 1,1-Dichloroethane (75-34-3)
8. Dibutyl phthalate (DBP) (1,2-Benzene-
dicarboxylic acid, 1,2- dibutyl ester) (84-74-
2)
9. Butyl benzyl phthalate (BBP) - 1,2-
Benzene-dicarboxylic acid, 1-
butyl2(phenylmethyl) ester (85-68-7)
10. Di-ethylhexyl phthalate (DEHP) - (1,2-
Benzene-dicarboxylic acid, 1,2-bis(2-
ethylhexyl) ester) (117-81-7)
11. Di-isobutyl phthalate (DIBP) - (1,2-
Benzene-dicarboxylic acid, 1,2-bis-
(2methylpropyl) ester) (84-69-5)
12 Dicyclohexyl phthalate (84 61 7)
* EPA High-priority 13. 4,4’-(1-Methylethylidene)bis[2,6-
substances for risk dibromophenol] (TBBPA) (79-94-7)
evaluation under TSCA 14. Tris(2-chloroethyl) phosphate (TCEP)
(115-96-8)
(Continued) 15. Phosphoric acid, triphenyl ester (TPP)
(115-86-6)
16. Ethylene dibromide (106-93-4)
17. 1,3-Butadiene (106-99-0)
18. 1,3,4,6,7,8-Hexahydro-4,6,6,7,8,8-
hexamethylcyclopenta[g]-2-benzopyran
(HHCB) (1222-05-5)
19. Formaldehyde (50-00-0)
20. Phthalic anhydride (85-44-9)
In lieu of testing, approved letter of
guarantee (LoG) can be submitted for
review.
Latest revision: 26 Apr 2023 Page 4 of 5
EUROFINS MTS TEST PROTOCOL
SUMMARY OF TEST RESULTS FOR
SP - 953 - US - Costco
TSCA Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:
TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS
Pass Fail
Acid * Reporting Requirements for On June 27, 2018, EPA published in the
digestion / the Mercury Inventory of the Federal Register a final rule to require
ICP Toxic Substances Control reporting from persons who manufacture
Act (including import) mercury or mercury-
added products, or otherwise intentionally
use mercury in a manufacturing process.
The information collected through the
reporting requirements are used to develop
an inventory of mercury supply, use, and
trade in the United States. Based on the
information collected, the Agency will
identify any manufacturing processes or
products that intentionally add mercury and
recommend actions to achieve further
reductions in mercury use.
Costco limit:
Prohibited
Note:
- Letter of Guarantee (LoG) to be collected
for items with the following high risk
materials: (Print, Coating, Inks, Paints,
Pigments, Soft Plastics (Including Synthetic
Leather), Hard Plastics, Metal, Ceramic,
Glass.);
- Vendor shall be responsible for the
compliance of all other materials.
- If the product fails mercury testing for a
separate requirement, issue a failure for
this protocol line.
IMPORTANT NOTICE: Please review the Actual Products against the updated Requirements/Regulation. Prior to
testing and communicate with clients if additional test required. This protocol is the basic guidelines to follow
and does not replace the content of the standard. (For Silverware additional test should be included)
Note: It is the Vendor's responsibility to ensure that the products comply with all local laws,
regulations and ordinances of Countries and States where products will be sold. A Pass Lab test
result does not constitute a certification that a vendor's products meet all legal requirements. It is
the vendor's responsibility to manufacture their items to comply with all applicable laws and in
conformance with the purchase order terms and conditions.
Key:
*Additional Charge For This Test **Mandatory Requirement
Latest revision: 26 Apr 2023 Page 5 of 5
