EU: Vehicle indoor air quality partly regulated through REACH

 

On 17 July 2023, the European Union’s Official Journal (OJEU) published Regulation (EU) 2023/1464, which added a new restriction on formaldehyde released from articles under Annex XVII to REACH regulation as entry 77.

Interestingly, through this non-vehicle specific regulation, new requirements are introduced for formaldehyde emissions for parts for road vehicles in vehicle interior.

In accordance with the requirement, formaldehyde (CAS No 50-00-0, EC No 200-001-8) and formaldehyde-releasing substances:

should not be placed on the market in road vehicles after 6 August 2027 if, under the test conditions specified in Appendix 14, the concentration of formaldehyde in the interior of those vehicles exceeds 0,062 mg/m3.

Exempted are:

(a)  road vehicles exclusively for industrial or professional use unless the concentration of formaldehyde in the interior of those vehicles leads to exposure of the general public under foreseeable conditions of use;

(b)  second-hand vehicles.

The entry 77 is the first one of the REACH annex XVII dealing explicitly with vehicles and their parts. It shows how various non-type approval specific regulations (like REACH) can have impact on vehicles.

Background of VIAQ

Since the late 1970s, vehicle interior air quality (VIAQ) has been a subject of interest, mirroring growing concerns about the impact of volatile and semi-volatile organic compounds (VOCs and SVOCs) on indoor environments, now extended to the automotive industry. VOCs and SVOCs emitted from vehicle trim materials—such as plastics, polyurethane, foam, wood, carpets, textiles, and adhesives—are the primary contributors to poor VIAQ. The associated health risks have driven regulatory efforts in this field. However, in China, consumer dissatisfaction with unpleasant odors in vehicle cabins has emerged as the leading quality complaint, intensifying focus on VIAQ.

Regulations on VIAQ

In response to VIAQ concerns, voluntary guidelines were initially developed to set acceptable VOC levels in vehicle interiors. Today, most manufacturers are gearing up to comply with the mandatory Chinese regulation GB/T 27630.3. Unlike the industry-defined standards prevalent in the EU and US, this regulation is government-driven, akin to less stringent guidelines in Japan and Korea.