Group standard VW 91101

Issue 2015-03
Class. No.: 97210

Descriptors: avoidance of hazardous substances, environmental standard, material, operating fluid

Environmental Standard for Vehicles; Vehicle Parts, Materials, Operating

Fluids
Avoidance of Hazardous Substances

Previous issues
VW 91101: 1993-11, 1996-10, 1999-04, 2001-05, 2004-04, 2007-11, 2010-11

Changes
The following changes have been made to VW 91101: 2010-11:
– The order of section 2 "Definitions" and section 3 "Description" has been changed
– Reference to VDA 232-101 changed to GADSL
– Section 4.1 "General requirements" added
– Section 4.2 "Emission restrictions in the vehicle interior": Reference to VW 50179 deleted for
Audi and VW 96043 (PN 780) added for Porsche
– Section 4.3 "Substances subject to mandatory declaration and banned substances" expanded
– Section 4.4 "Material bans in the Volkswagen Group exceeding the requirements of the
GADSL" expanded
– Section 4.5 "Supplier's obligation to provide information" expanded
– Section 6 "Bibliography" added

Contents
Page
1 Scope ......................................................................................................................... 2
2 Definitions .................................................................................................................. 2
3 Description ................................................................................................................. 2
4 Requirements ............................................................................................................. 2
4.1 General requirements ................................................................................................ 2
4.2 Emission restrictions in the vehicle interior ................................................................ 3

Always use the latest version of this standard.

This electronically generated standard is authentic and valid without signature. Page 1 of 6
The English translation is believed to be accurate. In case of discrepancies, the German version is alone authoritative and controlling.

Technical responsibility The Standards department

EKDV/4 Dr. Christiane von
HF/1 Dr. Anja Pieper Tel.: +49 531 298 2574 Finckenstein-Wang EKDV
K-EFUP/S Klaus Mayr-Rauch Tel.: +49 5361 9 25480 Tel.: +49 5361 9 23945 Maik Gummert

All rights reserved. No part of this document may be provided to third parties or reproduced without the prior consent of one of the Volkswagen Group’s Standards departments.
© Volkswagen Aktiengesellschaft VWNORM-2014-06a-patch5
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4.3 Substances subject to mandatory declaration and banned substances .................... 3

4.4 Material bans in the Volkswagen Group exceeding the requirements of the
GADSL ....................................................................................................................... 4
4.5 Supplier's obligation to provide information ................................................................ 4
5 Applicable documents ................................................................................................ 4
6 Bibliography ............................................................................................................... 5

1 Scope
Environmental policy: Objectives and specifications as per Volkswagen standard VW 91100
This standard provides information on substances, preparations, and products the use of which is
banned, restricted, or subject to other requirements according to the following regulations:
– laws in countries which are sales markets for vehicles produced by the Volkswagen Group or
– internal decisions within the Volkswagen Group, regardless of legal regulations and the loca‐
tion of use.
The standard applies to substances, preparations, and products which are used in the vehicle or in
vehicle parts, and which are used as operating fluids. It also applies to substances, preparations,
and products which are produced or used during the operation of the vehicle or during its repair
and maintenance.
This standard deals with the use and handling of these materials, which are known to contain or
which could potentially contain harmful substances.
In this regard, it does not matter whether the undesired substances are introduced as additives or
impurities, or whether they develop at a later point in time.

2 Definitions
Mixture (preparation) Mixtures or solutions consisting of two or more substances.
Product Object which consists of one or several substances or preparations and
which during production is given a specific shape, surface, or design which
determines its function to a greater degree than its chemical composition.
Substance Chemical element and its compounds in natural form or artificially pro‐
duced. A substance may include additives required to maintain product sta‐
bility and pollutants caused by the production method. It does not include
solvents which can be separated from the substance without adversely af‐
fecting the substance‘s stability and without modifying its composition.

3 Description
The following entry must be made in the pertinent technical documentation:
Avoidance of hazardous substances as per VW 91101

4 Requirements

4.1 General requirements

The following standards must be complied with: VW 50156, VW 50180, VW 91100,
VW 91101 supplement 1, and VW 96043.
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All applicable laws and regulations (e.g., for USA, Canada, ECE, EC, Australia, China), as well as
all other relevant national regulations, must be complied with. In the case of tests required by law,
the current version of the law must always be applied.

4.2 Emission restrictions in the vehicle interior

The occupants of vehicles produced by the Volkswagen Group must not experience any effects
– threatening their health or
– compromising their well-being.
The following standards must be complied with:
– VW 50180;
– Additionally, for Porsche: VW 96043 (corresponds to Porsche standard PN 780).

4.3 Substances subject to mandatory declaration and banned substances

The Global Automotive Declarable Substance List (GADSL) [1] and the laws referenced therein
must be applied in all cases.
All data sheets containing confidential basic substances or basic substances hidden behind a wild‐
card must be checked each time the GADSL is updated or changed. If data sheets contain sub‐
stances that have been added to the GADSL as banned substances or substances subject to man‐
datory declaration, the following applies: The data sheets in question must be updated as soon as
the GADSL is modified; the substances in the data sheets must be explicitly specified and the data
sheets must be resubmitted to the Volkswagen Group (see also IMDS Recommendation 001, sec‐
tion 4.5 [2]).
The applicable limits of all substances marked with "P" (prohibited) in the GADSL must not be ex‐
ceeded in the specified fields of application.
Material bans must always be complied with, also in the case of carry-over parts (COPs), and the
applicability of the parts must be checked to that effect.
Products and mixtures may only contain or emit substances which are registered and approved for
the intended applications according to Regulation (EC) No. 1907/2006 ("REACH") [3] within the ap‐
plicable deadlines.
The following must be observed in particular:
– Regulation (EC) No. 1907/2006 "Regulation on Registration, Evaluation, Authorisation and Re‐
striction of Chemicals (REACH)" [3]
– Regulation (EC) No. 1272/2008 "Regulation on Classification, Labelling and Packaging of
Substances and Mixtures" [4]
– Directive 1999/45/EC "Directive on Classification, Packaging and Labelling of Dangerous
Preparations" [5]
– Directive 67/548/EEC "Directive on Classification, Packaging and Labelling of Dangerous Sub‐
stances" [6]
– Directive 2000/53/EC "Directive on End-of-Life Vehicles" [7]
– Directive 2006/66/EC "Directive on Batteries and Accumulators and Waste Batteries and Ac‐
cumulators" [8]
The supplier must comply with the requirements.
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4.4 Material bans in the Volkswagen Group exceeding the requirements of the GADSL
If the Volkswagen Group issues regulations or bans for substances or materials exceeding the reg‐
ulations specified in section 4.2 and section 4.3, these are specified in VW 91101 supplement 1,
with which the supplier must comply. VW 91101 supplement 1 is updated regularly and the suppli‐
er must comply with the agreed version in each case.
VW 91101 supplement 1 contains more precise specifications on the following:
– whether or not the use of a substance is completely prohibited
– limit values for the contents or the release of specific substances, or
– whether or not mandatory declaration applies.
If the regulations referenced in section 5 and section 6 end up imposing more stringent require‐
ments than those specified in VW 91101 supplement 1 as a result of further development, then the
more stringent requirements given in section 5 and section 6 will apply in all cases.

4.5 Supplier's obligation to provide information

The supplier is obliged to promptly inform the appropriate Procurement department (as per
VW 01155, "Supplier Guideline for Product Development" [9]) and the head of the appropriate De‐
sign Engineering department (if necessary, via the part owner), as well as the Materials Engineer‐
ing Quality Assurance department of the Volkswagen Group company that awards the contract.
The supplier must also clarify, jointly with the appropriate Procurement department, on how to pro‐
ceed further, if the following applies for a substance contained in a component:
– must no longer be used because it is marked as "P" in the GADSL,
– is subject to new regulations set forth in Annex II of Directive 2000/53/EC [7],
– is added to the directory of substances subject to authorization (Annex XIV of Regulation (EC)
No. 1907/2006 [3]),
– is added to the directory for restricting the manufacture, placement on the market, and use of
certain hazardous substances, mixtures, and products, (Annex XVII of Regulation (EC) No.
1907/2006 [3]) and is prohibited in terms of its application according to the entry in Annex XVII,
or
– is regulated or banned by the Volkswagen Group through a new issue of VW 91101 supple‐
ment 1 to this standard.
The supplier of operating fluids is obliged to provide a safety data sheet and the exact chemical
composition in as-received condition to the authorized recipient upon request by the responsible
person as per VW 50156, appendix A 1.
The confidential data are only used for purposes of marking, evaluation, and release in the context
of industrial hygiene. Access is restricted to a defined group of users. The supplier has the option
of receiving a non-disclosure agreement in advance.

5 Applicable documents
The following documents cited in this standard are necessary to its application.
Some of the cited documents are translations from the German original. The translations of Ger‐
man terms in such documents may differ from those used in this standard, resulting in terminologi‐
cal inconsistency.
Standards whose titles are given in German may be available only in German. Editions in other
languages may be available from the institution issuing the standard.
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VW 01155 Vehicle Parts; Approval of First Supply and Changes

VW 50156 General Information for Process Materials and Industrial Hygiene Relea‐
ses for Operating Fluids and Cosmetics; Technical (Process Materials
Only) and Industrial Hygiene Conditions for Sample Inspections, Relea‐
ses, and Deliveries
VW 50180 Components in the Passenger Compartment; Emission Behavior
VW 91100 Environmental Standard for Vehicles; Vehicle Parts, Materials, Operat‐
ing Fluids; Policy, Specifications
VW 91101 Environmental Standard for Vehicles; Vehicle Parts, Materials, Operat‐
supplement 1 ing Fluids; Avoidance of Hazardous Substances; Special Requirements
of the Volkswagen Group
VW 96043 PN 780 - Interieur; Emissionsverhalten

6 Bibliography
[1] GADSL (Global Automotive Declarable Substance List); see www.gadsl.org
[2] IMDS (International Material Data System) Recommendation 001, section 4.5; see
www.mdsystem.com
[3] Regulation (EC) No. 1907/2006 "Regulation of the European Parliament and of the
Council concerning the Registration, Evaluation, Authorisation and Restriction of Chemi‐
cals (REACH), establishing a European Chemicals Agency, amending Direc‐
tive 1999/45/EC and repealing Council Regulation (EEC) No. 793/93 and Commission
Regulation (EC) No. 1488/94 as well as Council Directive 76/769/EEC and Commission
Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC" (can be found at
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:
2007:136:0003:0280:de:PDF)
[4] Regulation (EC) No. 1272/2008 "Regulation of the European Parliament and of the
Council on Classification, Labelling and Packaging of Substances and Mixtures, amend‐
ing and repealing Directives 67/548/EEC and 1999/45/EC, and amending Regulation
(EC) No. 1907/2006" (can be found at http://eur-lex.europa.eu/LexUriServ/LexUri‐
Serv.do?uri=OJ:L:2008:353:0001:1355:de:PDF)
[5] Regulation 1999/45/EC "Directive of the European Parliament and of the Council con‐
cerning the Approximation of the Laws, Regulations and Administrative Provisions of the
Member States relating to the Classification, Packaging and Labelling of Dangerous
Preparations" (can be found at http://eur-lex.europa.eu/legal-content/en/ALL/?uri=CEL‐
EX:31999L0045)
[6] Directive 67/548/EEC "Council Directive on the Approximation of Laws, Regulations and
Administrative Provisions relating to the Classification, Packaging and Labelling of Dan‐
gerous Substances" (can be found at http://eur-lex.europa.eu/LexUriServ/LexUri‐
Serv.do?uri=CELEX:31967L0548:DE:PDF)
[7] Directive 2000/53/EC "Direction of the European Parliament and of the Council on End-
of-Life Vehicles" (can be found at http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?
uri=CONSLEG:2000L0053:20050701:DE:PDF)
[8] Directive 2006/66/EC "Directive of the European Parliament and of the Council on Bat‐
teries and Accumulators and Waste Batteries and Accumulators and repealing Directive
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91/157/EEC" (can be found at http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?

uri=CONSLEG:2006L0066:20060926:DE:PDF)
[9] Supplier Guideline for Product Development; see https://sso.volkswagen.de/cqpubl-
kbp/content/doclib/vwkbc.iddownload.html/id=58d8cb8b-
ae01-4b24-939b-7ecad5847a4a/lieferantenleitfaden_prod_entw__v2_0_b2b_portal.pdf