Group standard VW 91101

Issue 2019-04
Class. No.: 97210

Descriptors: avoidance of hazardous substances, environmental standard, fuels, coolants, fluids, and lubricants,
material

Environmental Standard for Products

Material Conformity

Previous issues
VW 91101: 1993-11, 1996-10, 1999-04, 2001-05, 2004-04, 2007-11, 2010-11, 2015-03

Changes
The following changes have been made to VW 91101: 2015-03:
– Standard completely revised
– VW 91101 Supplement 1 was revised and incorporated into this standard as appendix A
– Appendix A from VW 01155 was revised and incorporated into this standard as appendix B

Contents
Page
1 Scope ......................................................................................................................... 2
2 Definitions .................................................................................................................. 3
3 Abbreviations ............................................................................................................. 3
4 Description ................................................................................................................. 4
5 Requirements ............................................................................................................. 4
5.1 General requirements ................................................................................................ 4
5.2 Emission restrictions in the vehicle interior ................................................................ 5
5.3 Substances subject to declaration and prohibited substances .................................. 5
5.4 Material prohibitions and restrictions at the Volkswagen Group that go beyond
the requirements in the regulations and that are referenced in the GADSL or
QUELLE: NOLIS

other associated regulations governing substances or chemicals ............................. 5

5.5 Supplier obligation to provide information .................................................................. 5
6 Applicable documents ................................................................................................ 6
7 Bibliography ............................................................................................................... 7

Always use the latest version of this standard.

This electronically generated standard is authentic and valid without signature. A comma is used as the decimal sign. Page 1 of 14
The English translation is believed to be accurate. In case of discrepancies, the German version controls.

Technical responsibility The Standards department

K-GETU/3 Stephan Schöne Tel.: +49 5361 9 45227 K-ILI/5 Carl Eckhard Hagelberg K-ILI
ETB/3 Dr. Andre Hartmann Tel.: +49 5361 9 126564 Tel.: +49 5361 9 23945 Uwe Wiesner
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-2018-11
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Appendix A Avoidance of Hazardous Substances; Special Requirements of the

Volkswagen Group ..................................................................................................... 8
A.1 Radioactivity ............................................................................................................... 8
A.2 Substances of very high concern as per the REACH Regulation .............................. 8
A.3 Substances subject to approval under REACH ......................................................... 8
A.4 Biocides ...................................................................................................................... 8
A.5 Decabromodiphenyl ether .......................................................................................... 8
A.6 1,3-Di-o-tolylguanidine (DOTG) ................................................................................. 9
Appendix B MDS requirements in IMDS, CDX, and MISS .......................................................... 10
B.1 Requirements ........................................................................................................... 10
B.2 Milestones ................................................................................................................ 10
B.3 Data systems ........................................................................................................... 10
B.4 Rules ........................................................................................................................ 10
B.4.1 General errors .......................................................................................................... 10
B.4.2 Formal errors ............................................................................................................ 11
B.4.3 Content errors .......................................................................................................... 13
B.5 Confidential basic substances .................................................................................. 13
B.6 Additional notes ........................................................................................................ 14

1 Scope
Environmental policy: Objectives and specifications as per Volkswagen standard VW 91100
This standard defines requirements for substances, mixtures, and products the use of which is pro-
hibited, restricted, or otherwise subject to requirements as per:
– Laws in countries that are sales markets for Volkswagen Group vehicles
– Internal Group decisions independently of regulations and the location of use
The standard applies to substances, mixtures, materials, and products that are used in the vehicle
or in vehicle parts, as well as to all other products including fuels, coolants, fluids, and lubricants. It
also applies to substances, mixtures, and products that are produced or used during the operation
of the vehicle or during its repair or maintenance.
The subject matter of this standard is the use and handling of materials that verifiably or potentially
contain pollutants or that are subject to chemical inventory regulations.
In this regard, it does not matter whether the undesired substances are introduced as additives or
impurities, or whether they are produced upon end use.
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2 Definitions
CAS No. The CAS number (CAS = Chemical Abstracts Service) is an international
designation standard for chemical substances. There is a unique CAS num-
ber for each chemical substance registered in the CAS database.
Chemical inventory Regulation governing chemicals, with a list of substances, prescribes the
conditions for the manufacture, import/export, or use of the listed substan-
ces exclusively or bans the manufacture, import/export, or use of the listed
substances in general. The most important chemical inventories include:
EU/EEA: EINECS/NLP/ELINCS/REACH, USA: TSCA, Canada: DSL, Aus-
tralia: AICS, Korea: KECI/K-REACH, Japan: ENCS/ISHL, the Philippines:
PICCS, China: IECSC, New Zealand: NZIOC, Russia: RPOHV, Mexico:
INSQ, Taiwan: TCSI, Malaysia: EHSNR, Vietnam: VNECI, Turkey: KKDIK
D-U-N-S® D-U-N-S®1) is the acronym for "Data Universal Numbering System," a nu-
meric code that is internationally recognized as a standard and is used to
uniquely identify companies. These nine-digit D-U-N-S® numeric codes are
issued by Dun & Bradstreet and serve as identification numbers for all the
companies in Dun & Bradstreet's database.
Life cycle In this standard, the life cycle of a product includes its production, import,
usage, maintenance, and disposal.
Material data sheet Substance declaration in the required IT systems as per appendix B.
Mixture Preparations or solutions consisting of two or more substances.
Product And object that consists of one or more substances or mixtures and that,
during production, gets a specific shape, surface, or design that determines
its function to a greater extent than its chemical composition does.
Product The term "Volkswagen AG product" refers to all products and services pro-
duced or sold by the companies (e.g., vehicles, components, genuine parts,
spare parts, accessories, promotional items).
Regulation In this standard, the term "regulation" encompasses all regulations, ordi-
nances, government decisions, and other such rules that have a direct or
indirect effect on substances during product life cycles.
Substance Every organic or inorganic substance with a specific molecular identity, in-
cluding all combinations of these substances, that occurs in nature or as
the result of a chemical reaction as a whole or in part, as well as every ele-
ment and free radical.

3 Abbreviations
AICS Australian Inventory of Chemical Substances (Australian inventory)
CDX Compliance.Data.Exchange (IT system for material data reporting)
DSL Domestic Substances List (Canadian inventory)
EEA European Economic Area
EHSNR Environmentally Hazardous Substances Notification and Registration (Ma-
laysian law governing chemicals)
EINECS European Inventory of Existing Commercial Chemical Substances
ELINCS European List of Notified Chemical Substances
ENCS Existing Notified Chemical Substances (Japanese inventory)
EU European Union
GADSL Global Automotive Declarable Substance List (list of substances subject to
mandatory declaration – substances in components and materials)

1) D-U-N-S® is a registered trademark of Dun & Bradstreet International, Ltd.

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IECSC Inventory of Existing Chemical Substances in China (Chinese inventory)

IMDS International Material Data System (IT system for material data reporting in
the automotive industry)
INSQ National Inventory of Chemical Substances of Mexico (Mexican inventory)
ISHL Industrial Safety and Health (Japanese inventory)
K-REACH Act for Registration and Evaluation of Chemical Substances (Korean law
governing chemicals)
KECI Korea Existing Chemicals Inventory (Korean inventory)
KKDIK Turkish Regulation on Chemicals Registration, Evaluation, Authorization
and Restriction (Turkish law governing chemicals)
MDS Material data sheet (bill of materials for a product that contains the chemi-
cal composition for all the materials and components in the product)
MISS Material Information System (Volkswagen AG IT system)
NLP No-longer Polymers list
NZIOC New Zealand Inventory of Chemicals (New Zealand inventory)
PICCS Philippine Inventory of Chemicals and Chemical Substances (Philippine in-
ventory)
REACH Registration, Evaluation, Authorization, and Restriction of Chemicals (EU
Regulation concerning the Registration, Evaluation, Authorization, and Re-
striction of Chemicals)
RPOHV Russia National Existing Chemical Substance Inventory (Russian invento-
ry)
SOP Start of Production
TCSI Taiwan Chemical Substance Inventory (Taiwanese inventory)
TSCA Toxic Substance Control Act (law governing chemicals in the USA)
TSCA SNURs TSCA Significant New Use Rules (rules for significantly new substance
uses)
USA United States of America
VNECI Vietnam National Existing Chemical Inventory (Vietnamese inventory)

4 Description
The following note must be added to the affected technical documents and to the documents con-
cerning procurement and quality assurance2):
Material conformity as per VW 91101

5 Requirements

5.1 General requirements

The following must be adhered to: VW 50156, VW 50180, VW 91100, appendix A, and appendix B.
All applicable laws and regulations (e.g., for the USA, Canada, the EU, Australia, China), as well
as all other national and international regulations, must be complied with. For legally required tests,
the current version of the law must always be applied.

2) Examples include: Product specifications, drawings, agreements, and other documents related to the products defined in this stand-
ard.
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5.2 Emission restrictions in the vehicle interior

For the occupants of vehicles produced by the Volkswagen Group, emissions in the interior must
not:
– Affect their health negatively
– Cause them discomfort
The following must be adhered to:
– VW 50180

5.3 Substances subject to declaration and prohibited substances

The regulations listed in the GADSL [1], as well as all other regulations worldwide that may have
an effect on the life cycle of products, must be complied with.
In addition to the requirements in IMDS Recommendation 001, section "Basic rules for MDS revi-
sions," material data sheets must also be revised, and the corresponding substances must be dis-
closed, if they are subject to mandatory declaration or if they may have effects during the life cycle.
All substances identified with P = Prohibited in the GADSL must not exceed the corresponding lim-
its in the specified application fields.
Material restrictions must always be adhered to – even with carry-over parts (COPs) –, and the
whether the parts can be used must be checked within this context.
Products and mixtures must only contain or release substances that are registered and approved
worldwide for the intended applications as per all relevant chemical inventories and regulations
governing chemicals.

5.4 Material prohibitions and restrictions at the Volkswagen Group that go beyond the
requirements in the regulations and that are referenced in the GADSL or other
associated regulations governing substances or chemicals
If the Volkswagen Group issues any rules or prohibitions for substances or materials that go be-
yond the ones in section 5.2 and section 5.3, they will be listed in appendix A, which is binding for
suppliers.
Appendix A defines the following in greater detail:
– Whether the use of a substance is completely prohibited,
– The limit up to which substances can be contained or released, or
– Whether the substance is subject to mandatory declaration

5.5 Supplier obligation to provide information

The supplier is obligated to provide material data sheets as per appendix B.
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The supplier is obligated to inform the purchaser about the product and the product composition
within 48 hours if the product contains:
– A substance that must no longer be used because it is identified with "P" in the GADSL or its
specific usage is regulated in any other regulation worldwide
– A substance that is directly or indirectly subject to restrictions in any chemical inventory world-
wide
– A substance that is part of any regulatory measure worldwide (e.g., TSCA SNURs, REACH
Annex XIV/XVII)
The supplier must also discuss the further course of action together with the purchaser.
Any change to the chemical composition of a product must be managed as per VW 01155.
Suppliers of fuels, coolants, fluids, and lubricants or materials for the production process are obli-
gated to provide, in addition to the requirements in appendix B, the exact chemical composition as
per VW 50156 and a material safety data sheet.

6 Applicable documents
The following documents cited are necessary to the application of this document:
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.

VW 01098 Part Number System

VW 01155 Vehicle Parts; Approval of First Supply and Changes
VW 50156 General Information for Process Materials; Industrial Hygiene Releases
for Fuels, Coolants, Fluids, Lubricants, and Cosmetics Technical (Proc-
ess Materials Only) and Industrial Hygiene Conditions for Sample In-
spection, Release, and Delivery
VW 50180 Components, Semi-Finished Products, and Materials in the Vehicle Inte-
rior; Emission Behavior
VW 91100 Environmental Standard for Vehicles; Vehicle Parts, Materials, Fuels,
Coolants, Fluids and Lubricants, Genuine Parts, Exchange Parts, Econ-
omy Parts; Objectives, Specifications
VW 99000 Overall Requirements for the Performance of Component Development
Contracts
VDA 231-106 Material classification in motor vehicle construction - Structure and no-
menclature

IMDS (International Material Data System) Recommendation 001; see www.mdsystem.com

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7 Bibliography
[1] GADSL (Global Automotive Declarable Substance List); see www.gadsl.org
[2] Regulation (EU) No 528/2012 of the European Parliament and of the Council of 22 May
2012 Concerning the Making Available on the Market and Use of Biocidal Products; see
https://eur-lex.europa.eu
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Appendix A (normative) Avoidance of Hazardous Substances; Special Requirements of

the Volkswagen Group

A.1 Radioactivity
The substances, mixtures, and products listed in section 1 must not emit ionizing radiation that
goes beyond natural radiation.

A.2 Substances of very high concern as per the REACH Regulation

One important objective of the European REACH Regulation governing chemicals is "to encourage
and in certain cases to ensure that substances of high concern are eventually replaced by less
dangerous substances or technologies where suitable economically and technically viable alterna-
tives are available."
In order to achieve this objective, it is recommended to avoid, in components for the Volks-
wagen Group, substances on the "candidate list for substances of very high concern" and to re-
place them under consideration of the conditions above.
The candidate list can be obtained from the homepage of the European Chemicals Agency.

A.3 Substances subject to approval under REACH

Substances listed in Annex XIV of the REACH Regulation are prohibited for new components that
are to be developed, even if the approval obligation comes into effect after introduction into produc-
tion.
If using these substances is unavoidable – especially if there is no alternative that is reasonable
technically or in terms of economic feasibility –, the substances will require approval from the part
owner and the head of the appropriate Development department at the Volkswagen Group compa-
ny placing the order, particularly under consideration of the provisions in the REACH Regulation.
Annex XIV of the REACH Regulation can be obtained from the homepage of the European Chemi-
cals Agency.

A.4 Biocides
The use of biocides is not permissible.
If using biocides is unavoidable, the European Biocidal Products Regulation [2] must be complied
with and the permissibility of active agents in biocidal products in particular must be observed.
The active agents in the biocides used are subject to mandatory declaration in the material data
sheets (IMDS, CDX).

A.5 Decabromodiphenyl ether

The use of bromated flame-retardant decabromdiphenyl ether (DBDE, CAS-No. 1163-19-5) for
newly developed components for the Volkswagen Group is prohibited.
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A.6 1,3-Di-o-tolylguanidine (DOTG)

The use of 1,3-Di-o-tolylguanidine (DOTG, CAS-No. 97-39-2) as a vulcanization accelerator is pro-
hibited worldwide.
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Appendix B (normative) MDS requirements in IMDS, CDX, and MISS

B.1 Requirements
The material data sheets must meet the conditions and rules in IMDS Recommendation 001.
Requirements deviating from this are defined in this appendix.

B.2 Milestones
For the recyclability type approval, at least the provisional material data (i.e., weights, materials,
and material classes as per VDA 231-106) must be published in the IMDS, CDX, or MISS for all
components and assemblies by the B-release.
In all cases, the design engineer is obligated to ensure that the material data is available with the
appropriate quality at the time of the B-release.
14 months before SOP for the components at the latest, complete material data sheets must be
provided.

B.3 Data systems

All vehicle-specific components, semi-finished products, and materials must be declared in the
IMDS. Vehicle parts that cannot be effectively declared in the IMDS because, e.g., they fall under
ROHS legislation3), are exempt from this requirement. All other products must be declared in the
CDX system.
IMDS data and CDX data must be sent to the purchaser by the deadlines specified in section B.2.

B.4 Rules
Every part, every semi-finished product, and every material must be described with the complete
structure by its MDS in its final condition (e.g., adhesives and paints in cured condition).
The data sheet will be rejected if one of the items specified in section B.4.1, section B.4.2, or
section B.4.3 applies4).

B.4.1 General errors

Part number missing or incorrect

The Volkswagen part number as per VW 01098 must be entered into the MDS on the "Recipient
Data" page.

3) Directive 2011/65/EU of the European Parliament and of the Council of 8 June 2011 on the Restriction of the Use of Certain Hazard-
ous Substances in Electrical and Electronic Equipment Text with EEA Relevance
4) In justified individual cases, MDSs may be exempt from certain tests.
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Part designation missing or incorrect

The designation of the part/semi-finished product as per the drawing or CAD file must be entered
into the MDS on the "Recipient Data" page in German or English. Addenda to the designation to
provide a more detailed description are permissible. However, the exact designation as per the
drawing/CAD file must be included.

Drawing number or drawing version missing or incorrect

The drawing number and drawing version (version/date) from the drawing must be entered into the
MDS on the "Recipient Data" page. The drawing version must be entered using the following for-
mat: DD.MM.YYYY (e.g., 01.02.2003). If the drawing number or drawing version does not exist, "-"
or "does not exist" must be entered.
For fuels, coolants, fluids, and lubricants, the specific recipe number must be entered into this field.

Question regarding distribution of MDS not answered with "Yes"

Distribution must be allowed for all MDSs.

Supplier number missing, incorrect, or unknown

The D-U-N-S® number of the supplier must be entered into the MDS on the "Recipient status data"
page. For the D-U-N-S® number to be accepted, the supplier must have the "active" status in the
Volkswagen supplier database. If the status is not active yet, it can be changed accordingly on the
ONE.Konzern Business Plattform5) using the "Partner registration" link.

B.4.2 Formal errors

The calculated weight deviates from the entered weight by more than the specified/derived
tolerance
For each MDS data set entered into the IMDS, the entered weight is usually the actual weighed
weight of the component. After being entered, the weight of each individual node is automatically
added up in the IMDS and shown as the calculated weight.
The weight tolerance is the permissible deviation from the specific component weight and is gener-
ally indicated in the specification or drawing. If the entered measured weight and the calculated
weight differ from each other significantly (deviation greater than the maximum permissible devia-
tion specified in table B.1), a check must be carried out in order to determine whether all part com-
ponents were specified in the MDS.
If a weight tolerance is not specified in the component specifications, the following tolerance values
must not be exceeded in the event of a deviation between the measures and calculated weights.

Table B.1 – Permissible weight deviations

Maximum permissible de-
Measured weight
viation
<1g 100%
< 100 g 10%
< 1 kg 5%
5) The ONE.Konzern Business Plattform can be found at http://www.vwgroupsupply.com/one-kbp-pub/en/kbp_public/homepage/home-
page.html.
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Maximum permissible de-

Measured weight
viation
< 10 kg 2%
< 100 kg 1%
≥ 100 kg 0,5%

Wildcard use
Using wildcards is impermissible. The exception is using the "not yet specified" wildcard in data
sheets for development sample inspections.
Confidential substances can be marked as "confidential". The supplier is obligated to define at
least two contractual counterpart representatives as trusted (additional information can be found in
section B.5).

Use of the "not yet specified" wildcard6)

This wildcard indicates that individual components in the material are not known. Because of this,
using it is only permissible on provisionally marked data sheets that are permissible up until the B-
release as per VW 99000.

Missing or wrong application ID

If a material in a part contains one or more basic substances the use of which is restricted by law,
appropriate application IDs that characterize the purpose of the corresponding usage must be
specified. These application IDs must be correct.

Use of the "Other Application (potentially prohibited)" application ID

The use of application IDs with a status of "concealed" or "inactivated" is not permissible for new
MDS versions.
This also applies to the "Other Application" application ID. This application ID is permissible only
following agreement.

MDSs to which the attribute of provisional MDS "Yes" has been assigned
Data sheets declared as "provisional" cannot be used for the sample inspection

6) MDSs for sample inspections during the development phase are exempt from these checks.
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B.4.3 Content errors

The wrong VDA category was assigned

A category as per VDA 231-106 must be assigned to every material (e.g., "3.2 Copper alloys,"
"5.1.a Filled thermoplastics"). This category assignment must be correct (e.g., a steel must not be
classified as an aluminum alloy) and as detailed as possible (e.g., 1.1.1 or 1.1.2 instead of 1.1).

The basic substance composition of materials is not specified in its final condition
The basic substance compositions of all materials must be specified in their final condition. In other
words, paints, adhesives, etc., must be specified in their cured condition and, in the case of other
solid materials, liquids and reactive substances must only be present in residual concentrations.

The part weight is incorrect

The weighed weight must be specified for each part. If the weighed weight is unknown, the part
must be weighed or the weight as per the drawing must be specified.

B.5 Confidential basic substances

In order to meet the requirements in this standard, and depending on the relevant product and
market, the Volkswagen Group is required by law to know all the component substances of a prod-
uct.
In order to meet the applicable legal requirements, using wildcards in the IMDS and CDX is imper-
missible (for exceptions, see section B.4.2). The supplier must declare all component substances
fully.
To ensure that confidential information remains protected, the corresponding substances can be
marked as being confidential in the IMDS And CDX so that they will only be accessible to defined
people at a manufacturing company at Volkswagen AG. This right can be revoked at any time.
The material data sheet preparer is obligated to provide select employees, from the manufacturing
company at Volkswagen AG using the components, with the right to view the confidential basic
substances.
In the IMDS and CDX, the only employees available for selection will be those that the manufactur-
ing company at Volkswagen AG has authorized to view confidential basic substances.
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B.6 Additional notes

For additional notes on preparing MDSs, the applicable version of IMDS Recommendation 001
must be consulted. These notes can be accessed by logging in to the IMDS and clicking on "Help"
→ "Recommendations."
A summary can be found on the ONE.Konzern Business Plattform7), in the "Sustainability" category
under "Product standards → IMDS".
Because the MDS is downloaded from the IMDS and checked once a night, a delay of one to
two workdays between transmission and rejection/acceptance must be planned for when submit-
ting the MDS as part of the initial sample inspection.

7) The ONE.Konzern Business Plattform can be found at http://www.vwgroupsupply.com/one-kbp-pub/en/kbp_public/homepage/home-

page.html.