If you’re purchasing IT products, you’re likely concerned about avoiding harmful substances in their supply chains. However, the task can seem overwhelming, leaving you unsure of where to start.
Blog by:
Stephen Fuller
The European Chemicals Agency (ECHA) has developed a five-step model for safer substitutions. It provides a useful framework that can be applied whether you operate within the EU or outside of it. However, there are a lot of loopholes if you don’t ensure testing and compliance is validated by independent experts.
Here, you’ll learn how to use TCO Certified as verification of proof, with results that go above and beyond ECHA’s model. This is a resource-efficient way to manage risks regardless of your level of expertise in the chemicals field.
Hazardous substances used in IT manufacturing present a wide variety of risks. Dioxins, halogens and other toxicants can persist in the natural environment and the human body. Out of the 350,000 substances that are available on the market, only around one percent have been tested for their impact on humans and the environment. In an attempt to get on top of the situation, the European Chemicals Agency (ECHA) has developed a five-step model for chemical substitution:
- Identify your hazardous substance
- Scope the issue and identify potential alternatives
- Assess, compare and select alternatives
- Test, implement and improve alternatives
- Inform your supply chain
The ECHA five-step model can serve as a guide for identifying potential alternatives, but it does not bridge the gap between identification and real-world application. Hazard identification must be combined with independently assessed safer alternatives that provide equal performance, so production suppliers are confident the substitute works and has a low risk of ending up on a future restriction list.
How TCO Certified goes beyond ECHA’s five-step model
Step 1: Identify your hazardous substance
ECHA: Make an inventory of the substances you use. For substitution, prioritise those that are considered the most hazardous, substances that may not be absolutely necessary for a product to function, and substances that may be subject to regulatory actions or market pressure in the near future.
TCO Certified: Identifying which substances are used in the product can be problematic due to confidentiality. To identify substances used in the product, TCO Certified requires close collaboration between brand owners, suppliers, and independent licensed toxicologists. For each product category, such as flame retardants used in plastic enclosures, a collective of brand owners engages suppliers to submit information on intentionally added substances, including CAS numbers, concentrations and chemical functions. This data helps to identify hazardous substances and potentially hazardous substances.
Conclusion: TCO Certified fully aligns with and directly supports the objectives of Step 1. Our collaborative, data-driven approach enables the effective identification and prioritisation of both hazardous substances and those that are potentially hazardous due to unassessed data on their impact.
Step 2: Scope the issue and identify potential alternatives
ECHA: Set the scope of the substitution project to determine the level of stakeholder engagement you intend to undertake, the goals and principles underlying the project, and the criteria you will use to select alternative substances. As a first step, you should carefully consider if there is a real need for the technical functionality provided by the hazardous substance and/or if there are other ways of achieving the same goal.
TCO Certified: We require that hazardous or unassessed substances are evaluated against known safer alternatives already used within the product category. Through our public TCO Certified Accepted Substance List approach, brands and suppliers are encouraged to explore functionally equivalent alternatives and materials, many of which are already being used in similar applications, but not universally. This fosters a proactive, informed search, speeding up the transitions to the sustainable options, avoiding speculative, regrettable substitutions.
Conclusion: This proactive approach of not only identifying potential alternatives but also publicly listing the safer alternatives fully aligns with and directly supports the objectives of Step 2.
Step 3: Assess, compare and select alternatives
ECHA: Compare the substances you have shortlisted to decide which one to use. Assess the hazard and risk level, technical performance, economic feasibility, and other relevant impacts.
TCO Certified: This step is at the core of the TCO Certified Accepted Substance List method. Before a substance is approved as safer, it must undergo a comprehensive and independent assessment by a licensed toxicologist. The evaluation covers a wide range of parameters, including human health, environmental impact and physical hazards such as flammability. Only substances proven safer for human health and the environment are listed on TCO Certified Accepted Substance List.
Conclusion: Our method for assessing, comparing and selecting alternatives is transparent, structured and science-based. It ensures that substitutions are not only safer but also feasible and economically viable, and fully aligns with and directly supports the objectives of Step 3.
Step 4: Test, implement and improve alternatives
ECHA: Conduct pilot tests of the chosen alternative to assess its effectiveness. Then, it is time to fully implement it. Gather feedback from stakeholders and make necessary continuous improvements based on the received feedback.
TCO Certified: As part of our process, we identify safer chemicals that are already in use by some suppliers. These substances have been tested and proven to be functionally effective. However, they are not adopted universally across the industry. To close this gap, TCO Certified requires the broader adoption of these verified safer alternatives, effectively phasing out hazardous and unassessed substances from products and supply chains.
Conclusion: By clearly specifying which substances are approved for use, TCO Certified reduces the need for every brand owner or supplier to conduct their own separate testing and piloting for the same category and application. This transparency not only speeds up the transition to safer alternatives across the industry but also ensures the substitution is practical and scalable, fully aligning with and supporting the objectives of Step 4.
Step 5: Inform your supply chain
ECHA: Communicate substitution decisions and alternative substances to suppliers and clients to ensure transparency and enable informed action across the supply chain.
TCO Certified: Unlike conventional approaches, where brand owners instruct suppliers on what not to use through limited restricted substance lists, often resulting in the risk of regrettable substitutions that can lead to product recalls, TCO Certified offers brand owners of all types of electrical equipment a strategic advantage by providing clear, proactive guidance on what to use instead. Through the publicly available TCO Certified Accepted Substance List, brand owners and suppliers can make informed decisions based on independently assessed safer alternatives.
Conclusion: By reducing uncertainty and promoting a consistent chemical use across the supply chain, where sustainability and functional performance are fully considered, this approach fully aligns with and directly supports the objectives of Step 5.
A verified model for safer chemicals
Our publicly available TCO Certified Accepted Substances List not only fully aligns with the structure and intent of the ECHA five-step model, but also actively supports its implementation in practice. By providing clear, science-based guidance on safer alternatives, requiring independent hazard assessments, and promoting consistent chemical use across the supply chain, TCO Certified turns the principles of substitution into actionable, scalable change. This approach, since 2015, has empowered brand owners and suppliers to move beyond compliance toward proactive, informed, and sustainable chemical management.
Ask for TCO Certified
With nearly 8,000 employees located in 88 cities, Atea is one of the leading suppliers of IT infrastructure in the Nordic and Baltic regions. Sustainability specialist Camilla Cederquist explains that when IT buyers ask how to prove compliance with ECHA’s five-step model, her advice is to use TCO Certified.
Listen to our chemicals expert, Stephen Fuller, as he explains how TCO Certified helps you avoid the risks of hazardous substances in the IT supply chain.
“TCO Certified is a comprehensive all-in-one solution, making it very easy to use. The proactive approach with TCO Certified Accepted Substance List allows our clients to confidently follow ECHA’s five-step model. They can trust that only substances deemed safer have been used in both the product and its manufacturing,” she says.
She also appreciates that TCO Certified makes the work with sustainability more efficient for her clients. “It can be challenging for purchasers to establish their own criteria, specifically, identifying which product characteristics are essential to include and determining how criteria should be verified. In my opinion, fragmented requirements that are not properly enforced do not lead to meaningful change.”
“With a comprehensive certification like TCO Certified, where all criteria are independently verified, customers can be confident that they are focusing on the right aspects. This approach ultimately saves a lot of time and resources,” she concludes.
About TCO Certified Accepted Substance List
- We view all substances as a risk until proven otherwise.
- Before a substance is approved for use, risks are assessed by an independent toxicologist.
- Approved substances can be used on production lines with certified products.
- TCO Certified Accepted Substance List is public and can be used across all industries.
