You identify phthalates in a product by reading the material declaration for the ester’s name, CAS number and concentration in each plasticized component, and you prove the answer with solvent-extraction GC-MS on that component when a limit applies. No handheld instrument can do it, and an SDS cannot rule a phthalate out.
1. Check the ingredient or material information
Look for each phthalate by CAS number, not only by abbreviation, in the material declaration, the plasticizer CoA and section 3 of any compound or plastisol SDS. Abbreviations drift between suppliers, and DINP alone is sold under two CAS numbers — 28553-12-0, and 68515-48-0 for the C8–C10 branched, C9-rich technical grade — so a search for one of them misses the other.
The twelve esters a declaration is most likely to name, with the restriction list each sits on:
| Phthalate | Common abbreviation | CAS No. | Restricted under |
|---|---|---|---|
| Di(2-ethylhexyl) phthalate | DEHP | 117-81-7 | CPSIA, REACH 51, RoHS |
| Dibutyl phthalate | DBP | 84-74-2 | CPSIA, REACH 51, RoHS |
| Benzyl butyl phthalate | BBP | 85-68-7 | CPSIA, REACH 51, RoHS |
| Diisononyl phthalate | DINP | 28553-12-0; 68515-48-0 | CPSIA, REACH 52 |
| Diisobutyl phthalate | DIBP | 84-69-5 | CPSIA, REACH 51, RoHS |
| Dicyclohexyl phthalate | DCHP | 84-61-7 | CPSIA |
| Di-n-pentyl phthalate | DPENP | 131-18-0 | CPSIA |
| Di-n-hexyl phthalate | DHEXP | 84-75-3 | CPSIA |
| Diethyl phthalate | DEP | 84-66-2 | Not on the lists below |
| Dimethyl phthalate | DMP | 131-11-3 | Not on the lists below |
| Diisodecyl phthalate | DIDP | 26761-40-0; 68515-49-1 | REACH 52 |
| Di-n-octyl phthalate | DNOP/DnOP | 117-84-0 | REACH 52 |
The last column is the point of the exercise. A declaration that reads “compliant with REACH Annex XVII entry 51” has told you about four esters and nothing about DINP, which sits on entry 52 and on the US list but on neither entry 51 nor RoHS. Read the column for the market the part ships into, and ask for the esters on that list by name.
2. Identify products with a higher likelihood of containing plasticizers
Flexible PVC is where the plasticizer is, and therefore where a phthalate will be. Around 85 % of the plasticizers consumed in Europe go into flexible PVC — cables, roof membranes, flooring, upholstery, blood bags and other medical products, technical textiles — and the same holds for hoses, films and coated fabrics. Any component that bends, dents under a thumbnail or carries a plastisol coating is plasticized until its declaration says otherwise.
Loading turns identification into a yes-or-no question. A flexible compound carries its plasticizer at tens of percent of the part: the CPSC’s worked example for its own test method found 30 % DEHP and 7.5 % DINP in a small PVC toy. If the ester is a phthalate, the part is orders of magnitude over any 0.1 % limit, so what you are identifying is which ester was used, not whether a trace slipped in.
The other end of the scale is the regulator’s own no-test list. The CPSC has determined that polypropylene, polyethylene, the polystyrene grades (GPPS, MIPS, HIPS, SHIPS) and ABS, compounded only with non-phthalate plasticizers, stabilizers, antioxidants, flame retardants and colorants, do not exceed the limits with a high degree of assurance and need no third-party test. PVC is not on that list in any form: a PVC part is declared or tested, never assumed.
3. Ask the manufacturer for compliance documents
Ask for three things: a signed material declaration naming each phthalate present by CAS number with its concentration in each plasticized component; the certificate the destination market requires; and the SDS of every compound, plastisol and plasticizer that goes into the part. The declaration carries the weight; the SDS is the weakest of the three, for reasons below.
The certificate depends on the market. A US children’s toy or child care article needs a Children’s Product Certificate citing 16 CFR part 1307, backed by third-party testing. In the EU, REACH Article 33 obliges the supplier of an article containing a Candidate List substance above 0.1 % w/w to pass on at least the substance’s name; DEHP, DBP, BBP and DIBP are on that list. For electrical and electronic equipment the RoHS declaration covers the same four at 0.1 % in each homogeneous material.
Article 33 covers only Candidate List substances, so a clean Article 33 statement says nothing about DINP, DIDP or DNOP. DINP is absent from entry 51 and from RoHS, and the same ester is one of the eight banned above 0.1 % in every US children’s toy and child care article. A part declared phthalate-compliant for Europe needs a DINP line item — by name, with a number — before it ships into a US children’s product.
The SDS cannot prove absence, for two reasons. It is owed for substances and mixtures — the plasticizer, the compound, the plastisol — and never for a finished article, so a cable jacket or a hose has no SDS at all. And section 3 lists only substances that are classified, on the Candidate List or PBT, above the cut-offs.
An ester that carries no classification — and ECHA’s Risk Assessment Committee concluded in 2018 that DINP warranted none — can be in a plastisol at 30 % and never appear in section 3. Read an SDS for what it lists; read nothing into what it omits.
4. Use laboratory testing when you need proof
Proof is solvent-extraction GC-MS on the plasticized component, run to a named method with the destination market’s full phthalate list written on the order. The component is dissolved completely in tetrahydrofuran, the PVC precipitated back out with a second solvent, and each ester quantified separately by GC-MS; the report comes back as percent by weight per phthalate per component, which is the form every limit is written in.
Three methods cover most PVC applications:
| Method | Matrix | Technique | Phthalates covered |
|---|---|---|---|
| CPSC-CH-C1001-09.4 (2018) | Consumer products, per plasticized component | THF dissolution, polymer precipitation, GC-MS | The eight in 16 CFR part 1307 |
| ASTM D7823-20 | PVC, low level (up to 1000 ppm) | Thermal desorption GC-MS | BBP, DBP, DEHP, DNOP, DINP, DIDP |
| IEC 62321-8:2017 | Polymers of electrotechnical products (RoHS) | GC-MS, or pyrolysis/thermal-desorption GC-MS | DIBP, DBP, BBP, DEHP, DNOP, DINP, DIDP |
CPSC also accepts EN 14372, EN 71-5, ISO 8124-6, GB/T 22048 and ASTM D8133 as written, with one condition it states outright: several methods do not include all eight US-regulated phthalates and must be extended to cover them. Enforce that yourself — write the phthalate list on the order instead of trusting the method’s default panel.
Sampling is per plasticized component part, never a composite of the whole article. A composite dilutes a soft grip with the rigid body around it and can put a failing component under the limit on paper.
Each reported hit must also state its identification basis. CPSC’s method requires linear C9 and C10 phthalates and terephthalates to be excluded by their spectra, because they share ions and elution windows with the regulated esters; a DOTP-plasticized part can put a signal where a lab expects a phthalate, and a report that does not say how the two were told apart is not proof either way.
5. Don’t rely on XRF for phthalate testing
XRF cannot see a phthalate: it reads elements, and a phthalate is carbon, hydrogen and oxygen, indistinguishable by element from every other ester, oil or resin in the compound. The instrument that clears a cable for lead and cadmium has nothing to say about DEHP or DINP.
The one thing XRF adds to a phthalate program is total chlorine. A high chlorine reading tells you the part is PVC, which is the part most likely to be plasticized — a sorting tool for deciding what goes to GC-MS, not a result.
Handheld FTIR is the other shortcut on offer, and the CPSC’s own optional IR pre-screen sets its limit: the phthalate doublet at 1600 and 1580 cm⁻¹ becomes visible at roughly 10 % phthalate or more, a hundred times the 0.1 % limit, and the method states that absence of the doublet does not indicate compliance, nor its presence a violation. The CPSC uses it to choose the dilution before GC-MS, and that is the extent of what any spectroscopic screen can do here.
A practical supplier-control workflow
Run six steps in this order — material identification, supplier declaration, SDS collection, risk ranking, GC-MS on the high-risk components, comparison against the applicable limit — each step deciding whether the next is needed.
- Material identification: Establish what polymer each component is and whether it is plasticized, from the drawing or the supplier’s material list, confirmed by XRF total chlorine where the material is unknown. Plasticized PVC goes down the full chain; polymers on the CPSC’s no-test list with non-phthalate additives stop here.
- Supplier declaration: A signed statement naming every phthalate present by CAS number, with its concentration per component, against the regulation you name — not a generic “phthalate-free”. For US children’s products, the CPC citing 16 CFR part 1307; for EEE, the RoHS declaration.
- SDS / material declaration: Collect the SDS for every compound, plastisol and plasticizer in the part and read section 3 for what it does list; treat silence as no information, not as absence. For a finished article, the material declaration is the only document that exists.
- Risk assessment: Rank components by plasticized PVC first, then by the market’s exposure trigger — mouthable, children’s, skin contact — and by how specific the declaration was. A flexible PVC component with a generic declaration ranks highest.
- GC-MS testing of high-risk flexible plastics: Send the top-ranked components to a lab under a named method, with the destination market’s full phthalate list, per-component sampling and spectral confirmation for any hit.
- Compare results with the applicable regulatory limit: Read the report against the basis of the regulation, not just the number.
| Regime | Scope | Phthalates and limit | Basis |
|---|---|---|---|
| 16 CFR part 1307 (CPSIA) | US children’s toys (12 years and under) and child care articles (3 years and under) | DEHP, DBP, BBP, DINP, DIBP, DPENP, DHEXP, DCHP — more than 0.1 % | Each phthalate separately, per plasticized component part |
| REACH Annex XVII entry 51 | Toys and childcare articles; all other articles since 7 July 2020, with exemptions | DEHP, DBP, BBP, DIBP — 0.1 % or more | Per plasticized material, individually or in any combination (summed) |
| REACH Annex XVII entry 52 | Toys and childcare articles that can be placed in the mouth | DINP, DIDP, DNOP — more than 0.1 % | Per plasticized material |
| RoHS Annex II | Electrical and electronic equipment from 22 July 2019; medical and monitoring devices from 22 July 2021 | DEHP, BBP, DBP, DIBP — 0.1 % | Each substance separately, per homogeneous material |
The bases are not interchangeable. A component reporting 0.06 % DEHP and 0.06 % DBP passes 16 CFR part 1307 and RoHS, which count each ester alone, and fails entry 51, which sums the four. Entry 51’s exemptions decide whether it applies at all: articles solely for industrial or agricultural use, articles used only in the open air with no skin or mucous-membrane contact, and articles covered by their own legislation — food contact, medical devices, EEE — sit outside it.
Conclusion
Identifying a phthalate comes down to two documents and one test: a declaration that names the ester by CAS number and concentration per component, the certificate the market requires, and GC-MS when the component is flexible PVC and the declaration is generic. Nothing else on the list is proof — an SDS shows only what is classified, XRF shows only elements, FTIR shows only loadings a hundred times the limit.
Write the phthalate list and the reporting basis on every request. The four esters Europe controls in every article are not the eight the US controls in a toy, and DINP is the one that falls between them.