AkzoNobel Paints and Coatings

Product Safety and Regulatory Affairs (PSRA)

Toxicological and Regulatory

Assessment Questionnaire (TRAQ)
The following Questionnaire has been created by AkzoNobel Paints and Coatings, Product Safety and
Regulatory Affairs group. Herewith it is requested to fill in this form as complete, as fully, as possible. It
has been designed to obtain additional information that is required to complete our own internal
assessments. Please send all requested information to your contact person at AkzoNobel. The
information will be treated confidentially.

• All suppliers of AkzoNobel must complete sections 1-3.

• In addition, suppliers of AkzoNobel selling materials for use in coatings requiring food
contact compliance MUST complete section 4.
• In addition, suppliers of AkzoNobel selling materials for use in consumer electronics MUST
complete section 5

Note: Only the grey boxes can be filled in, please use your Tab button to navigate through the document
and to fill in your answers.
Trade name: CRYLCOAT® 2655-6 powder resins
Supplier: allnex
Country of origin: Please contact your customer service partner or sales representative as the Country
of Origin may be different depending on supply conditions.

I confirm that the information in this form is correct to the best of my knowledge.

Company: allnex Place: Malaysia

Name: Toh Yee Chie Date: 22nd November 2021

E-mail address: YeeChie.Toh@allnex.com Signature

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Product Safety and Regulatory Affairs (PSRA)

Toxicological and Regulatory

Assessment Questionnaire (TRAQ)
SECTION 1 – General information

The following information is required, leave blank when it is available in the SDS/TDS, if not applicable
please put NA:

a) The density (specific gravity) of the material kg/m3

b) The percentage of water if present wt %
c) The percentage solids content wt%

If the raw material contains substances present that fits one of the following categories, please list them
in the table and concentration present in the Raw material:

Name (chemical name) CAS nr Content

%

Biocidal active substance (and M-

Factor)

Respirable Crystalline silica (only Select:

quote respirable component)
Non-Respirable Crystalline silica Select:
VOC (Volatile Organic Compound) Select: Please see SDS
boiling point ≤250°C (EU Directive
2004/42/CE)
Substances intentionally produced Select:
at Nanoscale

Definition of Product: □ Single Substance ■ Mixture □ Polymer □ UVCB

Shelf Life: Please see TDS

Composition of the material

Please declare content with name, CAS number and concentration for all classified components and
all non-classified components including intentionally added water. Please include additional
attachment if more space is required. If any trade secret codes apply (New Jersey Right To Know,
etc.) please provide any applicable codes in the table below.

Description CAS Number Weight %

Aliphatic amine Confidential <0.3
Confidential - Remaining

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Product Safety and Regulatory Affairs (PSRA)

Toxicological and Regulatory

Assessment Questionnaire (TRAQ)
In order for AkzoNobel to make risk assessments on the dangers of powdered materials, we request
the following information to be provided;

Can the material cause a dust explosion? Select: Please see SDS

If yes, please fill in the information below;

a) ST Class Select:
b) Kst Value (in bar*m/sec)
c) Minimum Ignition Energy (in mJ)

Particle Size: d10 (µm)

d50 (µm)

d90 (µm)

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Product Safety and Regulatory Affairs (PSRA)

Toxicological and Regulatory

Assessment Questionnaire (TRAQ)
SECTION 2 - Product Registration and Inventory Listings - Please see SDS

Please confirm if the product is registered in the following countries, specifying registration numbers
and exemptions in an attachment if applicable. All substances in this material are listed on:

AUSTRALIA □NO □EXEMPT □ AICS

CHINA □NO □EXEMPT □ IECSC
JAPAN □NO □EXEMPT □ ENCS (MITI/METI) □ ISHL
MALAYSIA □NO □EXEMPT □ EHS
NEW ZEALAND □NO □EXEMPT □ NZloC
PHILIPPINES □NO □EXEMPT □ PICCS
TAIWAN □NO □EXEMPT □ TCSI
TURKEY □NO □EXEMPT □ KKDIK
VIETNAM (draft) □NO □EXEMPT □ NCI
KOREA □NO □EXEMPT □ KECI □ KBPR
EUROPE REACh □NO □EXEMPT □ YES
UNITED STATES OF AMERICA (EPA-TSCA)

All chemical substances in this product are listed on the active TSCA Inventory (TSCA 8(b)):

□NO □EXEMPT □ TCSA

If exempt, provide the exemption category:

If one or more chemical substances are subject to a listed TSCA rule or order, please specify:

• Section 5 premanufacture notification rules

• Section 5 significant new use rules (SNUR)
• Section 5€ orders
• Section 5(f) rules and orders
• Section 6 rules and orders
• Section 7 judicial actions
• Title IV rules and orders

CAS Number Weight % Rule/Order

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Product Safety and Regulatory Affairs (PSRA)

Toxicological and Regulatory

Assessment Questionnaire (TRAQ)
Is any component currently subject to any rule or order under 1998 Chemical Diversion and Trafficking

Act or the Chemical Weapons Convention? □ YES □ NO

UNITED STATES OF AMERICA (EPA - FIFRA)

All chemical substances in this product are registered as FIFRA inert ingredients:

□ YES (Food Use) □ YES (Non-Food Use) □ NO

CANADA
All substances in this product are currently listed on the Domestic Substances List (DSL):
□YES □NO
If NO, please list the substance(s) below that are listed on the NDSL OR Not Listed on either the
DSL or NDSL.

Category
Description or Listing Type % by Chemical Reduced Polymer
CAS # weight Regulatory
Requirement
Polymer

□NDSL □Not Listed □ □ □

□NDSL □Not Listed □ □ □
□NDSL □Not Listed □ □ □
SOUTH KOREA

All substances in products are listed in Korea Existing Chemical Inventory (KECI): □ YES □ NO
If yes, please fill below list with substance that is regulated by K-REACH.

Regulated chemicals CAS No Registration Weight %

no, exemption
no. if exist
Toxic substance(s)
Substance(s) subject to authorization
Restricted Substance(s)
Prohibited Substance(s)
substance(s) requiring preparation for accidents
Registered Phase-in chemicals

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Product Safety and Regulatory Affairs (PSRA)

Toxicological and Regulatory

Assessment Questionnaire (TRAQ)
If no, please fill below list with CAS# or if exist, fill registration no. or exemption no. obtained under
K-REACH

Regulated chemicals Registration no or Weight %

Exemption no. if exist
Description or CAS #
Description or CAS #
Description or CAS #

Is any component currently subject to Korea Biocide Regulation? □ YES □ NO

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Product Safety and Regulatory Affairs (PSRA)

Toxicological and Regulatory

Assessment Questionnaire (TRAQ)
SECTION 3 - Trade Control

Harmonized Customs Codes (10 digits)

EU TARIFF Code: 3907.9980.90

US HTS Code: 3907.99.5050

Code Country of Origin if not EU member state or Please contact your customer service partner or
US: sales representative as the Country of Origin may be
different depending on supply conditions.

Hazardous Substances

□ Yes ■ No
Does the supplied product contain hazardous substances cited in Regulation (EC) No.689/2008
concerning the export and import of dangerous chemicals (PIC)?

If yes, please specify which part of Annex I:

□ Yes ■ No
Does the supplied product contain hazardous substances cited in Directive 2011/65/EU
concerning the use of certain hazardous substances in electrical and electronic equipment
(RoHS)?

If yes, please specify:

Drug Precursors

□ Yes ■ No
Is the product or any component drug precursor controlled in any country?

If yes, please specify:

Export Control

EU

Is the product export controlled according to the EU Common Military List or Dual-use Regulation? □ Yes ■ No
If yes, please provide classification:

US

Is the product subject to US export control regulations (due to e.g. US-origin, US-content)? □ Yes ■ No
If yes, please provide classification according ITAR or EAR: EAR99

Other Legislations
□ Yes □ No
Is the country of origin another country than an EU member state or the US?

If yes, is the product controlled in the country of origin?

□ Yes □ No
If yes, please provide classification and applicable regulation:

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Product Safety and Regulatory Affairs (PSRA)

Toxicological and Regulatory

Assessment Questionnaire (TRAQ)
SECTION 4 –Food Contact This product has not been evaluated for food contact applications.

Europe

Comments
If applicable, please specify chemical
Address and comment as needed. name, CAS no., concentration and
origin (e.g. impurity, deliberately added
or residual.
1. Would the use of this product allow compliance with
1935/2004/EC (Framework Regulation)? If ‘no’, please
Yes☐ No☐
comment.

2. Is the product manufactured in accordance with EU No.

2023/2006 Good Manufacturing Practices (GMP)? If ‘yes’,
Yes☐ No☐
provide ISO number or other support in comments.

3. Are the components of the product or the product itself

listed in COMMISSION REGULATION (EU) No 10/2011 on
plastic materials and articles intended to come into contact Yes☐ No☐
with food Annex I? Please specify restriction(s) if applicable.

4. Are the components of the product or the product itself

listed in the CEPE Code of Practice (A and/or C)? Please
Yes☐ No☐
specify materials and their restriction(s).

5. Are the components of the product or the product itself

listed in the temporary lists of the CEPE Coatings Code of
Yes☐ No☐
Practice (B and/or D)? Please specify components.

6. Do you intend to submit, or has a dossier been submitted

to EFSA to support this product? Are you willing to participate
Yes☐ No☐
in a Common Interest Group? Please comment.

7. Does the product contain a polymeric additive (PA) with

a molecular weight <1000Da?
If ‘yes’, specify if the PA has been assessed by EFSA,
Yes☐ No☐
provide information on whether components of PA have been
fully evaluated, wt%, and % < 1000Da.

8. Do any of the components of the product have a fraction

< 1000 Daltons? If yes, please specify. Yes☐ No☐

9. Does the product contain any residual free monomers?

If yes, please specify monomers and residual level. Yes☐ No☐

10. Product is, or contains an aid to polymerization (A/P)? Yes☐ No☐

If ‘yes’, please specify substance wt% and indicate if listed in:
▪ Council of Europe AP (92)2 Yes☐ No☐
▪ Dutch Warenwet Chapter 1, Table 1.1. Yes☐ No☐

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Product Safety and Regulatory Affairs (PSRA)

Toxicological and Regulatory

Assessment Questionnaire (TRAQ)
11. Does the product contain food additives or dual use
additives listed in the CEPE Code of Practice Annex XI, in
Regulation (EC) No. 1333/2008 or in Regulation (EC) No. Yes☐ No☐
1334/2008 and their amendments? If ‘yes’, please specify.

12. Product is, or contains a colorant? If ‘yes’, comment if

listed in and if compliant with AP (89)1. Yes☐ No☐

13. Does the product comply with or are all components

permitted for use in the German BfR food contact
Yes☐ No☐
recommendations? Specify sections.

14. Does the product comply with or are all components

permitted for use in the German BfR IX purity requirements
Yes☐ No☐
for colorants?

15. Does the product comply with or are all components

permitted for use in the Italian Decreto Ministeriale of March
Yes☐ No☐
21, 1973?

16. Does the product comply with or are all components

permitted for use in the Dutch Warenwet Chapter X July 23,
Yes☐ No☐
2013?

17. Does the product comply with or are all components

permitted for use in the French repression des Fraudes JOC
Yes☐ No☐
No. 1227?

18. Does the product comply with or are all components

permitted for use in the French Circulaire 176? Yes☐ No☐

19. Does the product comply with or are all components

permitted for use in the Spanish Real Decreto 847/2011? Yes☐ No☐

20. Are all product components permitted for use by the

Royal Decree of Belgium 25/09.2016 on coatings and
varnishes intended to come into contact with foodstuffs?
Yes☐ No☐
If so, are any on temporary lists or used under the no
migration principle? If yes, please specify.

21. Does this product comply with the requirements of the

‘Technical Regulation of the Customs Union CU TR
05/2011’ on Packaging Safety (Russia, Kazakhstan, Belarus, Yes☐ No☐
Armenia and Kyrgyzstan)?

22. Does the product meet the April 2020 EuPIA Guideline
on Printing Inks? Yes☐ No☐

23. Does the product comply with the EuPIA Exclusion

Policy for Printing Inks and Related Products (EuPIA 3rd
Yes☐ No☐
Ed., Nov. 2016)?

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Product Safety and Regulatory Affairs (PSRA)

Toxicological and Regulatory

Assessment Questionnaire (TRAQ)
24. Product is, or contains a photoinitiator or a
photosynergist?
If ‘yes’, specify wt% and indicate if listed in the EuPIA Yes☐ No☐
Suitability List of Photoinitiators and Photosynergists
for Food Contact Materials (May 2019).

25. Are all components listed in the Swiss SR 817.023.21

Ordinance Annex 2 (lists I and II) or Annex10 (lists I-V)
Yes☐ No☐
published on the 1st of December 2019.

26. Are any components listed in the Swiss SR 817.023.21

Ordinance part B lists of Annex 2 (lists I and II) or Annex10
(lists I-V) published on the 1st of December 2019.? If yes, Yes☐ No☐
please specify.

27. Does the product contain any metals (or compounds

containing metals) of the elements listed below. If yes,
please specify level(s).
Aluminum (Al), Barium (Ba), Cadmium (Cd), Chromium
(Cr III and / or VI), Cobalt (Co), Copper (Cu), Lead (Pb), Yes☐ No☐
Manganese (Mn), Mercury (Hg), Nickel (Ni), Strontium
(Sr), Tin (Sn) (including organotin), Zinc (Zn), Iron (Fe),
Antimony (Sb), Arsenic (As), Boron (B), Selenium (Se)
and Lithium (Li).

28. Does the product comply with Article 11 of Packaging

and Waste Directive 94/62/EC? Indicate heavy metal wt%. Yes☐ No☐

29. Does the product comply with the migration limits listed in
Annex II of Safety of Toys Directive 2009/48/EC? Yes☐ No☐

30. Does the product contain primary aromatic amines

(PAA’s). If yes, please specify substance(s) and residual
Yes☐ No☐
level(s).

31. Does the product contain polychlorinated biphenyls

(PCB’s). If yes, please specify substance(s) and residual
Yes☐ No☐
level(s).

32. Does the product contain Vinyl chloride monomer, VCM

(CAS No, 75-01-4). If yes, please enter residual level. Yes☐ No☐

33. Does the product contain Carbon Black (CAS 133-86-

4)?
If yes, please specify level and indicate if the product meets
the specifications outlined in Table 1 of Annex I of (EU)
Yes☐ No☐
10/2011 (i.e. <0.1% toluene extractables, <0.25 mg
Benzo(a)pyrene and others such as specific particle size,
distribution & cyclohexane absorption).

34. Does the product contain any mineral oil saturated

hydrocarbons (MOSH), mineral oil aromatic hydro- Yes☐ No☐
carbons (MOAH) or polyolefin oligomeric saturated
hydrocarbons (POSH)?
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Product Safety and Regulatory Affairs (PSRA)

Toxicological and Regulatory

Assessment Questionnaire (TRAQ)
If yes, please specify substance(s), wt % and indicate the
products meets the benchmark levels specified in the
“German LAV-BLL Opinion (April 2019):
“Orientierungswerte für Mineralölkohlenwasserstoffe
(MOH) in Lebensmitteln”.

35. Does the product contain Dioxins or Furanes?

If yes, please specify substance(s), level(s) and indicate if the
product meets the requirements of the German “Dioxine Yes☐ No☐
Ordinance” (Chemikalienverbotsverordnung) Annex 1,
No.2 and the (EU) No. 1259/2011 requirements.

36. Does the product contain any of the following

substances? If yes, please specify substance(s) and level(s),
added or residual.
▪ Alkyl phenols (AP), alkyl phenol ethoxylates Yes☐ No☐
(APEO), alkylphenol phosphites and other
alkylphenols derivatives
▪ Hexachlorobenzene (CAS 118-74-1) Yes☐ No☐
▪ 4-Nitrobiphenyl (CAS 92-93-3) Yes☐ No☐
▪ Triarylmethane “fanal” pigments Yes☐ No☐
▪ Acetylacetone (CAS 123-54-6) releasing substances, Yes☐ No☐
such as Titanium Acetylacetonate (CAS 17927-72-3)

37. Does the product contain any of the following

substances? If yes, please specify substance(s) and level(s),
added or residual.
▪ Phthalates Yes☐ No☐
▪ Bisphenols Yes☐ No☐
▪ Nitrosamines Yes☐ No☐
▪ Azo dyes Yes☐ No☐
▪ Diarylide pigments Yes☐ No☐
▪ Halogenated organic compounds, including bromi- Yes☐ No☐
nated (i.e. PBB, PBDE) or (per)fluorinated
substances (i.e. PTFE, PFOA, PFCA, PFOA, PFOS
and others)

38. Does the product contain any of the following materials?

If yes, please specify.
▪ Microplastics defined as materials consisting of solid Yes☐ No☐
polymer containing particles, to which additives or other
substances may have been added, and where ≥ 1% w/w
of particles have (i) all dimensions 1nm ≤ x ≤ 5mm, or (ii),
for fibres, a length of 3nm ≤ x ≤ 15mm and length to
diameter ratio of >3.
▪ Microbeads defined as a microplastic used in a mixture Yes☐ No☐
as an abrasive, i.e.to exfoliate, polish or clean.
39. Does the product contain recycled materials per EC No.
282-2008? If yes, comment if the product is compliant. Yes☐ No☐

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Product Safety and Regulatory Affairs (PSRA)

Toxicological and Regulatory

Assessment Questionnaire (TRAQ)
40. Does the product contain allergens, as listed in
1169/2011 Annex II? If yes, please specify. Yes☐ No☐

41. Does the product contain any materials of the following

origins? If yes, please substance(s) and level(s).
▪ Animal origin (e.g. animal fats, oils and/ or gelatin Yes☐ No☐
▪ Human origin (e.g. L-cysteine) Yes☐ No☐
▪ Insect origin (e.g. shellac resin) Yes☐ No☐
▪ GMO origin Yes☐ No☐
▪ Bio-based origin (i.e. derived from plants and other Yes☐ No☐
renewable agricultural, marine and forestry materials.

42. Does the product contain any of the following

substances? If yes, please specify substance(s) and level(s),
added or residual.
▪ Endocrine, or suspected endocrine substances, as Yes☐ No☐
listed in the following Endocrine Disruptor lists
(https://edlists.org/)
▪ Carcinogenic, mutagenic, or repro-toxic (CMR) Yes☐ No☐
substances as classified by EU CLP or GHS (Category
1A, 1B, or 2)
▪ Very Persistent / very Bio-accumulative (vPvB), Yes☐ No☐
Persistent Bio-accumulative and Toxic (PBT), or
potential PBT

43. Does the product contain any substances listed on the

“Substitute It Now” (SIN) List? If yes, please specify Yes☐ No☐
substance(s) and level(s).

North America

Comments
If applicable, please specify chemical
Address and comment as needed. name, CAS no., concentration and
origin (e.g. impurity, deliberately added
or residual.
44. Complies with 21 CFR 175.300 (resinous and polymeric
coatings)? List all restrictions. Yes☐ No☐

45. Complies with 21 CFR 175.105 (adhesives)? List all

restrictions. Yes☐ No☐

46. Complies with 21 CFR 176.170 and 176.180 (paper and

paperboard)? List all restrictions. Yes☐ No☐

47. Contains components cleared for use via other CFR

section? If ‘yes’, provide section and details. Yes☐ No☐

48. Contains components cleared for use via GRAS? If ‘yes’,

Yes☐ No☐
provide section and details.

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Product Safety and Regulatory Affairs (PSRA)

Toxicological and Regulatory

Assessment Questionnaire (TRAQ)
49. Contains components cleared for use via FCN? If ‘yes’,
specify FCN number and details. Yes☐ No☐

50. Contains a catalyst or other material cleared under the

Basic Resin Doctrine? If ‘yes’, provide wt% and justify. Yes☐ No☐

51. Does the product comply with CONEG heavy metals

regulation? Yes☐ No☐

China

Comments
If applicable, please specify chemical
Address and comment as needed. name, CAS no., concentration and
origin (e.g. impurity, deliberately added
or residual.
52. Deleted Yes☐ No☐
53. Does the product comply with GB9685-2016 and are all
components listed in Annex A.2 for coating application?
Yes☐ No☐
If yes, please specify the restriction limits.

54. Does the product comply with GB4806. 10-2016? Are the
resins listed in Annex A? If yes, please specify the restriction
Yes☐ No☐
limits.

55. Do you intend to submit a dossier to the National Health

and Family Planning Commission? Yes☐ No☐

Mercosur & Brazil Food Contact

Comments

If applicable, please specify chemical

Address and comment as needed.
name, CAS no., concentration and origin
(e.g. impurity, deliberately added or
residual.

56. Does the product comply with Brazilian Resolution No

91 of May 11th, 2001 General Criteria and Classification of Yes☐ No☐
Materials for Equipment and Packages in contact with
Foodstuff.
57. Does the product comply with Brazilian Resolution No
105 of May 19th, 1999 and amendments (RDC 17and Yes☐ No☐
RDC 56)? List all restrictions in comments.
58. Product is, or contains a colorant? If ‘yes’, comment if
the product is compliant with Brazilian RDC Resolution Yes☐ No☐
No 52/2010.

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Product Safety and Regulatory Affairs (PSRA)

Toxicological and Regulatory

Assessment Questionnaire (TRAQ)
59. Does the product comply with Brazilian RDC
Resolution No 51/2010 Mercosur Technical Regulation on Yes☐ No☐
Migration in Plastic Materials, Packaging and Articles
Coming into Contact with Foodstuff?
60. Does the product comply with MERCOSUR/GMC/RES
Nº 03/92 General Criteria for Packages and Equipment in Yes☐ No☐
Contact with Foodstuff?
61. Does the product comply with MERCOSUR/GMC/RES
Nº 56/92 General Provisions for Packages and Equipment Yes☐ No☐
Plastics in Contact with Foodstuff?
62. Does the product comply with MERCOSUR/GMC/RES.
Nº 32/07 (* and amendments)? List all restrictions in Yes☐ No☐
comments.
63. Product is, or contains a colorant? If ‘yes’, comment if
the product is compliant with MERCOSUR/GMC/RES. Nº Yes☐ No☐
15/10.
64. Does the product comply with MERCOSUR/GMC/RES.
N° 32/10 Mercosur Technical Regulations on Migration in Yes☐ No☐
Materials, Packages and Plastic Equipment Coming into
Contact with Foodstuff?
65. Does the product contain recycled materials? If ‘yes’,
comment if the product is compliant with Brazilian RDC Yes☐ No☐
Resolution No 20 / MERCOSUR/GMC/RES. Nº 30/07.

Japan

Comments

Address and comment as needed. If applicable, please specify chemical name,

CAS no., concentration and origin (e.g.
impurity, deliberately added or residual.

66. Are the components of the product or the product itself

listed in the Japan Positive List )? Yes☐ No☐

67. Do you intend to submit, or has a dossier been submitted

to the Japanese Authorities to support this product? Are
you willing to participate in a Common Interest Group? Yes☐ No☐
Please comment.

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Product Safety and Regulatory Affairs (PSRA)

Toxicological and Regulatory

Assessment Questionnaire (TRAQ)
SECTION 5 - Electronic Consumer Products market:

List all Chlorinated components in the substance/mixture

Name CAS number Weight %

Not intentionally added

List all Nickel & Nickel components in the substance/mixture

Name CAS number Weight %

Not intentionally added

List all Cobalt & Cobalt components in the substance/mixture

Name CAS number Weight %

Not intentionally added

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