What this is
What is a restricted substance compliance record?
What is a restricted substance compliance record?
A record confirming that substances on site, including refrigerants, packaging materials and other chemicals, are checked against the lists that ban or restrict them, and that the obligations attached to the ones still permitted, such as leak checking or reporting, are being met. It is a compliance instrument, not a hazard assessment.
How is this different from a safety data sheet review?
A safety data sheet review confirms a substance's hazard information is current. This record confirms the substance's legal status: whether it is banned, phased down, subject to a reporting duty, or restricted in a particular use such as packaging, regardless of how hazardous it is judged to be.
Who maintains a restricted substance compliance record?
A compliance lead, working with whoever holds the technical detail: refrigeration for phase-down schedules, procurement or packaging for supplier declarations, and the environmental lead for reporting obligations. The record consolidates their inputs rather than being written from one function's knowledge alone.
Scope
When is a restricted substance compliance record required?
This record is a compliance check across several restricted-substance regimes at once. Where a regime has its own dedicated instrument, that instrument should carry the technical detail and this record should hold the compliance conclusion.
Use this template when
- The annual or scheduled review of restricted substance obligations is due
- A new refrigerant, chemical or packaging material is introduced and needs a restriction check before use
- A regulatory change, such as a phase-down step or a new listing, needs to be assessed against what is on site
- Reporting or a supplier declaration request needs a current compliance position to draw on
- A linked record needs this one to exist: links legal register, refrigerants
Do not use it for
- Chemical Substitution Assessment, which is the route for replacing a restricted substance once this record has identified the need, not for identifying restriction itself
- Explosive Atmosphere Zoning Record, which addresses the physical explosion risk of a substance, not its legal restriction status
- Safety Data Sheet Review, which confirms hazard information is current rather than confirming legal permissibility
- A refrigerant leak log or F-gas equipment register, which should hold the technical leak-checking detail this record only summarises
- Anything outside KnowEnviro, which belongs in the workspace that owns that process
Compliance mapping
Which ISO 14001 cl.6.1.3 requirements does this satisfy?
Restricted substance obligations sit across several distinct instruments rather than one, and the compliance record's job is to hold the conclusion from each without duplicating its technical detail.
| Clause | Requirement | Where it lands |
|---|---|---|
| Montreal Protocol, Kigali Amendment | Phased reduction in production and consumption of ozone-depleting substances and high-warming-potential HFCs | Refrigerants |
| EU F-Gas Regulation (EU) 517/2014 | Leak checking frequency, record-keeping and phase-down quota for fluorinated greenhouse gases | Refrigerants |
| REACH Regulation (EC) 1907/2006 art.33 and art.57 | Identification and communication of substances of very high concern present in articles above the threshold | Packaging and materials |
| EU Packaging and Packaging Waste Directive 94/62/EC | Restriction of heavy metal concentration in packaging and producer responsibility obligations | Packaging and materials |
| Stockholm Convention on Persistent Organic Pollutants | Elimination or restriction of listed persistent organic pollutants | Other restricted substances |
| EU Biocidal Products Regulation (EU) 528/2012 | Biocidal products and their active substances approved before being made available or used | Other restricted substances |
| ISO 14001 cl.6.1.3 | Determination and evaluation of compliance obligations arising from environmental aspects | Header |
What it does not cover
- Chemical Substitution Assessment, which evaluates a replacement once this record has flagged a substance for removal, rather than establishing restriction status itself.
- Explosive Atmosphere Zoning Record, which addresses physical explosion risk and carries no restriction or reporting content.
- Safety Data Sheet Review, which confirms the hazard information on a data sheet is current, not whether the substance is legally permitted.
- A refrigerant F-gas equipment log, which holds the per-unit leak-checking and charge records this record only summarises.
- The legal register itself, which is the master list of obligations; this record evidences compliance against the subset covering restricted substances.
Global
Restricted Substance Compliance Record requirements by country
Restriction regimes are unusually asymmetric across borders: the EU legislates substance-by-substance in detail, the US relies more on sector-specific rules, and the underlying phase-down commitments are set internationally and then implemented differently everywhere.
REACH (EC) 1907/2006; F-Gas Regulation (EU) 517/2014; Packaging and Packaging Waste Directive 94/62/EC
Substance-specific restriction and reporting duties, updated through a rolling candidate list and periodic recasts.
The candidate list and phase-down schedules change more than once a year, which is why horizon scanning matters more here than the review interval.
Toxic Substances Control Act; EPA Refrigerant Management Program 40 CFR Part 82
Restriction and reporting handled through TSCA for chemicals and a separate EPA programme for refrigerants, rather than one unified substance list.
A substance cleared under TSCA is not automatically clear of refrigerant-specific leak and reporting duties, so both need checking independently.
Montreal Protocol with the Kigali Amendment; Stockholm Convention on Persistent Organic Pollutants
Multilateral treaties setting phase-down and elimination schedules that national law then implements.
The treaty schedule is the earliest signal of an upcoming restriction; waiting for national transposition means finding out after the phase-down has already started.
How to complete it
How to complete a restricted substance compliance record, step by step
The template checks status substance by substance. What makes the record defensible is whether it catches a change before it becomes a finding, and whether it can show its evidence rather than an assertion.
The field asking whether horizon scanning is in place is easy to answer yes to without a process behind it. A defensible record names the source being monitored, whether a candidate list update, a treaty amendment or a supplier notification, and shows when it was last checked.
For packaging composition and restricted substances in purchased articles, the site rarely tests independently and depends on what the supplier states. Recording that declarations are held without retaining them leaves the compliance conclusion unsupported the moment it is questioned.
Leak checking, phase-down quota and record retention for refrigerants are distinct from whether a persistent chemical or packaging additive is restricted. Treating them as one undifferentiated compliance score obscures which specific obligation is actually at risk.
A gap identified here is a live compliance exposure until it reaches the legal register and an owner. A record that closes with open gaps unreflected in the register has documented a problem without connecting it to the mechanism that fixes it.
What auditors find
Most common restricted substance compliance record findings
Findings on this record rarely concern whether a check happened. They concern whether the check kept pace with a regime that moves faster than the record's own review cycle.
| Finding | Clause | What fixes it |
|---|---|---|
| Horizon scanning described as in place with no monitored source or check date named. | ISO 14001 cl.6.1.3 | Name the specific source monitored and the date it was last checked, not just a yes. |
| Supplier declarations referenced but not retained on file. | REACH Regulation (EC) 1907/2006 art.33 | Retain the declaration itself against the substance or article it covers, not a note that one was received. |
| Refrigerant leak checking frequency not matched to the charge size and gas type it applies to. | EU F-Gas Regulation (EU) 517/2014 | Set leak checking frequency from the equipment's actual charge and global warming potential, not a single site-wide interval. |
| Replacement plan for a phased-down refrigerant not documented or not started. | Montreal Protocol, Kigali Amendment | Record a replacement plan with a timeline before the phase-down step it addresses takes effect. |
| Reporting obligation missed or submitted late. | EU Packaging and Packaging Waste Directive 94/62/EC | Calendar reporting deadlines against the obligation they belong to, separately from the annual review date. |
| Compliance gap identified but not reflected in the legal register or given an owner. | ISO 14001 cl.6.1.3 | Raise every open gap in the legal register with an owner and date at the point it is found. |
Case in point
Case in point: the phase-down that arrived on schedule
A cold storage operator maintained a restricted substance record showing its refrigerant inventory as compliant, reviewed annually, with the phase-down schedule marked as understood. The record had been accurate at every review date for three years.
A quota reduction step under the regional F-gas phase-down took effect mid-cycle, cutting the availability of the high-warming-potential refrigerant the site's largest plant used for top-ups. The site had recorded the schedule as understood but had not translated that into a replacement plan with a timeline, so when the quota step landed, sourcing had no substitute lined up and the plant ran on a shrinking supply of ageing refrigerant for months while a replacement was sourced under pressure.
The template
The template, field by field
The form exactly as it installs. Every field, option, score and conditional rule is editable, and the links to other templates come with it.
6 sections
- Reference
- ENV-049
- Archetype
- Record
- Record ID
- RSC-2026-000
- Scoring
- Compliance status
- Direction
- High is good
- Singleton
- Yes
- Basis
- ISO 14001 cl.6.1.3
- Links
- Links Legal register, Refrigerants
- Tags
- Chemicals, Compliance
- Sections
- 6
- Fields
- 43
- Follow up fields
- 3
- Repeating sections
- 0
- Links out
- 3
Header
10 fieldsRecord ID*
Auto sequence. Format RSC-2026-000.
The record's own ID. Other templates point at this value.
Status*
Drives who this goes to next.
- Planned2 pts
- In progress2 pts
- Complete3 pts
- Deferred0 pts
- Open0 pts
- Closed3 pts
- Overdue0 pts
Date and Time*
Completed By*
Site*
Site ID*
Format SITE-000.
Links to FDN-001 Site ID
Period Covered*
Maintained By*
Horizon Scanning In Place*
- Yes3 pts
- Informal1 pt
- No0 pts
Obligations Here Change Faster Than Anywhere Else
Refrigerant phase downs, packaging rules and persistent chemical restrictions all move on short timescales. A register checked yearly is often already out of date.
Refrigerants
6 fieldsRefrigerant Inventory Current*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Phase Down Schedule Understood*
- Yes3 pts
- Partly1 pt
- No0 pts
High Global Warming Potential Gases Identified*
- Yes3 pts
- Partly1 pt
- No0 pts
Replacement Plan Exists*
- Yes3 pts
- Being developed1 pt
- None0 pts
Leak Checking Frequency Compliant*
- Yes3 pts
- Partly1 pt
- No0 pts
Records Retained As Required*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Packaging and materials
6 fieldsPackaging Composition Known*
- Yes3 pts
- Partly1 pt
- No0 pts
Recyclability Assessed*
- Yes3 pts
- Partly1 pt
- No0 pts
Restricted Substances In Packaging Checked*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Producer Responsibility Obligations Met*
- Yes3 pts
- Partly1 pt
- No0 pts
Reporting Submitted On Time*
- Yes3 pts
- Partly1 pt
- No0 pts
Supplier Declarations Held*
- Yes3 pts
- Partly1 pt
- No0 pts
Other restricted substances
6 fieldsPersistent Chemicals Screened*
- Yes3 pts
- Partly1 pt
- No0 pts
Ozone Depleting Substances Eliminated*
- Yes3 pts
- Partly1 pt
- No0 pts
Restricted Cleaning Chemicals Identified*
- Yes3 pts
- Partly1 pt
- No0 pts
Biocide Approvals Current*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Supply Chain Declarations Obtained*
- Yes3 pts
- Partly1 pt
- No0 pts
Changes Tracked And Actioned*
- Yes3 pts
- Partly1 pt
- No0 pts
Related records
1 fieldSubstitution Assessment ID
Where a restricted substance is being replaced.
Links to ENV-048 Assessment ID
Outcome
14 fieldsCompliance Status*
- Compliant3 pts
- Partially compliant1 pt
- Non compliant0 pts
Open Gaps*
Highest Consequence Gap*
- None3 pts
- Reporting1 pt
- Permit0 pts
- Product0 pts
Legal Register Updated*
- Yes3 pts
- No0 pts
Feeds Management Review*
- Yes3 pts
- Partly1 pt
- No0 pts
Next Review Due*
Action Required*
Raise the action record, then enter its reference here.
- No2 pts
- Yes0 pts
Priority
- High0 pts
- Medium1 pt
- Low3 pts
CAPA ID
Format CAPA-2026-00000.
Links to FDN-014 CAPA ID
Action Owner
Compliance Lead*
Signature*
Environmental Lead*
Second Signature*
ENV-049 · record IDs look like RSC-2026-000 · Links Legal register, Refrigerants
Open in KnowellaRun it with agents
From a document you fill in to a programme that runs itself
The compliance conclusion is straightforward to state. What fails is catching a schedule change between review dates and connecting a gap to the register and owner that actually closes it.
Holds the restricted substance record against the legal register and the site's refrigerant and packaging inventories, and flags entries whose status has not been checked recently.
Tracks regulatory change across the restriction regimes this record covers and raises a review when a schedule or listing moves, rather than waiting for the annual date.
Connects packaging composition and producer responsibility findings to the suppliers and materials they trace back to.
Watches horizon-scanning sources and supplier declaration renewals for gaps, and holds every write to the compliance record for approval before it is applied.
This template lives in KnowEnviro — environment and energy. Aspects, permits, waste, emissions, spills and sustainability reporting.
Meet KnowEnviro→Glossary
Restricted Substance Compliance Record definitions and key terms
- Substance of very high concern
- A substance identified under REACH as carcinogenic, persistent, bioaccumulative or otherwise of high concern, triggering communication duties above a concentration threshold in articles.
- Phase-down
- A scheduled reduction in the permitted quantity of a substance, typically a high-warming-potential refrigerant, applied in steps rather than as a single ban.
- Horizon scanning
- Active monitoring of upcoming regulatory change, as distinct from checking current status, so an obligation is caught before it takes effect rather than after.
- Persistent organic pollutant
- A chemical that resists degradation, accumulates in organisms and is restricted or eliminated under the Stockholm Convention and its national implementations.
- Producer responsibility
- An obligation placed on the producer of packaging or product to fund or manage its end-of-life handling, distinct from the restriction on substances within it.
FAQ
Frequently asked questions about restricted substance compliance record
How often should restricted substance status actually be checked?+
Continuously, through horizon scanning, with the annual review as a backstop rather than the primary mechanism. Several of the regimes this record covers change on cycles shorter than a year, and a purely annual check will miss the interval where the change applies.
What counts as adequate evidence for packaging composition?+
A retained supplier declaration naming the substances checked and their concentrations, not a general assurance of compliance. A declaration that does not name what was tested for cannot support a conclusion about a specific restricted substance.
Are refrigerant obligations part of this record or a separate one?+
Both. This record holds the compliance conclusion, inventory currency and phase-down awareness; the detailed leak-checking and charge records belong in dedicated refrigerant logs it should reference rather than reproduce.
What should happen when a substance is newly listed as restricted?+
The gap goes into the legal register immediately with an owner, and a substitution assessment is raised if the substance is still in use. Waiting for the next scheduled review leaves the site non-compliant in the interval.
Who is accountable when a phase-down step is missed?+
The compliance lead for the record's currency, but the replacement plan belongs with whoever operates the equipment affected. Naming the schedule as understood without a named replacement plan owner has identified the risk without assigning it.
Does this record replace a Chemical Substitution Assessment?+
No. It identifies that a substance needs replacing or is approaching restriction; the substitution assessment then evaluates the alternative and what it brings with it. Treating this record as sufficient alone skips the step that manages the change.
Keep going
Related templates and programmes
Industries this is written for
Programmes this belongs to
Used together in Chemical Safety and WHMIS
Spill Report
Records a release of chemical, fuel, oil or wastewater
Spill Response Record
Records what was done to contain, clean up and dispose of a spill
Chemical Substitution Assessment
Assesses whether a hazardous substance can be replaced by something safer, and what the substitute brings with it
Explosive Atmosphere Zoning Record
Records the zoning of areas where flammable dust or vapour can form an explosive atmosphere, and the equipment permitted there
Chemical and Substance Register
Lists every chemical and hazardous substance held on site, with quantity, location and hazard class
Chemical Inventory Record
Records what chemicals are held where, in what quantity and in what container
More in Chemicals and Substances
Chemical Substitution Assessment
Assesses whether a hazardous substance can be replaced by something safer, and what the substitute brings with it
Explosive Atmosphere Zoning Record
Records the zoning of areas where flammable dust or vapour can form an explosive atmosphere, and the equipment permitted there
Written and reviewed by
Siddarth Singh
Founder & Chief Executive Officer, Knowella
Certified Safety Professional and industrial and systems engineer with more than a decade inside food supply chain, freight and manufacturing operations. This page was written against the current text of the standards it cites, not against secondary summaries of them.
- Certified Safety Professional (CSP), Board of Certified Safety Professionals
- MBA, University of Chicago Booth School of Business
- MS and BS, The Ohio State University, Industrial and Systems Engineering
- Six Sigma Black Belt
Sources and last review. Reviewed 16 August 2026 against:
- REACH Regulation (EC) 1907/2006, articles 33 and 57
- EU F-Gas Regulation (EU) 517/2014
- Montreal Protocol on Substances that Deplete the Ozone Layer, Kigali Amendment
- Stockholm Convention on Persistent Organic Pollutants
- EU Packaging and Packaging Waste Directive 94/62/EC
This page is general guidance, not legal advice. Confirm requirements with your jurisdiction’s regulator.