9.1 Material Restrictions (X01) & Enhanced Material Restrictions (X05)

9.1 Material Restrictions (X01) & Enhanced Material Restrictions (X05)

Core Exam Takeaway: Materials has three preconditions (X01, X02, X03) and eight optimizations (X04–X11), and carries 9 scored exam questions. X01 Material Restrictions restricts exactly three substances in newly installed products — asbestos, mercury, lead. X05 Enhanced Material Restrictions (2 pt) adds HFRs, PFAS, orthophthalates, cadmium at 100 ppm, across 50% by cost, minimum 10 distinct products. There is also a beta feature X12 Contact Reduction, which is not assessable.

The concept's two halves

Materials divides cleanly, and knowing which half a feature sits in prevents most numbering errors:

The "newly installed products" scoping rule

This is essential to X01 and X05 and is stated in WELL's general guidance: the requirements of some features apply to products installed after project registration. Two consequences:

• Preconditions have no minimum scope. A project that installs no lamps or electronics is considered in compliance with X01's relevant parts. Nothing must be ripped out.
• Optimizations do have minimum scope. X05 requires at least 10 distinct products within the category before the percentage test even applies — which stops a project from claiming the point on the strength of two chairs.

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Feature X01: Material Restrictions — Precondition

Intent: reduce or eliminate human exposure to building materials known to be hazardous.

X01 Part 1 — Restrict Asbestos

For newly installed or applied products within the project boundary: the following nine product categories do not contain over 1,000 ppm of asbestos by weight or area:

1. Thermal protection, including all insulation (lagging) applied to pipes, fittings, boilers, tanks and ducts
2. Acoustic treatments
3. Sheathing
4. Roofing and siding
5. Fire and smoke protection
6. Joint protection
7. Plaster and gypsum board
8. Ceilings
9. Resilient flooring

X01 Part 2 — Restrict Mercury

• (a) Newly installed fluorescent and sodium lamps, if present, meet RoHS restrictions or these limits:

• (b) Newly installed fire alarms, meters, sensors, relays, thermostats and load break switches meet RoHS restrictions or contain no more than 0.1% (1,000 ppm) mercury by weight.

X01 Part 3 — Restrict Lead

Option 1: Paints and electronics

• (a) The same device list — fire alarms, meters, sensors, relays, thermostats, load break switches — meets RoHS or contains no more than 0.01% (100 ppm) lead by weight.
• (b) Newly installed paints applied as finishes meet at least one of:
  1. Lead concentration of 100 ppm (0.01%) by weight or below
  2. No added lead carbonates and lead sulfates
  3. Deemed free of lead or with no added lead by an ISO 14024-compliant (Type 1) Ecolabel, or a voluntary third-party certification recognized by local government
  4. Paints meet Feature X08: Materials Optimization

Option 2: Drinking water pipes, fittings and solder — newly installed or applied pipes, fixtures, fittings and solder intended for drinking water distribution.

WELL Core guidance for all parts: extent of developer buildout.

+-----------------------------------------------------------------------------+
|            X01: THREE SUBSTANCES, THREE DIFFERENT THRESHOLDS                |
|                                                                             |
|   ASBESTOS    1,000 ppm by weight or area, in 9 named product categories     |
|   MERCURY     0.1% = 1,000 ppm by weight, in electrical devices              |
|               (plus a per-lamp-type milligram table)                         |
|   LEAD        0.01% = 100 ppm by weight, in electrical devices AND paints     |
|                                                                             |
|   Note the ten-fold difference between the MERCURY device limit (1,000 ppm)  |
|   and the LEAD device limit (100 ppm) for the SAME device list. Lead is      |
|   held to the stricter number.                                              |
+-----------------------------------------------------------------------------+

[!IMPORTANT] The same six devices appear in both Part 2 and Part 3 — fire alarms, meters, sensors, relays, thermostats and load break switches — but the thresholds differ by a factor of ten: 0.1% (1,000 ppm) for mercury, 0.01% (100 ppm) for lead. Both parts accept RoHS compliance as a shortcut, which is why specifying RoHS-compliant devices satisfies the whole of X01 Parts 2(b) and 3(a) in one stroke.

[!TIP] X01 Part 3(b)(4) is a cross-reference worth noticing: a paint that meets X08 Materials Optimization automatically satisfies the lead criterion. WELL builds these shortcuts deliberately — a product screened against the Living Building Challenge Red List or the Cradle to Cradle Restricted Substances List has already been screened for lead.

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Feature X05: Enhanced Material Restrictions — Optimization (2 pt / WELL Core 2 pt)

Intent: minimize exposure to certain chemicals by limiting their presence in products.

X05 Part 1 — Select Compliant Interior Furnishings (1 pt / Core 1 pt)

Option 1: Furniture, millwork and fixtures. At least 50% by cost of newly installed furniture, millwork and fixtures (minimum 10 distinct products, as defined in Appendix X1) meet one of:

• (a) Textiles (fabrics including upholstery) and plastics contain 100 ppm (0.01%) by weight or less of these five compound classes, unless higher amounts are mandated by local codes:

  1. Halogenated flame retardants (HFR)
  2. Per- and polyfluoroalkyl substances (PFAS)
  3. Lead
  4. Cadmium
  5. Mercury

  For assessing compliance, all pieces of each of the two material categories (textiles, plastics) are grouped together and each is assessed independently against the 100 ppm threshold.

• (b) The products do not contain textiles and plastic at all.

Option 2: Electrical and electronic products. All newly installed electrical and electronic products specified in Appendix X1 are compliant with RoHS restrictions.

X05 Part 2 — Select Compliant Architectural and Interior Products (1 pt / Core 1 pt)

At least 50% by cost of newly installed products in the classes below (minimum 10 distinct products), meet these 100 ppm (0.01%) by weight limits, unless higher amounts are mandated by local code:

WELL Core guidance for both parts: extent of developer buildout.

[!IMPORTANT] Memorize the pattern, not each cell. HFRs appear in all four product classes because flame-retardant treatment is ubiquitous in flooring, insulation and panels. Orthophthalates appear wherever flexible PVC does — flooring, panels, plastic plumbing — because they are the plasticizers that make PVC flexible. PFAS appear where stain and water repellency is sold — textiles and flooring. Reasoning from function gets you the right answer faster than rote recall.

Why these four chemical classes

Note that all four classes share a dust pathway: they are not strongly volatile, so they leave products as semi-volatile compounds and particulate that settle into dust and are ingested or absorbed dermally — especially by crawling children. That is why WELL restricts them in products rather than setting an air concentration threshold as it does for VOCs in A01 and X06.

[!TIP] "50% by cost" and "minimum 10 distinct products" travel together throughout X05, X06 Part 2, X07 and X08. Cost-weighting stops a project from satisfying the requirement with cheap trivia while installing an expensive non-compliant floor; the product-count floor stops a tiny project from claiming a materials point on almost no material at all.