It is important to test the textiles regularly for the presence of restricted chemicals. As it is not relevant or possible to test for the whole substance content, it would be a good idea to make a test for substances that are in the high-risk group. If you are in doubt of what to test for, you can contact your trade association and they will be able to help you.
The purpose of using negative lists is to avoid that products contain restricted substances and to protect the environment and the customers from these types of substances.
Positive lists can be a help to find alternative substances with less impact on the environment and the customer.
The two central regulations on textile products are REACH and the General Product Safety Directive. PFOS (perfluoroctansulfonat) and its derivates that have been used in impregnating agents as well as certain flame retardants are regulated in the Regulation on persistent organic pollutants. Specific countries may also have few national rules that apply – See “Overview of rules for textiles (in Danish) later in this paragraph”.
The General Product Safety Directive
The General Product Safety Directive (GPSD) demands that consumer articles on the market are safe. A product is safe when there is no unacceptable risk for the consumers, safety and health associated with normal or foreseeable use within the expected lifetime of the products. In addition to the basic requirement to place only safe products on the market, producers must inform consumers of the risks associated with the products they supply. They must take appropriate measures to prevent such risks and be able to trace dangerous products.
REACH is the overall EU chemical legislation that came into effect on 1 June 2007 (REACH regulation 1907/2006).
The purpose of REACH is to reduce the impact of certain chemical substances on human beings and the environment by ensuring that the individual substances are used in a safe way throughout the entire supply chain.
- Annex XIV deals with a list of substances subject to authorization.
- Annex XVII deals with restrictions on the manufacture, placing on the market and use of certain dangerous substances, mixtures and articles.
- The Candidate List is a list of prioritized Substances of Very High Concern meeting the criteria in Article 57 and which are candidates for inclusion in Annex XIV
- The REACH Candidate List is a dynamic list of Substances of Very High Concern (SVHCs)
- Article 33 of REACH applies to all SVHC substances.
The above link guides you to the latest consolidated version (25th of September 2015), however amendments occur.
The Candidate List is a list of Substances of very high concern (SVHCs). When a chemical substance is included in the Candidate List a number of obligations will have to be accepted. These are duties to obtain information and provide information on the substance in the supply chain. Suppliers must provide information to their customers if an article contains a substance listed on the Candidate List in a concentration exceeding 0.1 % weight/weight. The 0.1% threshold for notifying SVHCs in articles applies to “each of the articles incorporated as a component of a complex product” rather than to the entire article. As an example, the button in a garment is an article in itself and therefore the 0.1% threshold is not only valid for the entire garment, but also the button.
A guidance document has been elaborated in co-operation between authorities responsible for REACH in Belgium, Denmark, France, Germany, Norway and Sweden. The document provides practical advice for suppliers of articles on how to carry out their legal duties to inform about contents of chemical substances listed on the so-called Candidate List. Both professional customers and consumers must be provided with such information.
Regulation on persistent organic pollutants
PFOS (perfluoroctansulfonat) and its derivates have been used in impregnating agents in textiles. The Regulation on persistent organic pollutants gives a threshold value for PFOS and derivates on 1 μg/m2 or 0.1 % by weight in coating. Certain flame retardants which can be used in textiles are also regulated in the Regulation on persistent organic pollutants with a threshold of 0.001 % by weight. The chemicals in question are regulated because they are persistent and harmful to health and the environment.
Overview of rules for textiles (in Danish)
The Danish EPA has released a webpage in cooperation with the Danish Safety Technology Authority that provides an overview of the rules and responsibilities with regard to chemicals and product recall for textile products. In addition, physical/mechanical safety of textile products for children is described. The link is in Danish and there are a few national rules on chemical content of textiles which are described in addition to other regulation of chemicals.
Restricted Substance List (RSL)
Many of the large companies choose to make their own negative list of chemicals, which are unwanted in their products. The list of unwanted chemicals – the so-called Restricted Substance List (RSL) contains chemicals that may be restricted through legislations such as REACH, but will often be based on different legislation requirements throughout the world, i.e. the list will represent all legislative requirements from different regions of the world. However, companies may choose voluntarily to include non-legislated chemicals on their RSL because of identified concerns to consumers, environment or the working environment.
In the text below, some examples of RSLs from different companies are listed. The RSL can be used as inspiration for requirements regarding chemicals to suppliers.
IC Group’s RSL is based on their products. It is through the work with the RSL and having internal processes for risk assessment and due diligence, that IC Group complies with REACH and other national legislations and directives of the countries in which the products are sold. They also have limits for other chemicals, which are harmful for the worker safety, the environment and/or the consumer safety.
BESTSELLER has a RSL.
AFIRM is a collaboration between 16 large companies that have come together to make a common RSL. The aim is to have the same values for the content of chemicals and the same testing methods. This RSL list can be helpful for others and will be available to the public.
Nike has a RSL based on the most stringent worldwide legislation. In addition, Nike has voluntarily included substances that may not be legislated but have been identified as hazardous to the worker, consumer or the environment.
AAFA – AMERICAN APPAREL & FOOTWEAR ASSOCIATION
The AAFA RSL was first released in the summer of 2007 and was the first of its kind. The list covers chemicals and other substances whose presence in a product is restricted through a government regulation or law. The list identifies the most restrictive iteration of that regulation worldwide. Every six months, the publication is reviewed, updated, and the latest version is made available for free to the apparel and footwear industry. The AAFA RSL is offered in a variety of languages. The most current English version is always the prevailing document.
Zero Discharge of Hazardous Chemicals Group (ZDHC)
Manufacturing Restricted Substance List (mRSL), i.e. requirements for chemicals in the production instead of RSL, which includes the chemicals present in the textile.
Some chemical manufacturers have now made chemicals that comply with the requirements of the above mRSL. These are:
- Archroma (Clariant)
- Oeko-Tex has drawn up a positive list of flame retardants in textiles.
Studies on chemicals in textiles
English surveys from the Danish EPA
The Danish EPA publishes various surveys about chemicals in textiles including health- and environmental risk assessments. The reports are published both in Danish with an English “Summery and conclusion paragraph” and in English. The surveys give information about content of selected chemicals in textiles and potential associated risks. The chemicals tested have been selected because of special concern. You can search by keywords such as “textile”.
The Danish survey report “Kortlægning af kemiske stoffer i tekstiler” from 2011 provides an overview of groups of chemicals in textiles in addition to functions and effects.
Examples of relevant reports from the Danish EPA:
- Chemical substances in car safety seats and other textile products for children
- Survey of products with nanosized pigments
- Survey of Selected Allergenic, Disperse Dyes in Clothes
- Survey and health and environmental assessments of biocidal active substances in clothing
- Survey, health and environmental assessment of flame retardants in textiles
- Survey and environmental and health assessment of nonylphenol and nonylphenlethoxylates in textiles
- Assessment of nanosilver in textiles on the Danish market.
Report from the Swedish Chemicals Agency
In 2014 the Swedish Chemical Agency published the report “Chemicals in textiles - risk to human health and the environment” which identifies the harmful chemicals that are present in finished textiles.
Information regarding NPEOs in textiles
Nonylphenol ethoxylates (NPEOs) are used in the production of textiles.
NPEOs are regulated in REACH Annex XVII.
Questions and comments about the guideline can be directed to Louise Fredsbo Karlsson (firstname.lastname@example.org) from the Danish Environmental Protection Agency.