Release Date: September 30, 2013
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RSL Task Force
Peer Review Group
Glossary of Terms
This Restricted Substance List (RSL) was created by a special working group of the American Apparel & Footwear Association's (AAFA) Environmental Task Force. The RSL is intended to provide apparel and footwear companies with information related to regulations and laws that restrict or ban certain chemicals and substances in finished home textile, apparel, and footwear products around the world.
It is our hope that this RSL will serve as a practical tool to help those individuals in textile, apparel and footwear companies, andtheir suppliers, responsible for environmental compliance throughout the supply chain, to become more aware of various national regulations governing the amount of substances that are permitted in finished home textile, apparel and footwear products.
Our effort is to create a dynamic and useful instrument. The RSL will be updated on a regular basis and will be supplemented with additional resources to help officials in these companies undertake responsible chemical management practices in the aforementioned finished products.
Note on Release 13 – September 2013:
A list of changes from Release 12 - March 2013 to Release 13- September 2013 is contained at the end of this document, beginning on page 62.
For more information or questions on the AAFA RSL please contact Danielle Abdul at 703-797-9039.
The RSL includes only those materials, chemicals, and substances that are restricted or banned in finished home textile, apparel and footwear products because of a regulation or law. In each case, the RSL identifies the most restrictive regulation.
The RSL does not include regulations that restrict the use of substances in production processes or in the factory; rather the focus is on whether or not the substance can be found in finished home textile, apparel, and footwear products at a certain level.
For each substance the RSL identifies the following features:
Common chemical or color name
Information on the Restriction/Limit on Final Product or Tested Component
Country where that Restriction/Limit is found
Test Method (where no test method is stipulated in the regulation, the GAFTI column may suggest one)
Other countries that maintain equal or less restrictions
Comments (if applicable)
B. What is Included and What is Not
The RSL is not intended to address product safety regulations outside the chemical management area – such as Consumer Product Safety Commission (CPSC) regulations related to small parts. Moreover, it is not structured to cover toys, automotive textiles, or other industrial textiles. This list does not include restrictions related to use of substances in packaging or related materials.
The following legislation is not listed because there are not regulatory concentration limits but may warrant evaluation for applicability.
The US EPA, following the Montreal Protocols, promulgated legislation on ozone depleting compounds. Class I and Class II listed chemicals used in the process of manufacturing of product or packaging requires special labeling as detailed in the regulation. Residuals of the chemical components in the product or package are not necessary to trigger the requirement. Minor usage in textiles as a spot cleaner is acceptable.
California Proposition 65 requires a “clear and reasonable” warning label for all products sold in the state of California containing one or more chemicals known to the state to cause cancer or reproductive toxicity. Labeling requirements AAFA Restricted Substance List (RSL) 5 Version Date: March 2013 are dependent on consumer exposure to the chemical (measured in micrograms (μg)/day) not the concentration in the product. To comply with the law, manufacturers must either ensure that consumer exposure to regulated chemicals in their products do not exceed the established safe harbor levels or label their products. For more information on California Proposition 65, please visit our website at https://www.wewear.org/aafa-on-the-issues/category/?CategoryId=82.
For more information on other non-regulated chemicals AAFA has developed a separate tool based on the work done by the AFIRM group. This tool can be found on our website (https://www.wewear.org/assets/1/7/103112NonRegulatedRSL.pdf) and includes chemicals that are neither regulated nor proven to be dangerous, but may be of note to the industry.
Chemical nomenclature can take several forms. Technical chemical names may take numerous forms. It is the responsibility of the user to verify synonyms of any regulated chemicals referenced.
It is possible that regulated components may be present in raw materials below the levels that require reporting on Material Safety Data Sheets (MSDS). Care should be taken to verify the presence of all regulated ingredients regardless of the concentration.
This list represents the known and applicable standards at the time of publication; any inaccuracy or omission is not the responsibility of AAFA.
Test methods noted in blue are the GAFTI recommended test methods.
D. GAFTI Comments
The members of the Global Apparel, Footwear and Textile Initiative (GAFTI) have collaboratively produced recommended test methods for certain chemicals in cases where the test method is not stipulated by the regulation. This is an ongoing process, and test methods will continue to be added in subsequent releases of the RSL.
Global Apparel, Footwear and Textile Initiative is an initiative to bring retailers, brands, mills and factories together to improve efficiencies and set standards globally.
Because there is no single source of standards, there is a lack of standardization in the apparel, textile, and footwear industry. This gap creates conflicting requirements across customers.
GAFTI’s goal is to reduce complexity and remove costs from common industry practices and prevent increased scrutiny from press and governments, which could lead to increased regulation.
For more information see: www.GAFTI.org
Representing more than 1,000 world famous name brands, the American Apparel & Footwear Association (AAFA) is the trusted public policy and political voice of the apparel and footwear industry, its management and shareholders, its four million U.S. workers, and its contribution of $350 billion in annual U.S. retail sales.
AAFA stands at the forefront as a leader of positive change for the apparel and footwear industry. With integrity and purpose, AAFA delivers a unified voice on key legislative and regulatory issues. AAFA enables a collaborative forum to promote best practices and innovation. AAFA's comprehensive work ensures the continued success and growth of the apparel and footwear industry, its suppliers, and its customers.
The AAFA gratefully acknowledges the support and contribution of the following individuals and organizations in developing this RSL:
RSL Task Force:
John Eapen, American & Efird, Inc.
Andre Leroy, Avery Dennison Retail Branding Information Systems
Rick Horwitch, Bureau Veritas Consumer Products
Lisa Clerici, Bureau Veritas Consumer Products
Elizabeth Hausler, Bureau Veritas
Rick Horwitch, Bureau Veritas Consumer Products
Tim Mattulke, Bureau Veritas Consumer Products
Brian Eichelberger, PhD, Consumer Testing Laboratories, Inc.
Nate Sponsler, GAP Inc.
Tommy Thompson, Hanesbrands, Inc.
Sam Moore, PhD, Hohenstein Institute America, Inc./Oeko-Tex
Vicky Au, Intertek Testing Services Hong Kong Ltd
Pratik Ichhaporia,Ph.D, Intertek
Seemanta Mitra, Intertek Consumer Goods North America
Andy Kahn, Kahn Lucas Lancaster
John R Gerringer, Modern Testing Services, LLC
Jongsei Park, PhD, Modern Testing Services, LLC
Andy Chen, PhD, Nike Inc.
Manfred Wentz, North Carolina State University
Jeab Pierre Haug, SGS Consumer Testing Services
Sanjeev Gandhi, PhD, SGS Consumer Testing Services
Helmut Krause, PhD, SGS Consumer Testing Services
Meena Kumari, TÜV SÜD
Anne Bonhoff, PhD, UL-STR
Sean Cady, VF Corporation
Harsha Chenna, VF Corporation
Kitty Man, PhD, VF Corporation
Arthur Herold, Webster, Chamberlain & Bean
James Wilson, Webster, Chamberlain & Bean
AAFA also acknowledges the contributions of the following individuals who served as Peer Reviewers of this RSL.
Peer Review Group:
Elizabeth Treanor, AFIRM
Michael Walls, American Chemistry Council
Henry Boyter, Ph.D, Center for Environmentally Sustainable Textile and Apparel Businesses
John Easton, PhD, Dystar, Inc.
Antonio Barberi Ettaro, MODINT
Nick Odom, Springs Industries
Kilian Hochrein, W.L.Gore & Associates, Inc.
Glossary of Terms/Acronyms related to the AAFA RSL list
CAS—Chemical Abstracts Service. CAS Registry Numbers (often referred to as CAS RNs or CAS Numbers) are unique identifiers for chemical substances. CAS is a division of the American Chemical Society. See www.cas.org.
CEN—European Committee for Standardization
CPSC - Consumer Product Safety Commission. Main U.S. government agency responsible for product safety and for enforcement of CPSIA.
CPSIA - Consumer Product Safety Improvement Act
Detection limit—the lowest quantity of a substance that can be distinguished from the absence of that substance (a blank value) within a stated confidence limit
DIN—German Standards Institute (Deutsches Institut für Normung )
Dioxins and Furans—Chemical compounds that are an undesirable by-product in the manufacture of herbicides, disinfectants, and other agents
EEC—European Economic Community
EPA—Environmental Protection Agency (U.S.)
GB—Guo Biao in Chinese which means National Standards
GC-MS—Gas Chromatography/Mass Spectrometer - instrument used to identify components of mixtures or unknown substances - liquids, gases.
ISO—International Organization for Standardization
JIS—Japanese Industrial Standard
LFGB—Lebensmittel-, Bedarfsgegenstände- und Futtermittelgesetzbuch – German Law Book on food, consumer article and feed.
LC-MS—Liquid Chromatography/Mass Spectrometer - instrument used to identify components of mixtures or unknown substances - liquids, gases.
mg/L—milligram per liter.
mg/kg—milligram per kilogram.
MSDS Information—Material Safety Data Sheet Information – this is chemical safety & toxicological information supplied with chemicals
Percent by Mass—also called weight percent or percent by weight, this is the mass of the solute divided by the total mass of the solution and multiplied by 100% (also see ppm)
Pesticide—A chemical agent or substance used for destroying pests
ppm—Parts Per Million. A unit describing concentrations of chemical substances. 1 ppm can also be notated as 1 milligram per kilogram (mg/kg) or 1 microgram per gram (μg/g).
ppb—Parts per Billion. A unit describing concentrations of chemical substances. 1 ppb can also be notated as 1 microgram per kilogram (μg/kg).
REACH - Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals. It entered into force on 1st June 2007. It streamlines and improves the former legislative framework on chemicals of the European Union (EU).
Solvent—A substance in which another substance is dissolved, forming a solution.
Test method – A definitive procedure that produces a test result.
US – United States
μg/cm²/week—microgram per square centimeter per week
μg/g—microgram per gram
μg/kg—microgram per kilogram
μg/m²—microgram per square meter
NOTE: This Restricted Substance List (“RSL”) is provided by the American Apparel & Footwear Association (“AAFA”) for informational purposes only. This list represents the known and applicable standards at the time of publication; any inaccuracy or omission is not the responsibility of AAFA. Determination of whether and/or how to use all or any portion of this RSL is to be made in your sole and absolute discretion. Prior to using this RSL, you should review it with your own legal counsel. No part of this document constitutes legal advice. Use of this RSL is voluntary.
AAFA does not make any representations or warranties with respect to this RSL or its contents. The RSL is provided on an “AS IS” and on an “AS AVAILABLE” basis. AAFA HEREBY DISCLAIMS ALL WARRANTIES OF ANY NATURE, EXPRESS, IMPLIED OR OTHERWISE, OR ARISING FROM TRADE OR CUSTOM, INCLUDING, WITHOUT LIMITATION, ANY IMPLIED WARRANTIES OF MERCHANTABILITY, NONINFRINGEMENT, QUALITY, TITLE, FITNESS FOR A PARTICULAR PURPOSE, COMPLETENESS OR ACCURACY.
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View the AFIRM RSL Toolkit for Suppliers