AAFA Publishes 12th Edition of the Restricted Substances List (RSL)
05/09/2013

The American Apparel & Footwear Association (AAFA) published the twelfth edition of the AAFA Restricted Substance List (RSL)(1) in March 2013. The list covers apparel, footwear and home textiles.

Online PR News – 09-May-2013 – 08.05.2013 – The updated Restricted Substances List was reviewed and revised by the AAFA Environmental Committee, the members of the RSL Task Force (including SGS experts) and also the RSL peer review group. The AAFA RSL intends to assist the industry in creating a safer and more sustainable supply chain by providing information on the newest developments in global product safety and chemical management standards.

The latest AAFA Restricted Substances List (RSL) Release 12 was published with the following newly-added items:

• Added regulatory requirement for soluble heavy metals under section “Metals”.
• Added regulatory requirements for N-nitrosamines, pH value, vinyl chloride monomer (VCM) and polycyclic aromatic hydrocarbons (PAH) under section “Misc. Chemicals”.
• Added Appendix III – ARIRM Extra (Non-regulated substances on the AFIRM RSL Guidance which do not otherwise appear in the AAFA RSL).

Further changes to Release 12 from Release 11 are outlined below:

Restricted Substance, Test Method, Limit and Comments Modification

Arylamines
- Added test method EN ISO 17234-1:2010 for Leather (EU).
- Changed test method EN ISO 17234-2 to EN ISO 17234-2:2011 for 4-Aminoazobenzene.
- Changed test method EN 14362-3 to EN 14362-3:2012 for 4-Aminoazobenzene.
- Changed China Regulation GB18401 to GB18401-2010.
- Changed test method Textiles (China) GB/T 17592-2006 to GB/T 17592-2011.
- Changed test method Leather and fur (China) GB/T 19942 to GB/T-19942-2005.
- Added Indonesia (No.72/M-IND/PER/7/2012; SNI 7617:2010); Egypt (ES 7266-4/2011; ES 7322/2011) and Taiwan (CNS 15290; CNS15503 (children products); CNS 8634 (leather casual shoes); CNS 10532 (leather shoes)) to other countries that also regulate Arylamines.

Disperse Dyes
- Added 9 new disperse dyes.
- Added country Egypt and regulation ES 7266-4/2011for added dyes.
- Added test method DIN 54231/ §64 LFGB 82.02-10 for added dyes.

Solvent
- Added restriction limit as ≤20 g/m² for Chlorinated Solvents
- Added country China and regulation GB 21550-2008 (PVC artificial leather) for Chlorinated Solvents
- Added test method GB 21550 Clause 5.5 for Chlorinated Solvents
- Removed EC No. 2037/2000 and added Regulation (EC) No. 1005/2009

Pesticides
- Added restriction limit as prohibited for Hexachlorobenzene, Mirex, and PCTs
- Added Canada as the most restrictive country setting limit Hexachlorobenzene, Mirex, and PCTs
- Added regulation Prohibition of Certain Toxic Substances Regulations 2012 (SOR/2012-285) for Hexachlorobenzene, Mirex, and PCTs
- Added restriction limit as 1mg/kg (textile), less than 1mg/kg (leather) and 5mg/kg (wood in footwear) for Pentachlorophenol (PCP), its salts and compounds
- Added Egypt as the most restrictive country setting limit for Pentachlorophenol (PCP), its salts and compounds
- Added Regulation ES 6535/2008, ES 7322/2011, ES 3571/2006, ES 3572/2006
- Added test method XP-G08 015 (textile), ISO 17070 (leather) and EN/TR 14823 (wood)
- Added Denmark and the Netherlands to other countries that also regulate Pentachlorophenol (PCP), its salts and compounds
- Removed EU Decision 2009/251/EC (0.1ppm) and France (1 year ban) from other countries that also regulate Dimethyl Fumarate
- Added REACH Regulation (EC) No.1907/2006 Annex XVII, limit 0.1mg/kg and Taiwan to other countries that also regulate Dimethyl Fumarate

Fluorinated Greenhouse Gases
- Changed restriction limit from may not be used to prohibited
- Removed Council Directive 2008/842/EC
- Added Regulation (EC) No. 842/2006

Flame Retardants
- Changed restriction limit from may not be used to prohibited for SCCP, PBBs, pentaBDE, octaBDE, TRIS, Bis (2,3-dibromopropyl) phosphate and TEPA
- Removed regulation European Union REACH Regulation (EC) No. 1907/2006 Annex XVII for SCCP
- Added regulation POPs Regulation (EC) No. 850/2004, Annex 1 for SCCP
- Added Canada to the list of countries that also regulate SCCP
- Added to comment: POPs: Articles should not contain SCCPs that were placed on the market after January 10, 2013
- Added Egypt to the list of countries that also regulate Polybrominated biphenyls (PBBs), Tris (2,3-dibromopropyl) phosphate (TRIS) and Tris (1-aziridinyl)-phosphine oxide (TEPA)
- Added regulation European Union POPs Regulation (EC) No. 850/2004, Annex I for Penta-bromodiphenyl ether (pentaBDE)
- Added to comment: “European Union REACH Regulation (EC) No. 1907/2006 Candidate List” for
Tris(2-chloroethyl) phosphate (TCEP)

Metals
- Removed Regulation REACH Annex XVII with restriction limit 100ppm and test method total digestion for Cadmium in textiles, leather, plastics and films, surface coatings and printing
- Added regulation Taiwan CNS 15290 with restriction limit prohibited for Cadmium in textiles, leather, plastics and films, surface coatings and printing
- Added test method Taiwan CNS 4797-2 for Cadmium in textiles, leather, metal parts, plastics and films, surface coatings and printing
- Added Egypt to the list of countries that also regulate Lead in textiles, plastic and film, surface coatings and printing
- Added Egypt and South Korea to the list of countries that also regulate Cadmium in leather, metal parts, plastics and films, surface coating and printing
- Added Taiwan and Egypt to the list of countries that also regulate Chromium (Cr 6+) – hexavalent in leather
- Added Egypt and South Korea to the list of countries that also regulate Lead in metal parts
- Changed test method for Nickel release to EN 1811:2011
- Added Egypt to the list of countries that also regulate Nickel in metal parts

Added Soluble Heavy Metals
- Added restriction limit for Lead 90 mg/kg and Cadmium 75 mg/kg for PVC artificial leather
- Added restriction limit for Antimony 60 mg/kg, Arsenic 25 mg/kg, Barium 1000 mg/kg, Cadmium 75 mg/kg, Chromium 60 mg/kg, Lead 90 mg/kg, Mercury 60 mg/kg and Selenium 500 mg/kg
- Added China as the most restrictive country limiting Lead and Cadmium in PVC artificial leather
- Added regulation GB 21550-2008 for Lead and Cadmium in PVC artificial leather
- Added test method GB 21550 Clause 5.4 for Lead and Cadmium in PVC artificial leather
- Added Egypt and Taiwan as the most restrictive country limiting Antimony, Arsenic, Barium, Cadmium, Chromium, Lead, Mercury, and Selenium
- Added regulation ES 7322/2011 and test method EN 71-3 for Antimony, Arsenic, Barium, Cadmium, Chromium, Lead, Mercury and Selenium
- Added comment: limits on soluble heavy metals apply in Egypt is for children less than 36 months footwear, size 26 and less.
- Added regulation CNS 15503 (children’s product) and test method CNS 4797-2 for Antimony, Arsenic, Barium, Cadmium, Chromium, Lead, Mercury, and Selenium
- Added comment: limits on soluble heavy metals apply in Taiwan is for children products up to age 14

Organotin
- Added restriction limit as prohibited for Tributyltin (TBT)
- Removed regulation Japanese law for the control of household products containing harmful substances (Law no.112)
- Removed test method performance-based method of ethanol extraction derivatization and analysis by GC-MS or LC-MS ISO 17353-2005 (industry practice – not specified by the regulation)
- Added Canada as the most restrictive country limiting Tributyltin (TBT)
- Added regulation Prohibition of Certain Substances Regulation, 2012 (SOR/2012-285)
- Added Japan and the EU to the list of other countries that also regulate Tributyltin (TBT)
- Added comment: European Union, all tri-substituted organotin are restricted
- Added comment: Taiwan test method: NIEA T504.30B
- Added restriction limit for EU as 0.1% by weight of tin on final product for Dibutyltin (DBT)
- Added the EU as the most restrictive country limiting Dibutyltin (DBT)
- Added regulation European Union REACH Regulation (EC) No.1907/2006 Annex XVII for Dibutyltin (DBT) and Dioctyltin (DOT)
- Added by weight of tin to the restriction limit for Dioctyltin (DOT)

Misc. Chemicals
- Added Egypt and Indonesia to countries that also regulate Formaldehyde
- Added restriction limit less than 0.1% for articles (textiles or other coated materials) for Perfluorooctane sulfonate (PFOS)
- Removed regulation European Union REACH Regulation (EC) No 1907/2006 Annex XVII for Perfluorooctane sulfonate (PFOS)
- Added regulation POPs Regulation (EC) No. 850/2004 Annex I for Perfluorooctane sulfonate (PFOS)
- Added Egypt to other countries that also regulate Perfluorooctane sulfonate (PFOS)
- Added Egypt to other countries that also regulate Blue Colorant
- Added comment: “For substances and mixtures only” for Blue Colorant and Nonyl phenol & Nonyl phenolethoxylates

Added N-Nitrosamines
- Added 9 new substances
- Added restriction limit as not detected (detection limit: 0.5 mg/kg) for all Nitrosamines
- Added China as the most restrictive country limiting Nitrosamines
- Added regulation GB 25036-2010 and GB 25038-2010 for Nitrosamines
- Added test method GB/T 24153 for Nitrosamines

Added pH Value
- Added China, South Korea and Egypt as the countries setting the most restrictive limit for pH value
- Added 4.0-7.5 as maximum limit for (0-36 months); 4.0-8.5 as maximum limit for (direct skin contact) and 4.0-9.0 as maximum limit for (without direct skin contact) for China
- Added 4.0-7.5 as maximum limit for (infant, children, innerwear, midwear) and 4.0-9.0 as maximum limit for (outerwear, bedding) for South Korea
- Added not less than 3.5 as maximum limit for Egypt
- Added regulation GB 18401-2010 and test method GB/T 7573 for China
- Added regulation KC Mark and test method KS K ISO 3071/ ISO 3071 for South Korea
- Added regulation ES 6535/2008 and test method ISO 4045 for Egypt

Added Vinyl Chloride Monomer (VCM)
- Added restriction limit as 1mg/kg
- Added Egypt as country setting the most restrictive limit for Vinyl Chloride Monomer (VCM)
- Added regulation ES 7322/2011 and test method ISO 6041/ 64 LFGB B.80.32- 1:1981-11/80/766/EC for Vinyl Chloride Monomer (VCM)
- Added China to other countries that also regulate Vinyl Chloride Monomer (VCM)

Added Polycyclic Aromatic Hydrocarbons (PAH)
- Added 18 new substances
- Added restriction limit as 1mg/kg for Benzo(a)pyrene and Sum of 18 PAH as 10mg/kg
- Added restriction limit as 1mg/kg (each) for Polycyclic aromatic hydrocarbons (PAH)
- Added Taiwan and European Union as country setting the most restrictive limit for Polycyclic aromatic hydrocarbons (PAH)
- Added regulation CNS 3478 (Plastic shoes) and CNS 11503 (children products) (up to age 14) and test method CNS 3478 Clause 6.18 for Polycyclic aromatic hydrocarbons (PAH)
- Added regulation: draft regulation amending European Union REACH regulation (EC) No 1907/2006 Annex XVII

Phthalates
- Added restriction limit for U.S. each phthalates 0.1%
- Added restriction limit for EU 0.1% for DEHP+DBP+BBP and 0.1% for DINP+ DIDP+DNOP
- Added EU as country with most restrictive limit on phthalates
- Changes test method CPSC-CH-C1001-09 to CPSC-CH-C1001-09.3
- Added test method GB/T 22048-2008 as alternative
- Added Egypt, Turkey and Denmark to other countries that also regulate phthalates
- Added 8 new phthalates
- Added restriction limit as 0.1% (sum) for Dimethyl phthalate (DMP), Diethyl phthalate (DEP), Diisobutyl phthalate (DIBP)
- Added restriction limit as 0.1% w/w per article (each) for (DHNUP), (DIHP), (DMEP), (DIPP), (NPIPP), (DPP)
- Added Taiwan as the country setting the most restrictive limit for (DMP) and (DEP)
- Added regulation CNS 15503 (children's products) for (DMP) and (DEP)
- Added Denmark as the country setting the most restrictive limit for (DIBP)
- Added regulation Executive Order 1113 of 26 October 2012 for (DIBP)
- Added EU as the country setting the most restrictive limit for (DHNUP), (DIHP), (DMEP), (DIPP), (NPIPP), (DPP)
- Added regulation “European Union REACH Regulation (EC) no.1907/2006 Candidate List” for (DHNUP), (DIHP), (DMEP), (DIPP), (NPIPP), (DPP)

Appendix III – AFIRM Extra
- Newly added appendix
- This appendix lists those non-regulated substances on the AFIRM RSL Guidance which do not otherwise appear in the AAFA RSL

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Reference:
1. AAFA Release 12 – https://www.wewear.org/assets/1/7/RSL12english-March2013.pdf

Should you require more information on the AAFA Restricted Substance List, please contact the SGS experts.
Contact details:

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t.: +852 27747492
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