RESTRICTED SUBSTANCES
IN CONSUMER GOODS
(WITH SP. REFERNCE TO TEXTILES & APPARELS)
Neyamul Hasan
Intertek Consumer Goods
Bangladesh
24 Nov-2012
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RSL
RSL means the Restricted Substances List
Chemicals that are health hazards
- Carcinogenic
- Toxics
- Sensitizing – allergenic
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Common List of Restricted Substances
Allergenic Disperse Dyes
Azo Dyes
Heavy metal content
 Nickel Release
 Cadmium
 Chromium VI
 Lead
 Formaldehyde
 Phenol content
Dimethyl Fumarate (DMF)
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Carcinogenic dyes Dyes
 Phthalates
Triclosan
 PCBs
APEOs
Pesticide
Flame Retardant
Organotin compounds
COC
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RS - Azo
Azo dyes (which degrade to form one of the carcinogenic amines listed on the
restricted substance list)
Description:
Azo dyes incorporate one or several azo groups (-N=N-)
bound with aromatic compounds. Thousands of azo dyes
exist, however, only those which can degrade to form the
listed amines are restricted.
Maximum permissible limit: 30 mg/kg in finished articles or in dyed
parts
Where they
In textiles and apparel, azo dyes (which may degrade to form
may be found: 22 listed amines) may be found in dyed fiber or leather.
Toxicity
4
Amines are Considered as Carcinogenic
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RS - Azo
Allergy from textile dyes in Leg & Abdomen
area
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RS - APEOs
APEO/AP (Alkyphenol Ethoxylates/Alkylphenols)
Description:
NPEOs/OPEOs are included in the group of non-ionic surfactants
called alkylphenol ethoxylates (APEOs). NPEOs and OPEOs can
degrade to NP and OP respectively.
Maximum limit: 0.1 % in preparations
Where they
may be
found:
APEOs are used in detergents, scouring agents, wetting agents,
softeners, emulsifier/dispersing agents for dyes and prints.
In leather tanning, APEO is used in de-greasing, finishing etc.
In silk production for de-gumming. APEO could also be present in
dyes and pigment preparations..
Toxicity
APEO can cause cancer, disrupt hormone system and reduce fertility.
Important
Info
Our statistical data says: SILK is the most potential groups of
fiber where APEOs get fail very frequently.
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RS – Disperse Dyes
Sensitizing Disperse Dyes
Description:
Disperse dyes is a group of dyes generally used to dye
synthetic fiber, eg, Polyester.
Maximum permissible limit: Not detected (<5 mg/l)
Where they
may be
found:
Disperse dyes are used to dye synthetic or manufactured
fibers (polyester, acetate, and polyamide).
Other Dyes:
Navy Blue or Blue colorant as a dye mixture also kind of
disperse dyes.
Toxicity
Some of Disperse dyes suspected to cause allergic
reactions.
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RS - Formaldehyde
Formaldehyde
Description: Formaldehyde is a volatile compound used
widely in apparel and textile manufacturing
as an anti-creasing and an anti-shrinking agent.
In addition, formaldehyde is often used in polymeric
resins (e.g. phenol-formaldehyde and urea-formaldehyde).
Maximum permissible limits 20 ppm 0-36 months,
75 ppm for Adult
Where it
may be
found:
In apparel and textiles, formaldehyde could be found in artificially
stiffened fabric. Since formaldehyde is volatile, cross contamination of
material may occur.
Toxicity
It is an irritant to eyes, nose, lung and may cause allergic reactions.
Suspected carcinogen.
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RS - Phenols
Pentachlorophenol (PCP)
Description:
PCP is a polychlorinated compound used as a
preservative to wood, leather, and textiles (Natural Fiber).
Where it may be
found:
PCP has been used as an antifungal in textiles,
leather, and some wood products. Specially during
storing & Transportation PCP is used as insect killer.
Regulation/Direc
tive
/Legislation
Legislation - 91/73/EEC prohibits the marketing and
use of PCP and its salts and esters in substances or
preparations in a concentration equal to or greater
than 0,1 % by mass.
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RS – Organotin
Organotin Compounds
Description:
Organotins are a class of chemicals combining tin and organics
such as butyl and phenyl groups.
Where they
may be
found:
In textiles and apparel, organotins may be associated with
plastics, inks, paints, and heat transfer material. Mostly they used
as antifoulants in paints, but they can also be used as biocides
(antibacterials) and / or heat stabilizer in plastics
Toxicity
3 Listed Organotin (i.e. Monobutyl tin trichloride, Tetrabutyl tin,
Monoheptyl tin trichloride)
Suspected to be endocrine disrupters
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RS - PVC
Polyvinyl chloride (PVC)
Description:
PVC (also known as vinyl) is a chlorinated polymer used
extensively. Generally, PVC is used for soft plastic
accessories like badges or zip pullers, as coating on
textiles for rainwear, as prints etc.
Limit: Not detected in toys and products intended to be in
mouth
Where it may
be found:
PVC can be found in plastic items and trim in apparel and
textiles. In addition, PVC can often be found in screen
prints and inks.
Toxicity
Environmentally persistent, and their manufacture and
disposal often results in highly toxic wastes (e.g.
DIOXINS)
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RS - Phthalates
Phthalates
Description:
Colorless, odorless liquids which are used as
“plasticizers”
Soften the polyvinyl chloride plastic (PVC), Rubber
products, paints, printing inks, adhesives, lubricants
and some Cosmetics.
Where they may be found: In textiles and apparel, phthalates may be associated
with flexible plastic components, trims and screen
prints.
Toxicity
6 Listed Phthalates
Very low volatility, do not readily dissolve in water and
are persistent in the environment
They are suspected to be carcinogenic and to disturb
the hormone system
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RS - Nickel
Nickel
Description:
Nickel is an abundant metal often combined with
other metals to create alloys with increased hardness
and resistance to corrosion.
Where it may be found:
In textiles and apparel, nickel may be associated is
mostly with metal accessories. Very rarely could be
found in clothing, paints, inks, trims and plastics.
Toxicity
It can cause allergenic reaction to human beings
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Effect of Nickel Poisoning
Earring containing Nickel and
dermal effects observed
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RS - Lead
Lead is one of the potential risky & common RS in the field of CG
Lead
Description:
Lead is a naturally occurring metal important to the
production of batteries, fuels, paints, plastics (as a heat
stabilizer), ceramics and solders.
Where it
may be
found:
In textiles and apparel, lead may be associated with plastics,
paints, inks, pigments, and metal components.
Toxicity
Lead can affect the central nervous system (particular
children) and can damage the kidneys and immune system
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Adverse effect of Lead to Human
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Adverse effect of Lead to Human
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Adverse effect of Lead to Human
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RS - Cadmium
Cadmium
Description:
Cadmium is a naturally occurring and abundant metal
that does not easily corrode (rust).
Maximum permissible limit: 100 mg/kg
Where it may be found:
In textiles and apparel, cadmium may be associated
with plastics, pigments (particularly red, orange,
yellow, and green), and as a surface layer for metals.
Toxicity
In like other Heavy Metals Cadmium also
anticipated to be carcinogens .
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RS – Chromium VI
Chromium VI
Description:
Chromium is a kind of metal that can exist in three
main forms (Chromium (0), Chromium (III), and
Chromium (VI). In nature, Cr (III) is the predominate
form, Cr (0) and Cr (VI) do not occur in nature or are
rare.
Where it may be found:
In textiles and apparel, chromium may be associated
with plastics, pigments and mainly in tanned leather.
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Effect of Heavy Metal Poisoning
Arsenic Poisoning
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RS – Dimethyl Fumarate
DMFu (Dimethyl Fumarate)
Description:
DMF is a stable compound classified as irritant and
even harmful for the skin, eyes, mucous membranes
and upper respiratory tracts, by simple contact.
Limit: 1 mg / kg (the lab should have a method
detection limit of < 0.1 mg/kg)
Where it may be found:
This chemical substance is a BIOCIDE and could be
found in Textiles/Apparel, Leather and most likely in
Silica Gel, etc.
Toxicity
Sevier Instant Irritation
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Common RS Requirement (based on current
regulations/legislation) – EU & USA
RS
Azo
Phthalates
Formaldehyde
pH
Lead
PVC
DMFu
Allergenic Disperse
Dyes
Carcinogenic Dyes
Chlorophenols
(PCP/TeCP)
APEOs
Organotin
COCs
Solvents
Crhomium VI
Sol. Heavy Metals,
ASTM F963
Mig. of Heavy Metals,
EN 71-3
Cadmium
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EU Market
Applicability
General
Requirement
√
30 ppm
√
1000 ppm
√
20, 75 ppm
√
Variable
NA
√
ND
√
0.1 ppm
√
1, 5 mg/l
USA Market
Applicability
General
Requirement
NA
√
1000ppm
√
20, 75 ppm
√
variable
√
90/300 ppm
NA
NA
√
√
1, 5 mg/l
1 ppm
NA
NA
√
√
√
√
√
NA
1000 ppm
1 ppm
1, 2 ppm
ND
3 ppm / ND
NA
NA
NA
NA
NA
√
√
Element wise
NA
√
100ppm
√
Element wise
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Major RS Tests requirement - Component/materialwise (For EU Market)
RS
Azo
Phthalates
Formaldehyde
Cadmium
PVC
Al. Disperse Dyes
Carcinogenic Dyes
Chlorophenols
(PCP/TeCP)
APEOs
Organotin
COCs
pH
Crhomium VI
Heavy Metals
Nickel Release
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Natural
Fiber
Synthetic
Fiber
Blend
(Natural +
Synthetic))
√
√
√
√
√
√
Synthetic
Leathers,
Inks,
Thermoplasti
cs,
etc
√
Metals
Leather /
Coated
Leathers
Trims
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
√
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Major RS Tests Requirement - Component/materialwise (For US Market)
RS
Natural
Fiber
Synthetic
Fiber
Blend
(Natural
Synthetic))
Inks, Coating,
Thermoplastics,
etc
Non-Metals
Substrate
√
Phthalates
Formaldehyde
√
√
√
pH
√
√
√
Lead
√
Sol Heavy Metals
√
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Metals
(Children)
√
√
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Common Sources of RS in Textile/Apparel
Industry




Raw Fibre,
Dyes and Chemicals
Ancillary Chemicals
Poor Process control
- Poorly controlled reactions = Risk
- Reactions are controlled by…
- Ratio of reagents, Temperature, pH & Time

Many RSL failures due to non-deliberate application
- Unspecified chemicals in a formulation
- Unlabelled drums in the store
- Unlabelled buckets by the machine
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Sources of RS in Textile/Apparel Industry
PRODUCTION CONTROL
Chemicals
Production
Textile
Final product
Accessories
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Sources of RS in Textile/Apparel Industry
Chemicals inside the products
Dyes
Auxiliaries
Wet processing
Print paste
Pigment
Button
Plastic
Zipper
Metal
Sequin
Accessories
Spinning
Synthetic fibre
Natural fibre
Fibre
Knitting
Oil
Weaving
Size
Final Products
Washing
Detergents
Red color indicates source of Restricted chemicals
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How to avoid RS failure
Very Basic:
Production Control:
- Adequate knowledge on RSL
- Record of chemical products used
- Require necessary information about chemical products
- Follow SOP
All chemicals must have:
- MSDS (Material Safety Data Sheet)
- Compliance declaration to RSL
- Labelled containers
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How to avoid RS failure - Educate the supply chain
Brands are responsible for educating factories on the RSL, and the supplier is responsible for
educating vendors on the RSL as well.
Brands
Factories
Vendors
Other
suppliers
Agents,
traders
Make sure all of your subcontractors, accessory suppliers, dye mills, print mills, tanneries,
chemical suppliers etc. are aware of the brand’s specific RSL restrictions and have the latest
updated version available.
Only do business with RSL compliant companies.
Use and encourage the use of dyestuffs, pigments and textile auxiliaries from reputable
manufacturers.
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How to avoid RS Failure
Risk Assessment:
Technical Managers must risk assess each product to decide if:
- A product needs testing?
- What it needs to be tested for?
When Deciding What to Test
- All new suppliers are deemed high risk and will be subject to a high test frequency in their
first season until a level of confidence is established.
-All suppliers who have historically performed well are deemed as low risk and can only be
subjected to random testing.
All infant, babies, and children’s products are considered high risk
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RSL Failur
Frequent Failure observed in Products Manufactured in Bangladesh
Allergenic Disperse Dyes (mainly in Polyester Dyes)
Azo Dyes
Formaldehyde
SCCP (mainly in leather)
Lead in Paint
 Lead in Metal
Chromium VI (leather)
 Phthalates (soft plastics
APEOs
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One Year Analyzed Data
RS
% Failure
Azo Dyes
4.6%
Disperse Dyes
3.8%
Carcinogenic Dyes
0%
Phthalates
6.8%
Organotin
0.3%
Phenols (PCP/TeCP)
1.6%
COCs
0.37%
Formaldehyde
9%
Lead in Coating
4.3%
Lead in metals
6.0%
Lead in Non-metals
3.7%
APEOs
13%
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Remarks
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Key Regulations in consumer Products
CPSIA
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US CPSIA
• Background
• Key Definitions
• Key Requirements
• CPSIA Reform Bill –
HR 2715
• Recent Activity
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CPSIA – Consumer Product Safety Improvement Act
It is targeted mostly toward "children's
products", which are defined as any
consumer product designed or intended
primarily for children 12 years of age or
younger.
History
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Background - CPSIA
• Signed into Law on August 14, 2008
• Scope: Consumer Products (as defined in CPSA)
• Key Requirements
o Lead and Phthalate Content
o Certification
 General Certificate of Conformity (GCC)
 Children’s Product Certificate (CPC)
o Mandatory Toys standard (ASTM F963)
o Third Party Testing for children’s product
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Key Definitions
“Children’s Product”: a consumer product
designed or intended primarily for children 12
years of age or younger.
“Children’s Toy”: a consumer product designed
or intended by the manufacturer for a child 12
years of age or younger for use by the child
when the child plays.
“Child Care Article”: a consumer product
designed or intended by the manufacturer to
facilitate sleep or the feeding of children age 3
and younger, or to help such children with
sucking or teething.
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Lead Requirements (CPSIA Section 101)
Total Lead in Surface Coating
• Requirement: 90ppm
Total Lead Content (Substrate)
• 14 Aug 2009 – 300ppm
• 14 Aug 2011, 100ppm – HR 2715
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Phthalate Prohibition (CPSIA Section 108)
From February10th, 2009, it became unlawful for anyone to sell:
• Any children’s toy or child care article that contains concentrations of more
than 0.1% of DEHP, DBP or BBP
• Any children’s toy that can be placed in a child’s mouth or child care article that
also contains concentration of more than 0.1% of DINP, DIDP or DnOP
Scope
DEHP
DBP
BBP
DINP DIDP DnOP
Limit
Toys(≤12 years old)
√
√
√
√
√
√
√
√
√
√
√
√
Max.
0.1%
(individual)
Toys(≤12 years old + put in mouth) √
√
Childcare article (≤3 years old)
√
Childcare article (≤3 years old)
√
√
√
√
√
√
Toys that can be placed in the mouth are: toys that can be kept in the mouth by a child so
that it can be sucked or chewed, or toys or parts of toys with one dimension less than 5 cm.
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General Certification of Conformity (sec: 102)
General Certification of
Conformity
Certification based on Third-Party
Testing:




- Stating the product was being
tested in approved Third-party lab
for Certain Tests.
- Products without certificate or
with a false certificate will be
destroyed
Product description
Date of production
Place of production
Place Product was tested
All rules enforceable by CPSC:
(Adult and Children product)
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Third Party Testing Requirement
Third party testing for most of children’s product rules are already in place.
The CPSC published accreditation requirements for 3rd party testing for ASTM
F963 and phthalate content on August 3rd and August 10th – 2011 respectively.
Certification based on 3rd party testing will be required for applicable children’s
products manufactured on and after January 1, 2012:
• Total lead content (Substrate)
• Phthalate content
• ASTM F963
http://www.cpsc.gov/about/cpsia/accredited.html
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CPSIA third party testing – Example Timeline
Rules/Standard/Ban
Non-Children’s
Products GCC
requirement
Children’s Products CPC
based on Third party
Testing requirement
Lead paint on Children’s Products (16 CFR part 1303)
Not Applicable
December 21, 2008
Small Parts (16 CFR part 1501)
Not Applicable
15 February 2009
Lead in Metal components of Chidren’s metal Jewelry (sec
101 of the CPSIA)
Not Applicable
23 March 2009
16 CFR 1500.48 & 49 – Sharp points and sharp edges
Not Applicable
Sept ‘ 2009
Total Lead content in metal children’s products and in
non-metal children’s products (sec 101 of the CPSIA)
Not Applicable
31 Dec’ 2011
Ban on Lead-in-paint in Paint and on Furniture
10 Feb’ 2010
Not Applicable
Flammability of Vinyl Plastic (16 CFR part 1611)
26 Jan’ 2011
19 Oct’ 2010
Flammability on Wearing Apparel (16 CFR 1610)
26 Jan’ 2011
16 Nov’2010
Phthalates (sec 108 of the CPSIA)
Not Applicable
31 Dec’ 2011
Flammability of Children’s Sleepwear (16 CFR part 1615
& 1616)
Not Applicable
17 Feb’ 2011
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Commonly Used Acronyms
GCC = General Certificate of Conformity
CPC = Children’s Product Certificate
COC = Certificate of Conformity
IOR = Importer of Record
DM = Domestic Manufacturer
CPSIA = Consumer Product Safety Act of 2008
HR 2715 = House Resolution 2715 (CPSIA
reform legislation passed in 2011)
CPSC = U.S. Consumer Product Safety
Commission
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Valued Quality. Delivered.
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