Restricted Substance Problem Solution
Prevention Library
Heavy
Metals
Formaldehyde
Aromatic
Amines
Disperse
Dyes
APEO’s
Organotins
Phthalates
Misc.
Problem #1
• Soft hand screen print using discharge
printing technique
• Printer performed a strike off
• Strike off approved for appearance
• Printer could not meet formaldehyde
requirements of the brand because the ink
system used Zinc Formaldehyde Sulfoxylate
(ZFS) catalyst
Formaldehyde
• Discharge ink systems require chemicals to
break down the color of the dyed garment
• Many discharge systems contain
formaldehyde
• Printer worked with ink supplier to optimize
printing concentrations, curing times and
temperatures
• Reduced but did not remove 100% of
formaldehyde in the final prints
• Product could not be used on children’s
garments
Formaldehyde
Problem #1
PREVENTION:
Problem #1
• Printer developed a quality control process to manage print recipes
• Curing times and temperatures kept consistent to meet RSL
requirements for adult products
• Printer looked for a non-formaldehyde
catalyst system for discharge designs.
• Printer and garment factory only show
prototypes to brand that meet RSL
requirements
Formaldehyde
Problem #2
• Urea formaldehyde resins are common
chemicals used in durable press resins
• Resins are used to prevent wrinkles and
stiffen fabrics
• Resin was applied to the backing fabric on
the cap to maintain its shape
• Backing fabric was less than 1% of the
weight of the cap, but the amount of
formaldehyde in the resin exceeded RSL
limits by almost 200%
Formaldehyde
Problem #2
• Caps were not able to ship while solutions and alternatives were
investigated
• Some materials were washed to reduce the formaldehyde
• Some other materials were replaced with alternatives
• No process to control the formaldehyde could be established
• Developed a new material that would meet
performance needs and RSL requirements
Formaldehyde
the
Problem #2
PREVENTION:
• Low level formaldehyde failures were still common in the cap
factories
• Factory had not switched materials for all customers
• Contamination from drying units and
factory air handling units
• Phase out of all formaldehyde containing
chemicals was the only way to guarantee
100% compliance
Formaldehyde
Problem #3
• Urea formaldehyde resins are common
chemicals used in durable press resins
• Resins are used to trap wrinkles and
stiffen fabrics
• Cotton t-shirt designed by brand to have wrinkled effect by
using durable press resin treatment
• Garment had formaldehyde concentration above RSL limit
Formaldehyde
• Wrinkle finish had been cured for
too short a time
• Cure temperature was also too low
• Process changes improved durability
and RSL compliance
• Always follow manufacturer
guidance for process conditions
• Always tell chemical supplier your
compliance needs
Formaldehyde
Problem #3
PREVENTION:
Problem #3
• In some cases a chemical on an RSL can be used
• Conditions must be carefully controlled to manage finished
product compliance
• Work with high quality chemical
suppliers
• Always follow chemical supplier
guidelines
Formaldehyde
Problem #4
• Formaldehyde releasing melamine resin is
commonly used as a crosslinker in pigment
printed garments and will cause
formaldehyde failures
• An alternative approach is to use a blocked diisocyanate
crosslinker which is formaldehyde free
• Isocyanates can be sensitizing and carcinogenic so proper curing
is required
Formaldehyde
Problem #4
• Diisocyanate crosslinker must be fully
cured, used in correct ratios, and dried off
• Printer will have to work with chemical
supplier to develop proper conditions
depending on equipment, temperature, and
humidity
• Measures must be taken to prevent
occupational hazards when utilizing
diisocyanate crosslinkers
Formaldehyde
Problem #4
PREVENTION:
• In this case chemical supplier provided formaldehyde free
option because printer requested it, but printer did not ask if any
new problems were created
• EH&S must also be considered when
utilizing new technologies
• Work closely with suppliers,
technical professionals, and
laboratories when starting new
techniques
Formaldehyde
Problem #5
• Cotton fabric failed children’s
Formaldehyde standard
• Supplier knew that Formaldehyde was
contained in the raw chemicals applied to
the fabric
• Supplier had worked with chemical
supplier to control the concentration
applied to meet Brand’s formaldehyde
requirements
Formaldehyde
• Fabric supplier checked their production
record and found a typo in the batch formula
which caused the formaldehyde
concentration to exceed RS requirement
• Supplier has changed their quality control
procedures to review the formula before
official production to avoid the same mistakes
in the future.
Formaldehyde
Problem #5
PREVENTION:
Problem #5
• The only 100% method to meet RS requirements is to eliminate
the use of chemicals on an RSL
• If a supplier knows they are using a
chemical on an RSL they must
establish and carefully monitor control
procedures to ensure compliance
• Supplier should also increase testing
for affected products during
development and production
Formaldehyde
Problem #6
• Formaldehyde was found in a Full Grain
Leather material
• Leather supplier initiated investigation
and found out that Formaldehyde was
used in one of the re-tanning chemicals
without any intended chemical function
Formaldehyde
• As a short-term solution, Leather supplier
took strict measure of decreasing the % usage
of the Formaldehyde containing chemical in
its formula to reduce Formaldehyde content
level in finished products
• For long-team action, Leather supplier
found a Formaldehyde free chemical to
replace the contaminated chemical in its retanning process
Formaldehyde
Problem #6
PREVENTION:
Problem #6
• In some cases a chemical on an RSL can be used
• Conditions must be carefully controlled to manage finished
product compliance
• Work with high quality chemical
suppliers
• Always follow chemical supplier
guidelines
• When possible search for
formaldehyde free alternatives
Formaldehyde
Problem #1
• Brand designed a corded children’s
sweater
• Factory chose the cord supplier because
it was considered a “standard” item
• Cord supplier used a dyestuff that
contained prohibited azo-dyes
Aromatic Amines
Problem #1
• Product was already manufactured so
the only solution was an expensive
decision not to sell the product
• Lots of draw cords available to meet
RSL requirements
• RSL Compliant dyestuff from quality
chemical company with little to no cost
impact available
Aromatic Amines
Problem #1
PREVENTION:
• RS requirements must be
communicated to all suppliers
• Laws require product compliance
• A small component prevented the
entire garment from being sold
Aromatic Amines
Problem #1
• Cadmium found in outer PVC (polyvinyl
chloride) layer of soccer ball
• PVC commonly contains heavy metal
stabilizers
• PVC also often contains phthalates for
flexibility
• Cadmium was used as a stabilizer
• Cadmium can also be used in pigments
Heavy Metals
Problem #1
• PVC layer was substituted with a TPU
(thermoplastic polyurethane)
• TPU was tested to be RSL compliant
• TPU had performed better for feel and
durability
Heavy Metals
Problem #1
PREVENTION:
• When investigating new materials or production
techniques brands and suppliers have to work together to
meet a variety of goals including:
- price
- performance
- quality
- safety
Heavy Metals
Problem #2
• Red paint used on trim of an infant’s
shoe found to contain lead exceeding
RSL limits
• Lead was used as a pigment in the
paint
• Lead is acutely toxic in high
concentrations
Heavy Metals
Problem #2
• Brand voluntarily recalled product at a
cost of $6.7 million
• Factory began more complete testing
program for sourced raw materials
• Lead in raw material will still be lead in
finished product
Heavy Metals
Problem #2
PREVENTION:
• Source raw materials from reliable suppliers with a well controlled
manufacturing process
• Compliance of raw materials will
lead to compliant finished products
Heavy Metals
Problem #3
• PU (polyurethane) coated fabric was found
to contain high levels of lead
• PVC and phthalates had been eliminated
from the product
• Lead could be used as a stabilizer or
pigment
• Not likely caused by contamination
Heavy Metals
Problem #3
• Brand gave RSL requirements to
garment factory
• Not all of the requirements were
communicated to PU fabric vendor
• Factory is expected to communicate
RSL to its suppliers
Heavy Metals
Problem #3
PREVENTION:
• Brands include all members of supply chain
in RSL training
• Garment factories must fully communicate
all brand requirements to their downstream
suppliers
• Strategically test products at all stages of
production
Heavy Metals
Problem #4
• Lead was detected in the coating on
the top cover fabric of sock liners
• Heavy metals including lead are often
used in low cost pigments and inks
• Lead pigment was used in the heat
transfer on the sock liner.
Heavy Metals
Problem #4
PREVENTION:
• Brands include all members of supply chain
in RSL training
• Garment factories must fully communicate
all brand requirements to their downstream
suppliers
• Consider even the smallest components in
the RS compliance scenario
• Strategically test products at all stages of
production
Heavy Metals
Problem #5
• Chromium was detected on wool/nylon
fabric
• It appeared the mill had used a
metalized dye
• The mill already had the same problem
before
• Mill provided dye recipe and dye lot
records and the recipe was not the
problem
• During mill audit brand reviewed dyes
and auxiliary chemicals – all okay
Heavy Metals
PREVENTION:
Problem #5
• Determined that mill had old stock of fabric
that had failed previously
• Mill had submitted wrong sample to
laboratory for testing
• Be aware of your inventory management
systems
• If all product is not RS compliant, provide
clearly marked storage areas
***It is a best practice to produce only
compliant materials in order to avoid
contamination issues
Heavy Metals
Problem #6
• Printed heat transfer failed for mercury
• Mercury can be used as a pigment
• In this case the source of the mercury
was determined to be a cleaning solvent
that had contaminated a mixing beaker
Heavy Metals
PREVENTION:
Problem #6
• Heat transfer supplier eliminated
suspected cleaning agent
• Changed its process to mix inks in
disposable mixing containers
• Established time frames for keeping
custom mixed inks
• Printer already had a separate mixing
kitchen for this brand due to PVC
requirements
Heavy Metals
Problem #1
• Many screen print inks contain PVC
• PVC screen print inks often contain
phthalates
• Phthalates are used to soften ink and
prevent cracking
• Printed t-shirts did not meet phthalate
requirements for DEHP
• All print chemicals were tested phthalate
free prior to printing
Phthalates
Problem #1
• Spray adhesive used to hold garment in
place during printing contained DEHP
• Adhesive contaminated finished
garment
• Printer substituted a different spray
adhesive to achieve compliance
Phthalates
Problem #1
PREVENTION:
• Contamination is a big problem in RSL compliance
• When developing a program think about everything that touches the
product
• The best approach is to make sure all
raw materials meet RSL requirements
Phthalates
Problem #2
• Plasticizers are commonly used in
plastics and foams to increase flexibility
and improve performance
• Many phthalate based plasticizers
have been banned as toxic or
reproductive hazards
• Manufacturer claimed to use acetyltributylcitrate (ATBC) as
plasticizer alternative in flip flop sandals
• ATBC is considered a safer plasticizer alternative
Phthalates
Problem #2
• Consumer complaints that the flip flops had sticky feeling and
were removing lacquer finish on wood floors
• Laboratory analysis detected tributycitrate (TBC) instead of ATBC
as manufacturer claimed
• TBC is a known solvent for decoating
furniture
• Manufacturer substituted TBC as a
cheaper alternative for ATBC
Phthalates
PREVENTION:
Problem #2
• Manufacturers must stick to recipes described to brands
• Any substitutions should be approved by brand
• Chemical substitutions should not be
made on price alone without safety,
quality, performance impact
Phthalates
Problem #1
• Scouring agent is used to remove oils
and fats from textiles
• Many scouring agents contain APEO’s
(alkylphenol ethoxylates) as a surfactant
• APEO’s will remain on the fabric after the
scouring process
APEO’s
Problem #1
• Vendor chose scouring agent because it
removed all oils for even dyeing
• Vendor knew it contained APEO’s
• Vendor did not know brand was concerned
about APEO’s on finished product
• Vendor sourced an APEO free alternative
scour agent with no cost increase
APEO’s
Problem #1
PREVENTION:
• Communication
• Alternatives exist for most restricted chemicals
• Just ask for them
APEO’s
Problem #2
• APEO was detected in an insole board
• Supplier investigated fibers used to
produce the board and confirmed no
APEO’s were used
• Emulsion used to coat fiber board was
contaminated with APEO’s
• Supplier switched to a new batch of
emulsion and component passed RS
testing
APEO’s
PREVENTION:
Problem #2
• Contamination is a big problem in RSL compliance
• When developing a program think about everything that touches the
product
• Chemicals and tools must be properly
handled, stored, and sanitized to prevent
contamination
APEO’s
Problem #3
• NPEO was detected in pig skin leather
• NPEO is usually associated with degreasing
agents
• Their previous source of degreasing agent
was from Japan and known not to contain
NPEO
• A ban on raw materials exported from
Japan forced them to change to an alternate
source
• NPEO source was identified as new
degreasing agent
APEO’s
PREVENTION:
Problem #3
• When switching suppliers, for any reason, always share RS
requirements with new supplier
• A thorough RS testing program should
focus testing on high risk items, unknown
materials, or inexperienced suppliers
APEO’s
Problem #1
• Foil screen prints on children’s t-shirts
found to contain organotins
• Organotins are often used as heat
stabilizers in printing and transfer
processes
• Organotins were found through testing
of the foil backing adhesive
Organotins
Problem #1
• Print house had MSDS for all foil print
papers and adhesives
• All chemical suppliers were contacted to
see if they used organotins
• Some of the cheap adhesives contained
organotins
Organotins
Problem #1
PREVENTION:
• Communication
• High quality adhesive chemicals should be requested
• Non-organotin heat stabilizer
alternatives are available
Organotins
Problem #1
• Phenol was detected in the
adhesive used to manufacture shoes
during a random audit
• Chemical supplier believed that
there was no Phenol in its adhesive
• Supplier individually tested each of
the chemicals used to manufacture
adhesive to detect Phenol
Misc.
• One of the chemicals used to
produce adhesive had small residual
of Phenol
• Phenol used in the manufacturing
but was supposed to be removed
during processing
• Supplier reviewed the chemical
recovery process to ensure complete
recovery of Phenol
Misc.
Problem #1
Problem #1
PREVENTION:
• Establish routine testing procedure for presence of
restricted substances in all process chemicals
- Especially if a restricted
chemical is a known precursor.
Misc.
Problem #2
• Molded black rubber logo failed
testing for Polyaromatic
Hydrocarbons (PAHs)
• Rubber raw material supplier
confirmed that one of the rubber
raw materials, Naphthenic oil,
contained PAHs
Misc.
• Rubber supplier reformulated
material and substituted naphthenic
oil out of formula
• RS testing of the improved sample
showed the new formula is RS
compliant
Misc.
Problem #2
Problem #2
PREVENTION:
• RS requirements must be
communicated to all down stream
suppliers
• Down stream suppliers must
understand RS requirements and
impacts of raw material choices
Misc.
Problem #3
• PFOA was detected in a webbing (65%
Polyester + 35% recycled PET)
• Previous test of material met RS
requirements
• Supplier told brand that a non-wicking
treatment had been applied to the
material to provide water repellency since
the last RS testing
Misc.
• MSDS for the non-wicking chemical
showed PFOA content and tests failed RS
requirements
• Supplier worked with the non-wicking
additive supplier and replaced it with a nonwicking additive which is PFOS/PFOA free
Misc.
Problem #3
Problem #3
PREVENTION:
• Review MSDS to see if any restricted chemicals are present, evaluate
usage and process conditions
*(MSDS will not include low percentage
chemicals and chemical concentration in
finished product will depend on chemical
and application. MSDS should not be used
to determine RS compliance.)
• Alternatives exist for most restricted
chemicals – ask for them
Misc.
Problem #4
• Small amount of Volatile Organic
Compounds (VOC) was detected in the ink
raw materials at screen print facility
• Printer investigated and discovered
contamination from solvent supplier
recycling solvent tanks
Misc.
Problem #4
PREVENTION:
• Chemicals and tools must be properly handled, stored, and sanitized
to prevent contamination.
• Know the contents of spot cleaners and
other cleaners because they will be used in
contact with finished products
• Any chemical supplier to a facility must
know the RS requirements to avoid
contamination
Misc.
• Phenol was detected on silk fabric with a
print during pre-production testing
• By analysing individual raw materials the
thickener (guar gum) was identified to be
contaminated
• Printer switched from guar gum to alginate
thickener to avoid contamination problems
Misc.
Problem #5
Problem #5
PREVENTION:
• Pre-production testing provided time to seek out alternatives and
achieve chemical compliance
Misc.
• Black cotton / rayon socks were a high
volume carryover item
• No customer complaints until a cluster of 5
complaints for skin irritations within 1
month
• Samples tested for pH, formaldehyde,
restricted dyes – all tests negative
• Samples pulled from store stock were
noted to have a “solvent” smell
Misc.
Problem #6
Problem #6
• Socks were tested for VOC’s and found to contain
Dimethylformamide, methylene chloride, and acetone
• Supplier was found to be lubricating the knitting yarn with an
unlabelled solvent with no MSDS information
SOLUTION:
• Production was stopped immediately
• All current stock/shipments destroyed
• Supplier is under review and production in
their facility has been suspended
• Supplier required to prove factory
corrective action plan before production can
resume
Misc.
Problem #1
• Restricted disperse dye was found in a
woven label
• All the yarns used to make this label
were from well known suppliers and there
was no history of RSL failures
• Supplier tested all yarns used to make
this label & no restricted disperse dye was
detected
Disperse Dyes
• Only remaining component was the backer
• Testing of the backer only produced a
positive result for restricted disperse dye
• Backer was changed and supplier destroyed
all the inventory of failed backer color
Disperse Dyes
Problem #1
Problem #1
PREVENTION:
• Laws require product compliance
• A small component or part of a
component can cause a product to be
non-compliant
Disperse Dyes
Restricted Substance Problem Solution
Prevention Library
Heavy
Metals
Formaldehyde
Aromatic
Amines
Disperse
Dyes
APEO’s
Organotins
Phthalates
Misc.