RSL Methodology

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.

Structure

For each substance the RSL identifies the following features:

  1. CAS number
  2. Common chemical or color name
  3. Information on the Restriction/Limit on Final Product or Tested Component
    1. Restriction Level
    2. Country where that Restriction/Limit is found
    3. Test Method (where no test method is stipulated in the regulation, the GAFTI column may suggest one)
    4. Other countries that maintain equal or less restrictions
    5. Comments (if applicable)

Scope

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 U.S. 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 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.

AAFA’s Restricted Substances List Covering California Proposition 65 can be accessed here .

For more information on the work done by the AFIRM group, see the AFIRM RSL. This tool covers chemicals that are neither regulated nor proven to be dangerous, but may be of note to the industry.

Technical Notes

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.

About GAFTI

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.

GAFTI 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