Restricted Substances List: Apparel and Footwear International RSL Management Group
Restricted Substances List: Apparel and Footwear International RSL Management Group
Restricted Substances List: Apparel and Footwear International RSL Management Group
RESTRICTED
SUBSTANCES
LIST
Version 03 | 2018
Table of Contents
AFIRM Mission.......................................................................................... 3
AFIRM Vision............................................................................................. 3
Policy Statement and Uses of This RSL.................................................. 3
Legal Statement........................................................................................ 4
Definition of Ages.................................................................................... 12
Apparel and Footwear International RSL Management (AFIRM) Group is the author of this work.
You may reuse or adapt this work, with or without attribution to AFIRM Group.
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AFIRM Mission
AFIRM is the Apparel and Footwear International RSL Management (AFIRM) Working Group, established in 2004. AFIRM’s mission is “to reduce the use
and impact of harmful substances in the apparel and footwear supply chain.” AFIRM’s purpose is to provide a forum to advance the global management of
restricted substances in apparel and footwear, communicate information about chemical management to the supply chain, discuss concerns, and exchange
ideas for improving chemical management.
AFIRM Vision
AFIRM continues to be a recognized global center of excellence, providing resources to enable continuous advancement of chemical management best
practices. We do this based on transparency, science, and collaboration with relevant industries and experts to build safer and more sustainable chemistry
within the apparel and footwear supply chains. It is understood that in adopting this vision, AFIRM’s mission, objectives, and projects will continue to be
product-focused or RSL-related.
Some examples of uses for the AFIRM RSL, depending on the objectives of the user, include:
• Providing a tool for vendors to establish chemical management knowledge and processes.
• Building base compliance with AFIRM member chemical restrictions.
• Providing a common base for testing products, which may be accepted by multiple AFIRM brands.
AFIRM member companies determine and communicate to their vendors their testing requirements and acceptance of test reports.
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Legal Statement
The AFIRM RSL constitutes information from AFIRM only and does not represent any individual AFIRM member. Individual brand RSLs may differ in
specific parameters.
The AFIRM RSL is not intended to and does not establish any industry standard of care. The AFIRM RSL may not always provide the most appropriate
approach for any individual company’s chemical management program. Many brands have implementation guidelines, and suppliers must follow those
guidelines where required. The AFIRM RSL does not constitute legal advice and is not a substitute for legal advice. There is no warranty, express or implied,
as to the completeness or utility of the information contained in this AFIRM RSL, including, without limitation, that the information is current and error-free.
AFIRM disclaims liability of any kind whatsoever resulting from any use of or reliance on the AFIRM RSL.
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In addition, ECHA must be notified if the substance(s) are present in article components above 0.1 percent in quantities totaling over one ton per
producer or importer per year. Notification is not required if the substance has already been registered for that use or when the producer or importer
of an article can exclude exposure of humans and the environment during the use and disposal of the article. In such cases, the producer or
importer must supply appropriate instructions to the recipient of the article.
ECHA periodically updates the Candidate List; find the most current version at https://www.echa.europa.eu/candidate-list-table.
AFIRM member brands may differ on how they address SVHCs as well as the legal obligations. AFIRM advises suppliers to consult with their
customers regarding brand-specific requirements for SVHCs.
AFIRM member brands may differ on how they address warning-label requirements. AFIRM advises suppliers to consult with their customers
regarding brand-specific requirements for Proposition 65 substances.
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AFIRM member brands have produced a comprehensive set of educational materials advising suppliers Other Names Uses in the Supply Chain
about best practices for chemical manangement. Each chemical information sheet covers a chemical or
Acetophenone • Methyl phenyl ketone There are few direct uses of acetophenone or 2-phenyl-2-
• Acetylbenzene propanol in the supply chain. These two chemicals are
2-Phenyl- • 1-Hydroxycumene byproducts when a peroxide initiator called dicumyl peroxide
2-Propanol • Dimethylphenylmethanol (DCP) is used in ethyl-vinyl-acetate (EVA) foam production.
class of chemicals, giving an overview of the substance(s), where they are likely to be found in the material
DCP initiates a cross-linking reaction in EVA foam by creating
peroxide radicals, and both acetophenone and 2-pheyl-2-
CAS Number Substance
propanol are potential endpoints for the radicals once they
have been deactivated.
manufacturing process, and how to maintain compliance with the AFIRM RSL.
98-86-2 Acetophenone
The complete library of chemical information sheets is available on the AFIRM website at http://afirm-group.
• Solvents voluntarily restricted acetophenone and 2-phenyl-2 propanol
• Cleaners due to the odor, which has prompted concern by some
enforcement agencies.
• Acetophenone is classified as Acute Tox 4 - H302, Eye
com/information-sheets; additionally, links to individual information sheets are embedded in the pages
Irrit. 2 - H319
that follow.
EVA polymers created using DCP as a cross linker may contain some level of acetophenone and 2-phenyl-2-propanol.
Engaging in a conversation with your material supplier to discuss this issue is the best way to procure materials with the
lowest levels of Acetophenone and 2-phenyl-2-propanol possible.
✛ The plus symbol next to a chemical or class of chemicals in the AFIRM RSL indicates that a
to be utilized. Caution should be used if an alternative to DCP is used, as some available alternatives are suspected of
creating more hazardous byproducts.
While it may be possible to reduce the amount of the byproducts with stringent processing controls, it is unlikely that a
information sheet is available; simply click on the chemical name, and your web browser will
complete absence of these two chemistries will be achieved when DCP is used.
Safer Alternatives
There are alternative recipes for creating EVA polymers that do not require DCP as a cross-linker, but each has the
potential to create other additional byproducts.
Definition: Reporting limits are values at or above the practical quantification limit (PQL) for the test method. The PQL represents the
lowest level at which accurate, precise, and robust data can be reported. Reporting limits are values above which labs should report
detected substances for purposes of data capture and harmonization.
Reporting specific values, rather than using a simple PASS/FAIL model, allows the supply chain to capture information regarding the presence of
substances below the RSL limit. Reporting limits also enable the harmonization of data between various testing labs.
AFIRM RSL reporting limits should be widely achievable by laboratories across the global analytical testing industry as well as allow for combined
(composite) testing where applicable.
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AFIRM Group brands agree on the chemicals included in the AFIRM RSL, the allowable limits, and the test methods. The responsibility for managing testing
programs—which specific restricted chemicals should be tested in which specific materials and the frequency of such tests—remains with individual brands.
The risk matrix shown in Table 1, on the next page, highlights the restricted substance risks associated with different fibers and materials, and is presented
as a guidance tool. It is based on our many years of experience in manufacturing and in managing restricted substances across a wide range of materials.
The aim is to provide information on those substances that have historically been deliberately used or found as reagent/contaminants in different materials.B
It uses the following color code:
1 Red indicates that a chemical has been in widespread use and/or frequently detected in a particular material.
2 Orange indicates that a chemical has been deliberately used and/or detected in a particular material occasionally.
3 Yellow indicates there is a very low but theoretical chance that a chemical could be used and/or detected.
White indicates that we believe there is an almost negligible risk of a chemical being used and/or detected.
In the absence of a brand RSL and testing program, the matrix outlined in Table 1 is a good starting point until you gain a true understanding of the risks
within your specific supply chain. Use of this matrix should be accompanied by due diligence across all chemistries of concern.
The unified approach of the AFIRM RSL enables member brands to share test data more easily, and we anticipate that the risk matrix will evolve to reflect
realistic risks at any given time.
Individual brand testing programs, to the extent they are different, supersede this guidance tool.
A. See Section 5 of the AFIRM Supplier Toolkit for more information on testing and Appendix C of the AFIRM Supplier Toolkit for a model testing program if your customer does not have one
of its own.
B. If a substance is a component of a combined material (for example, a laminated component like polymer material + textile lining), we recommend testing according to different material types.
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Natural Leather
Blended Fibers
Substance
Natural Fibers
Metal
Glue
Acetophenone and 2-Phenyl-2-Propanol 2A
Acidic and Alkaline Substances (pH) 1 1 1 1 1
Alkylphenol (AP) and Alkylphenol Ethoxylates (APEOs), including all isomers 1 1 1 1 1 1 1 1 3 1
Azo-amines 1 1 1 1 1 1 1 1
Bisphenol-A 3B
Chlorinated Paraffins, SCCP (C10-C13) and MCCP (C14-C17) 3 3 3 3 1 3 2
Chlorophenols (Tri-, Tetra-, and Pentachlorophenols) 3 3 3 3 3 3
Chlororganic Carriers 2 2 3
Dimethylformamide (DMFa) 2 2 2
Dimethylfumarate (DMFu) 3 3 3 3 3 3 3
Dyes, Forbidden and Disperse 2 2 2 2
Dyes, Navy Blue 3 3 3 3
Flame Retardants 3 (If finish is applied)
Fluorinated Greenhouse Gases
Formaldehyde 1 1 1 1 1 1 1 1
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Natural Leather
Blended Fibers
Substance
Natural Fibers
Metal
Glue
Heavy Metals, Chromium VI 3 1
Heavy Metals, Nickel Release 1
Heavy Metals, Cadmium Total 3 3 3 3
Heavy Metals, Lead Total 3 3 3 C
3
Heavy Metals, Additional Total (Hg & As) 3 3 3 3
Heavy Metals, Extractable 2 2 2 2 2 2 2
N-Nitrosamines 2
Organotin Compounds 3 3 3 3 3 3 3 3
Ortho-phenylphenol (OPP) 2 2 2 2 2 2
Ozone-depleting Substances 3
Perfluorinated and Polyfluorinated Chemicals (PFCs) 2 (If water- or stain-repellant finish is applied)
Pesticides, Agricultural 3 3 3
Phthalates 1 1 1 1
Polycyclic Aromatic Hydrocarbons (PAHs) 1 1 1 1
Styrene Monomer 2D
Vinyl Chloride Monomer 2E 2E
Volatile Organic Compounds (VOCs) 2 2 2 2 2 2 2 2
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Definition of Ages
Various countries define the terms “babies,” “children,” and “adults” differently. Based on legislation, the age ranges listed in Table 2 satisfy the most
restrictive global requirements.
Age Range
Babies 0 to 36 months
Children 36 months to 14 years
Adults 14 years and older
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CAS No. Substance Limits Potential Uses Suitable Test Method Reporting
Raw Material & Textile Processing for Apparel & Sample Preparation & Measurement Limit
Finished Product Footwear Limits above which
test results should
be reported
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CAS No. Substance Limits Potential Uses Suitable Test Method Reporting
Raw Material & Textile Processing for Apparel & Sample Preparation & Measurement Limit
Finished Product Footwear Limits above which
test results should
be reported
Alkylphenols (APs) ✛
Alkylphenol Ethoxylates (APEOs) ✛
including all isomers
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CAS No. Substance Limits Potential Uses Suitable Test Method Reporting
Raw Material & Textile Processing for Apparel & Sample Preparation & Measurement Limit
Finished Product Footwear Limits above which
test results should
be reported
Azo-amines ✛
92-67-1 4-Aminobiphenyl
92-87-5 Benzidine
95-69-2 4-Chloro-o-toluidine
91-59-8 2-Naphthylamine
97-56-3 o-Aminoazotoluene
99-55-8 2-Amino-4-nitrotoluene
106-47-8 p-Chloraniline
615-05-4 2,4-Diaminoanisole
101-77-9 4,4’-Diaminodiphenylmethane
91-94-1 3,3’-Dichlorobenzidine Azo dyes and pigments are colorants
that incorporate one or several azo
119-90-4 3,3’-Dimethoxybenzidine groups (-N=N-) bound with aromatic Textiles: EN ISO 14362-1:2017
compounds. Leather: EN ISO 17234-1:2015
119-93-7 3,3’-Dimethylbenzidine Thousands of azo dyes exist, but
20 ppm each p-Aminoazobenzene: 5 ppm
838-88-0 3,3’-dimethyl-4,4’-diaminodiphenylmethane only those which degrade to form the
listed cleavable amines are restricted. Textiles: EN ISO 14362-3:2017
120-71-8 p-Cresidine Azo dyes that release these amines Leather: EN ISO 17234-2:2011
are regulated and should no longer
101-14-4 4,4’-Methylen-bis(2-chloraniline)
be used for dyeing textiles.
101-80-4 4,4’-Oxydianiline
139-65-1 4,4’-Thiodianiline
95-53-4 o-Toluidine
95-80-7 2,4-Toluylendiamine
137-17-7 2,4,5-Trimethylaniline
95-68-1 2,4 Xylidine
87-62-7 2,6 Xylidine
90-04-0 2-Methoxyaniline (= o-Anisidine)
60-09-3 p-Aminoazobenzene
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CAS No. Substance Limits Potential Uses Suitable Test Method Reporting
Raw Material & Textile Processing for Apparel & Sample Preparation & Measurement Limit
Finished Product Footwear Limits above which
test results should
be reported
Bisphenol-A ✛
Chlorinated Paraffins ✛
85535-84-8 Short-chain Chlorinated Paraffins (SCCPs) (C10-C13) 1000 ppm Combined CADS/ISO 18219:2015 100 ppm
method V1:06/17
May be used as softeners, flame
retardants, or fat-liquoring agents Extraction: ISO 18219 and analysis
in leather production; also as a by GC-NCI-MS
85535-85-9 Medium-chain Chlorinated Paraffins (MCCPs) (C14-C17) 1000 ppm plasticizer in polymer production. 100 ppm
For more information on the standard
method, click here.
Chlorophenols ✛
15950-66-0 2,3,4-Trichlorophenol
933-78-8 2,3,5-Trichlorophenol
933-75-5 2,3,6-Trichlorophenol Chlorophenols are polychlorinated
95-95-4 2,4,5-Trichlorophenol compounds used as preservatives
or pesticides. Pentachlorophenol
1 M KOH extraction, 12–15 hours
88-06-2 2,4,6-Trichlorophenol (PCP) and tetrachlorophenol (TeCP)
at 90 degrees C, derivatization and
0.5 ppm each are sometimes used to prevent 0.5 ppm
609-19-8 3,4,5-Trichlorophenol analysis § 64 LFGB B 82.02-08 or
mould and kill insects when growing
DIN EN ISO 17070:2015
cotton and when storing/transporting
4901-51-3 2,3,4,5-Tetrachlorophenol (TeCP) fabrics. PCP and TeCP can also be
58-90-2 2,3,4,6-Tetrachlorophenol (TeCP) used as preservatives in print pastes.
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CAS No. Substance Limits Potential Uses Suitable Test Method Reporting
Raw Material & Textile Processing for Apparel & Sample Preparation & Measurement Limit
Finished Product Footwear Limits above which
test results should
be reported
Chlororganic Carriers ✛
95-49-8 2-Chlorotoluene
108-41-8 3-Chlorotoluene
106-43-4 4-Chlorotoluene
32768-54-0 2,3-Dichlorotoluene
95-73-8 2,4-Dichlorotoluene
19398-61-9 2,5-Dichlorotoluene
118-69-4 2,6-Dichlorotoluene
95-75-0 3,4-Dichlorotoluene
2077-46-5 2,3,6-Trichlorotoluene
6639-30-1 2,4,5-Trichlorotoluene
76057-12-0 2,3,4,5-Tetrachlorotoluene
Chlorobenzenes and Chlorotoluenes
875-40-1 2,3,4,6-Tetrachlorotoluene (chlorinated aromatic hydrocarbons)
Total: 1 ppm can be used as carriers in the DIN 54232:2010 0.2 ppm
1006-31-1 2,3,5,6-Tetrachlorotoluene
dyeing process of polyester or wool/
877-11-2 Pentachlorotoluene polyester fibers. They can also be
used as solvents.
541-73-1 1,3-Dichlorobenzene
106-46-7 1,4-Dichlorobenzene
87-61-6 1,2,3-Trichlorobenzene
120-82-1 1,2,4-Trichlorobenzene
108-70-3 1,3,5-Trichlorobenzene
634-66-2 1,2,3,4-Tetrachlorobenzene
634-90-2 1,2,3,5-Tetrachlorobenzene
95-94-3 1,2,4,5-Tetrachlorobenzene
608-93-5 Pentachlorobenzene
118-74-1 Hexachlorobenzene
95-50-1 1,2-Dichlorobenzene 10 ppm 1 ppm
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CAS No. Substance Limits Potential Uses Suitable Test Method Reporting
Raw Material & Textile Processing for Apparel & Sample Preparation & Measurement Limit
Finished Product Footwear Limits above which
test results should
be reported
Dimethylformamide ✛
Dimethylfumarate ✛
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CAS No. Substance Limits Potential Uses Suitable Test Method Reporting
Raw Material & Textile Processing for Apparel & Sample Preparation & Measurement Limit
Finished Product Footwear Limits above which
test results should
be reported
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CAS No. Substance Limits Potential Uses Suitable Test Method Reporting
Raw Material & Textile Processing for Apparel & Sample Preparation & Measurement Limit
Finished Product Footwear Limits above which
test results should
be reported
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CAS No. Substance Limits Potential Uses Suitable Test Method Reporting
Raw Material & Textile Processing for Apparel & Sample Preparation & Measurement Limit
Finished Product Footwear Limits above which
test results should
be reported
Flame Retardants ✛
32534-81-9 Pentabromodiphenyl ether (PentaBDE)
32536-52-0 Octabromodiphenyl ether (OctaBDE)
1163-19-5 Decabromodiphenyl ether (DecaBDE)
Various All other Polybrominated diphenyl ethers (PBDEs)
EN ISO 17881-1:2016
79-94-7 Tetrabromobisphenol A (TBBP A)
59536-65-1 Polybromobiphenyls (PBB)
Flame-retardant chemicals, including
3194-55-6 Hexabromocyclododecane (HBCDD) the entire class of Organohalogen
10 ppm each 5 ppm
3296-90-0 2,2-bis(bromomethyl)-1,3-propanediol (BBMP) flame retardants, should no longer
be used.
13674-87-8 Tris(1,3-dichloro-isopropyl) phosphate (TDCPP)
25155-23-1 Trixylyl phosphate (TXP)
126-72-7 Tris(2,3,-dibromopropyl) phosphate (TRIS)
EN ISO 17881-2:2016
545-55-1 Tris(1-aziridinyl)phosphine oxide) (TEPA)
115-96-8 Tris(2-chloroethyl)phosphate (TCEP)
5412-25-9 Bis(2,3-dibromopropyl) phosphate (BDBPP)
Sample preparation:
Purge and trap — thermal desorption
Various See Regulation (EC) No 842/2006 for a complete list. 0.1 ppm each or SPME 0.1 ppm each
Measurement: GC/MS
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CAS No. Substance Limits Potential Uses Suitable Test Method Reporting
Raw Material & Textile Processing for Apparel & Sample Preparation & Measurement Limit
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test results should
be reported
Formaldehyde ✛
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Raw Material & Textile Processing for Apparel & Sample Preparation & Measurement Limit
Finished Product Footwear Limits above which
test results should
be reported
Extractable:
Cobalt and its compounds can be Textiles: DIN EN 16711-2:2016
Adults: 4 ppm Extractable:
7440-48-4 Cobalt (Co) used in alloys, pigments, dyestuff,
Leather: DIN EN ISO 17072-1:2017 0.5 ppm
Children and and the production of plastic buttons.
babies: 1 ppm
Extractable:
Copper and its compounds can be Textiles: DIN EN 16711-2:2016
Adults: 50 ppm Extractable: 5
7440-50-8 Copper (Cu) found in alloys and pigments, and in
Leather: DIN EN ISO 17072-1:2017 ppm
Children and textiles as an antimicrobial agent.
babies: 25 ppm
Extractrable:
Textiles: DIN EN 16711-2:2016
Extractable: Leather: DIN EN ISO 17072-1:2017
Adults and May be associated with plastics, Extractable:
children: 1 ppm Total: 0.1 ppm
7439-92-1 Lead (Pb) paints, inks, pigments and surface
Babies: 0.2 ppm coatings. Non-metal: CPSC-CH-E1002-08.3 Total: 10 ppm
Total: 90 ppm Metal: CPSC-CH-E1001-08.3
Lead in paint and surface coating:
CPSIA Section 101 16 CFR 1303
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Extractable:
Textiles: DIN EN 16711-2:2016
Mercury compounds can be present Extractable:
Extractable: Leather: DIN EN ISO 17072-1:2017 0.02 ppm
0.02 ppm in pesticides and as contaminants in
7439-97-6 Mercury (Hg) Total:
caustic soda (NaOH). They may also Total: 0.1 ppm
Total: 0.5 ppm be used in paints. Textiles, plastics, metal:
DIN EN 16711-1:2016
Leather: DIN EN ISO 17072-2:2017
Monomers ✛
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CAS No. Substance Limits Potential Uses Suitable Test Method Reporting
Raw Material & Textile Processing for Apparel & Sample Preparation & Measurement Limit
Finished Product Footwear Limits above which
test results should
be reported
N-Nitrosamines ✛
62-75-9 N-nitrosodimethylamine (NDMA)
55-18-5 N-nitrosodiethylamine (NDEA)
621-64-7 N-nitrosodipropylamine (NDPA) GB/T 24153-2009: determination
using GC/MS, with LC/MS/MS
924-16-3 N-nitrosodibutylamine (NDBA) verification if positive.
Can be formed as by-product in the Alternatively, LC/MS/MS may be
100-75-4 N-nitrosopiperidine (NPIP) 0.5 ppm each 0.5 ppm
production of rubber. performed on its own.
930-55-2 N-nitrosopyrrolidine (NPYR) prEN 19577:2017
59-89-2 N-nitrosomorpholine (NMOR)
614-00-6 N-nitroso N-methyl N-phenylamine (NMPhA)
612-64-6 N-nitroso N-ethyl N-phenylamine (NEPhA)
Organotin Compounds ✛
Various Dibutyltin (DBT)
Class of chemicals combining tin
Various Dioctyltin (DOT) and organics such as butyl and phenyl
groups.
Various Monobutyltin (MBT) Organotins are predominantly found
Various Tricyclohexyltin (TCyHT) 1 ppm each in the environment as antifoulants in
marine paints, but they can also be
Various Trimethyltin (TMT) used as biocides (e.g., antibacterials), CEN ISO/TS 16179:2012 0.1 ppm each
catalysts in plastic and glue production,
Various Trioctyltin (TOT) and heat stabilizers in plastics/rubber.
Various Tripropyltin (TPT) In textiles and apparel, organotins are
associated with plastics/rubber, inks,
Various Tributyltin (TBT) paints, metallic glitter, polyurethane
0.5 ppm each products and heat transfer material.
Various Triphenyltin (TPhT)
Ortho-phenylphenol ✛
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test results should
be reported
Ozone-depleting Substances ✛
Pesticides, Agricultural ✛
Natural fibers:
May be found in natural fibers, ISO 15913/DIN 38407 F2 or
Various See Appendix A for a complete list. 0.5 ppm each 0.5 ppm
primarily cotton. EPA 8081/EPA 8151A or
BVL L 00.00-34:2010-09
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CAS No. Substance Limits Potential Uses Suitable Test Method Reporting
Raw Material & Textile Processing for Apparel & Sample Preparation & Measurement Limit
Finished Product Footwear Limits above which
test results should
be reported
Phthalates ✛
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CAS No. Substance Limits Potential Uses Suitable Test Method Reporting
Raw Material & Textile Processing for Apparel & Sample Preparation & Measurement Limit
Finished Product Footwear Limits above which
test results should
be reported
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Raw Material & Textile Processing for Apparel & Sample Preparation & Measurement Limit
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test results should
be reported
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2-(2,4,5-trichlorophenoxy) propionic acid, its 120-36-5 Dichloroprop g-Hexachlorocyclohexane with and without
93-72-1 319-86-8
salts and compounds; 2,4,5-TP 115-32-2 Dicofol Lindane