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
    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 Guidance on Proposition 65 Labeling and Best Practices can be accessed here.

Technical Notes

Chemical nomenclature can take several forms. It is the responsibility of the user to verify synonyms of any regulated chemicals referenced.

It is possible that regulated substances may be present in raw materials below the levels that require reporting on Safety Data Sheets (SDS). Care should be taken to verify the presence of all regulated substances regardless of the concentration.

This list represents the most stringent known and applicable standards relevant to the apparel and footwear industry at the time of publication; any inaccuracy or omission is not the responsibility of AAFA.