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 06 | 2021
AFIRM Restricted Substances List | 2021
Table of Contents
AFIRM Mission.......................................................................................... 3
AFIRM Vision............................................................................................. 3
Legal Statement........................................................................................ 3
Policy Statement....................................................................................... 3
Additional Substances and Parameters to Consider.............................. 7 For more information about AFIRM,
visit www.afirm-group.com.
AFIRM Chemical Information Sheets....................................................... 8
Definition of “Ages”................................................................................... 8
Definition of “Child Care Articles”............................................................ 8
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.
2
AFIRM Restricted Substances List | 2021
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.
AFIRM Mission AFIRM Vision 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
AFIRM is the Apparel and Footwear AFIRM continues to be a recognized individual company’s chemical management program. Many
International RSL Management global center of excellence, brands have implementation guidelines, and suppliers must
(AFIRM) Working Group, established providing resources to enable follow those guidelines where required. The AFIRM RSL
does not constitute legal advice and is not a substitute for
in 2004. continuous advancement of chemical legal advice. There is no warranty, express or implied, as
management best practices. to the completeness or utility of the information contained
AFIRM’s mission is “to reduce in this AFIRM RSL, including, without limitation, that the
the use and impact of harmful We do this based on transparency, information is current and error-free. AFIRM disclaims liability
substances in the apparel and science, and collaboration with of any kind whatsoever resulting from any use of or reliance
on the AFIRM RSL.
footwear supply chain.” relevant industries and experts to
build safer and more sustainable Policy Statement
AFIRM’s purpose is to provide chemistry within the apparel and
a forum to advance the global AFIRM has created the following Restricted Substances List
footwear supply chains. (“AFIRM RSL”) to assist and guide supply chain participants
management of restricted seeking to increase product quality and safety or reduce
substances in apparel and footwear, It is understood that in adopting this their environmental impact by limiting the use of certain
communicate information about vision, AFIRM’s mission, objectives, substances in apparel and footwear. AFIRM acknowledges
that a brand’s offerings may include closely related products
chemical management to the and projects will continue to be
utilizing the same or similar materials, such as accessories,
supply chain, discuss concerns, product-focused or RSL-related. jewelry, sporting good equipment, wearables, and home
and exchange ideas for improving textiles. The AFIRM RSL may be applied to these additional
chemical management. product types, and examples are included in the scope
of this document for guidance; however, the primary
focus of the AFIRM RSL remains apparel and footwear.
AFIRM recommends that suppliers check with their brand
customers for specific requirements regarding additional
product categories.
3
AFIRM Restricted Substances List | 2021
• Apparel. Any garment worn on the body intended to protect, cover, or adorn.
• Footwear. Any durable covering for the feet intended to protect, cover, or comfort.
• Accessories. Any product intended to complement apparel, both carried and worn.
• Jewelry. Small decorative items worn for personal adornment such as rings, necklaces, earrings, pendants, bracelets and cufflinks. Jewelry may be
attached to the body or clothing.
• Sporting Good Equipment. Any product intended for use in sport or exercise, including protective equipment.
• Wearables. Battery-powered electronic devices intended to be worn on the body during normal use. The AFIRM RSL covers components used on the
external portion (i.e. skin contact) of the wearable product. Please note that certain wearable products, such as fitness trackers worn on the wrist, could
also be classified as jewelry. AFIRM recommends that suppliers check with their brand customers regarding specific testing requirements for wearable
components.
• Home Textiles. Any product intended for functional or decorative purposes in the home.
For guidance purposes, AFIRM provides examples of products to which the AFIRM RSL may be applied, including but not limited to those listed
in Table 1, on the next page.
Because AFIRM member brands may differ on the types of products classified under each of these categories, suppliers are advised to check with their
customers regarding brand-specific definitions, requirements, and product applicability.
4
AFIRM Restricted Substances List | 2021
• Shirts • Lifestyle • Hats • Shin and leg guards • Fitness trackers (worn on • Towels
wrist, chest, finger, ear, etc.) • Bathrobes
• Pants/trousers • Athletic (e.g. running, • Headbands • Gloves (e.g. baseball,
training) football, golf) • Heart-rate monitors • Bed linens (e.g. sheets,
• Shorts • Scarves
pillowcases, duvets)
• Sports (e.g. basketball, • Chest protectors • Digital watches
• Skirts soccer, football, baseball)
• Handbags • Blankets
• Balls (e.g. basketball, • Smart watches
• Dresses • Sandals
• Backpacks football, soccer)
• Smart apparel and footwear
• Swimwear • Flip flops
• Sunglasses • Helmets
• Wireless headphones and
• Socks • Boots
• Shoelaces • Shoulder, knee, and earbuds
• Jackets • Belts elbow pads
• Slippers
• Vests • Hair clips • Yoga mats and blocks
• Sweatshirts and hoodies • Gloves (e.g. winter) • Rackets (e.g. tennis,
racquetball, badminton)
• Sweaters • Jewelry
• Fitness equipment (e.g.
• Underwear treadmills)
• Sleepwear and loungewear • Bicycles
5
AFIRM Restricted Substances List | 2021
• Providing a tool for vendors to establish chemical management knowledge and processes.
• Building full or base compliance with AFIRM member chemical restrictions.
• Providing a common base for testing, 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.
Zero Discharge of Hazardous Chemicals (ZDHC) Foundation — Manufacturing Restricted Substances List (MRSL)
https://mrsl.roadmaptozero.com/
6
AFIRM Restricted Substances List | 2021
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.
7
AFIRM Restricted Substances List | 2021
AFIRM member brands have produced a comprehensive set of educational materials advising suppliers Other Names Uses in the Supply Chain
There are few direct uses of acetophenone or 2-phenyl-2-
about best practices for chemicals management. Each chemical information sheet covers a chemical or
Acetophenone • Methyl phenyl ketone
• 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.
DCP initiates a cross-linking reaction in EVA foam by creating
class of chemicals, giving an overview of the substance(s), where they are likely to be found in the material CAS Number
98-86-2
Substance
Acetophenone
peroxide radicals, and both acetophenone and 2-pheyl-2-
propanol are potential endpoints for the radicals once they
have been deactivated.
manufacturing process, and how to maintain compliance with the AFIRM RSL. 617-94-7
May Be Found In
2-Phenyl-2-Propanol
The sheets contain some information relevant to packaging, and future revisions will include more
• Cleaners due to the odor, which has prompted concern by some
enforcement agencies.
• Acetophenone is classified as Acute Tox 4 - H302, Eye
specific information.
Irrit. 2 - H319
While it may be possible to reduce the amount of the byproducts with stringent processing controls, it is unlikely that a
The complete library of chemical information sheets is available on the AFIRM website at
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.
✛ The plus symbol next to a chemical or class of chemicals in the AFIRM RSL indicates
that an information sheet is available; simply click on the chemical name, and your web
browser will load a PDF of the information sheet for that substance.
Age Range
Babies 0 to 36 months
Children 36 months to 14 years
Adults 14 years and older
8
AFIRM Restricted Substances List | 2021
Reporting limits are values at or above the method Practical Quantification Limit (PQL). The PQL represents the lowest level at which accurate, precise, and
robust data can be reported. AFIRM RSL reporting limits are widely achievable by laboratories across the global analytical testing industry and allow for
combined (composite) testing where applicable.
Natural fibers. Animal or vegetable fibers the substrate, such as by electroplating or colorants, plasticizers, stabilizers, and fillers.
(including semi-synthetics). ceramic glazing. These additives affect the chemical composition,
chemical properties, and mechanical properties
Blended fibers. Woven or knitted materials Printing. The process of applying color to a fabric of the plastic.
created by blending two or more fiber types. in definite patterns or designs.
For the purpose of this RSL, a blended fiber Natural rubber. Elastic material made from latex
consists of a natural and a synthetic fiber. Natural materials. Material derived from sap or trees that can be vulcanized.
animals or plants that have undergone very little
Synthetic fibers. Human-made fibers based modification. Includes horn, bone, cork, wood, Synthetic rubber. Material made from
on synthetic chemicals (often from petroleum paper, and straw. Excludes natural fibers, natural petroleum-based monomers with properties
sources) such as polymers and extruded fibers. leather, feathers, down, and metals. similar to natural rubber.
Artificial leather. A leather-like material Crystal. In this variety of glass, also known as Foam. Spongy material made by trapping air
composed of a textile backing and, typically, lead glass, lead replaces calcium content of a bubbles in a solid. These can be open cell or
a PU or PVC coating. typical potash glass. The addition of lead oxide closed cell.
gives crystal a much higher index of refraction
Natural leather. Created by tanning animal than normal glass, and consequently much Metals. Chemical elements that can be lustrous,
rawhides. greater sparkle. Crystal typically contains at ductile, malleable, and good conductors of heat
least 24% lead and is therefore exempt from and electricity. Includes metals deposited by
Coating. A fluid, semi-fluid, or other material, with physical vapor deposition (PVD), chemical vapor
or without a suspension of finely divided coloring many regulatory requirements for jewelry. In the
European Union, labeling of crystal products is deposition (CVD), or electroplating.
matter, which changes to a solid film when a thin
layer is applied to a metal, wood, stone, paper, regulated by Council Directive 69/493/EEC, which Feathers and down. Includes the smaller down
leather, cloth, plastic, or other surface. defines four categories based on the chemical feathers as well as the larger contour and flight
composition and properties of the material. feathers. See the International Down and Feather
Coatings do not include printing inks or those Bureau for specific down and feather definitions.
materials which actually become a part of the Polymers and plastics. Plastics are composed
substrate, such as the pigment in a plastic article of various polymers (typically from petroleum Glue. A substance capable of holding materials
or those materials which are actually bonded to sources) usually mixed with additives including together by surface attachment.
9
AFIRM Restricted Substances List | 2021
Natural Blended Synthetic Artificial Natural Coatings & Natural Other Polymers, Metal Feathers Glue
Fibers Fibers Fibers Leather Leather Prints Materials Materials Plastics, Foams, & Down
Including semi- Natural Rubber &
synthetics
Synthetic Rubber
• Cotton • Cotton- • Polyester • Polyurethane • Leather Printing techniques • Horn • Glass • Ethylene vinyl • Stainless • Feathers • Hot melt
Polyester (PU) such as: acetate (EVA) steel adhesive
• Wool • Acrylic • Bone • Synthetic • Down
• Wool-Nylon • Polyvinyl • Heat transfers stone • Polystyrene (PS) • Brass • Powdered
• Silk • Nylon • Cork adhesive
Chloride
• Ramie- • Dye sublimation • Porcelain • Polyethylene (PE) • Copper
• Hemp • Polyamide (PVC) • Wood
Polyester printing • Flock
• Ceramic • Acrylonitrile butadiene • Gold adhesive
• Cashmere • Paper styrene (ABS)
• Screen printing
• Crystal • Silver • Contact
• Linen • Straw • Neoprene
• Direct-to- adhesive
• Aluminum
• Fur garment printing • Stone • Polypropylene (PP) • Latex glue
• Rayon • Discharge
• Polycarbonate (PC) • Polyurethane
(Semi- printing
synthetic) • Polyamide (PA) glue
• Plastisol
• Lyocell transfers • Polyurethane (PU) • Neoprene
(Semi- cement
• Polyvinyl chloride
synthetic) Coatings such as: • Epoxies
(PVC)
• Polyvinyl chloride • Silicone
• Thermoplastic
(PVC) adhesive
polyurethane (TPU)
• Polyurethane • UV-cured
• Thermoplastic
(PU) adhesive
elastomer (TPE)
• UV-cured
• Styrene ethylene
butylene styrene
(SEBS)
10
AFIRM Restricted Substances List | 2021
• Added this new category of materials, which includes Porcelain, Synthetic Stone, Ceramic, Glass, and
Crystal, to the RSL.
• Added a definition of Crystal to page 9 9, 10,
N/A Other Materials
• Added a new column to Table 3 on page 10.. 13–14
• Added a new column to the Testing Matrix on pages 13 and 14, with a Level 1 (red) recommendation to
test for total Cadmium and Lead. Note that Crystal is exempt for Lead.
Various Chlororganic Carriers • Changed name from “Chlororganic Carriers” to “Chlorinated Benzenes and Toluenes” 13, 20
• Removed Level 2 (orange) testing recommendation from pH for Polymers in the Testing Matrix.
Various Acidic and Alkaline Substances (pH) • Updated test method for Textiles and Artificial Leather: 13, 15
• EN ISO 3071:2020
7440-50-8 Heavy Metals (Non-Jewelry) Copper • Extractable Copper is now exempt from restriction limits in Metal parts. 14, 25
Various Heavy Metals (Jewelry) • Updated test method ASTM F2923 to 2020 version. 27–28
• Clarified that the 75 ppm limit is applicable for adults only and the 40 ppm limit is applicable for
7440-43-9 Heavy Metals (Jewelry) Cadmium 27
children only.
Various PFOA and its salts • Removed area-based limit of 1µg/m2 after repeal of legislation by Norway. 31
68515-50-4 Di-hexylphthalate, branched and linear (DHxP) • Name corrected to match SVHC listing under REACH. 32
71850-09-4 Diisohexyl phthalate (DIHxP) • Added new SVHC phthalate under REACH. 32
11
AFIRM Restricted Substances List | 2021
The Testing Matrix is a more prescriptive approach to help brands and suppliers effectively manage chemical risks by adopting a common testing approach
for use and acceptance across different brands. Chemicals assigned a Level 1 in materials should be viewed as the minimum amount of testing required to
satisfy AFIRM member requirements, and chemicals assigned a Level 2 are recommended for additional testing and may be required at brand discretion.
Regular and self-governed testing of all relevant substances by suppliers will help to ensure the widest acceptance of third-party test reports by international
brands.
The Testing Matrix was developed by AFIRM brands utilizing multiple sources of information, including industry RSL testing information, a broad
understanding of global supply chain operations, and from nearly two decades of managing restricted substances across a wide range of materials.
2 Orange = Lower risk. Testing recommended and may be required at brand discretion.
Suppliers must check with their brand customers to understand if they will accept test reports according to this AFIRM Testing Matrix. Individual brand
testing programs, to the extent they are different, supersede the AFIRM RSLTesting Matrix unless a brand indicates otherwise.
It is a goal of the AFIRM Group to reduce the testing burden on suppliers and streamline the RSL testing approach, while further reducing risk of restricted
substances in materials and products. As brands adopt the AFIRM Testing Matrix into their RSL process, suppliers and AFIRM brands will be able to share
test reports and data more easily, reducing the need for multiple RSL test submissions to satisfy different RSL requirements.
NOTE:
The test methods listed in the RSL for specific materials correspond to the Testing Matrix. A blank color code for any material will not have a corresponding
test method. For example, Metal has a blank color code for APEOs and therefore no test method is listed for APEOs in Metal in the RSL. If the RSL states
“All Materials” or “All Materials Except,” this means the test method is applicable to all materials listed with a color of 1 or 2 that do not have a specific test
method listed. AFIRM recommends consulting your testing laboratory to determine the best test method for any material not currently listed in this document.
12
AFIRM Restricted Substances List | 2021
NOTE: For Recycled materials, additional testing may be required at Level 1; check with each brand on requirements.
Polymers
Polycarbonate
PU Foams
Metals
Blends
Rubber
Glue
ABS
PVC
EVA
Acetophenone and 2-Phenyl-2-Propanol 2
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 1 1 1 1 1 1 1 1 1
Azo-amines and Aryl Amine salts 1 1 1 1A 1 1A 1A 1
Bisphenols 2 2 2 2 1 2 2 2
Chlorinated Paraffins 2 1 2 2 1 1 2 2 1 2
Chlorophenols 2 2 2 2
Chlorinated Benzenes and Toluenes 2 2 2
Dimethylfumarate (DMFu) 2
Dyes, Forbidden and Disperse 1 1 1 2
Dyes, Navy Blue 2 2
Flame Retardants 2B
Fluorinated Greenhouse Gases
Formaldehyde 1 1 1 2 1 1C 2 1 1
A Level 1 for dyed/colored materials. D Level 2 for Wool materials. H Level 1 for Cadmium and Lead only; Crystal is exempt L Level 1 if a Fluorinated finish is applied.
B Level 2 if Flame Retardant use or contamination E Level 2 if extractrable Chrome above 1 ppm. for Lead. M Level 1 if Rubber or black Polymeric materials.
is suspected. F Copper is exempt from restriction limits in Metal parts. J Level 1 for PVC materials. N Level 1 for PU-based materials.
C Level 1 for Wood, Paper, and Straw materials. G Level 2 for plant-based fibers; N/A for animal-based fibers. K Level 2 for Styrene/Butadiene Rubbers (SBRs) only.
13
AFIRM Restricted Substances List | 2021
Polymers
Polycarbonate
PU Foams
Metals
Blends
Rubber
Glue
ABS
PVC
EVA
Heavy Metals, Chromium VI 2D 2E 1
Heavy Metals, Extractable 1 1 1 2 1 2F 2 2 2 2 2 2 2 2 2
Heavy Metals, Nickel Release 1
Heavy Metals, Total 2G 2G 1 2 1 1H 1 1 1 1 1 1 1 1 1 2
Monomers, Styrene & Vinyl Chloride 1J 2K 2 1 1J
N-Nitrosamines 2
Organotin Compounds 2 2 1 2 1 1 1 1 1 1 1
Ortho-phenylphenol (OPP) 2 2 2 2 2 2
Ozone-depleting Substances
Phthalates 1 1 1 1 1 2 2 1 1 1 1
Polycyclic Aromatic Hydrocarbons (PAHs) 2 1M 1M 1M 1 1M 1M 1M 1M
Quinoline 2 2
Solvents / Residuals, DMFa 1 1 1 1N 1N
Solvents / Residuals, DMAC and NMP 1 2 2 2 2 2
Solvents / Residuals, Formamide 2 2
UV Absorbers / Stabilizers 2 2 2 2 2 2 2 2
Volatile Organic Compounds (VOCs) 2 2 2 2 2 2 2 2 2 2 1
A Level 1 for dyed/colored materials. D Level 2 for Wool materials. H Level 1 for Cadmium and Lead only; Crystal is exempt L Level 1 if a Fluorinated finish is applied.
B Level 2 if Flame Retardant use or contamination E Level 2 if extractrable Chrome above 1 ppm. for Lead. M Level 1 if Rubber or black Polymeric materials.
is suspected. F Copper is exempt from restriction limits in Metal parts. J Level 1 for PVC materials. N Level 1 for PU-based materials.
C Level 1 for Wood, Paper, and Straw materials. G Level 2 for plant-based fibers; N/A for animal-based fibers. K Level 2 for Styrene/Butadiene Rubbers (SBRs) only.
14
AFIRM Restricted Substances List | 2021
CAS No. Substance Limits Potential Uses & Suitable Test Method Reporting
Component Additional Information Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
15
AFIRM Restricted Substances List | 2021
CAS No. Substance Limits Potential Uses & Suitable Test Method Reporting
Component Additional Information Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
Alkylphenols (APs) ✛
Alkylphenol Ethoxylates (APEOs) ✛
including all isomers
16
AFIRM Restricted Substances List | 2021
CAS No. Substance Limits Potential Uses & Suitable Test Method Reporting
Component Additional Information Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
CAS No. Substance Limits Potential Uses & Suitable Test Method Reporting
Component Additional Information Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
Bisphenols ✛
Chlorinated Paraffins ✛
All materials:
85535-84-8 Short-chain Chlorinated Paraffins (SCCPs) (C10-C13) 1000 ppm Combined CADS/ISO 18219:2015 100 ppm
May be used as softeners, flame
retardants, or fat-liquoring agents method V1:06/17 (extraction ISO
in leather production; also as a 18219 and analysis by GC/NCI/MS)
plasticizer in polymer production.
85535-85-9 Medium-chain Chlorinated Paraffins (MCCPs) (C14-C17) 1000 ppm For more information on the standard 100 ppm
method, click here.
18
AFIRM Restricted Substances List | 2021
CAS No. Substance Limits Potential Uses & Suitable Test Method Reporting
Component Additional Information Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
Chlorophenols ✛
15950-66-0 2,3,4-Trichlorophenol (TriCP)
933-78-8 2,3,5-Trichlorophenol (TriCP) Chlorophenols are polychlorinated
compounds used as preservatives or
933-75-5 2,3,6-Trichlorophenol (TriCP) pesticides.
95-95-4 2,4,5-Trichlorophenol (TriCP) Pentachlorophenol (PCP), All materials:
Tetrachlorophenol (TeCP), and
88-06-2 2,4,6-Trichlorophenol (TriCP) Trichlorophenols (TriCP) are 1 M KOH extraction, 16 hours at 90
0.5 ppm each degrees C, derivatization and analysis 0.5 ppm each
609-19-8 3,4,5-Trichlorophenol (TriCP) sometimes used to prevent mold and
kill insects when growing cotton and § 64 LFGB B 82.02-08 or DIN EN
4901-51-3 2,3,4,5-Tetrachlorophenol (TeCP) when storing/transporting fabrics. ISO 17070:2015
19
AFIRM Restricted Substances List | 2021
CAS No. Substance Limits Potential Uses & Suitable Test Method Reporting
Component Additional Information Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
CAS No. Substance Limits Potential Uses & Suitable Test Method Reporting
Component Additional Information Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
Dimethylfumarate ✛
21
AFIRM Restricted Substances List | 2021
CAS No. Substance Limits Potential Uses & Suitable Test Method Reporting
Component Additional Information Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
Dyes, continued
3179-89-3 C.I. Disperse Red 17
61968-47-6 C.I. Disperse Red 151
119-15-3 C.I. Disperse Yellow 1
2832-40-8 C.I. Disperse Yellow 3
6300-37-4 C.I. Disperse Yellow 7
6373-73-5 C.I. Disperse Yellow 9
6250-23-3 C.I. Disperse Yellow 23
12236-29-2 C.I. Disperse Yellow 39
54824-37-2 C.I. Disperse Yellow 49
Disperse dyes are a class of water-
54077-16-6 C.I. Disperse Yellow 56 insoluble dyes that penetrate the fiber
3761-53-3 C.I. Acid Red 26 system of synthetic or manufactured
fibers and are held in place by
569-61-9 C.I. Basic Red 9 physical forces without forming
chemical bonds. Disperse dyes are
569-64-2 50 ppm each used in synthetic fiber (e.g., polyester, All materials: DIN 54231:2005 15 ppm each
acetate, polyamide).
2437-29-8 C.I. Basic Green 4
Restricted disperse dyes are
10309-95-2 suspected of causing allergic
reactions and are prohibited from use
548-62-9 C.I. Basic Violet 3
for dyeing of textiles.
632-99-5 C.I. Basic Violet 14
2580-56-5 C.I. Basic Blue 26
1937-37-7 C.I. Direct Black 38
2602-46-2 C.I. Direct Blue 6
573-58-0 C.I. Direct Red 28
16071-86-6 C.I. Direct Brown 95
60-11-7 4-Dimethylaminoazobenzene (Solvent Yellow 2)
6786-83-0 C.I. Solvent Blue 4
561-41-1 4,4'-bis(dimethylamino)-4''-(methylamino)trityl alcohol
22
AFIRM Restricted Substances List | 2021
CAS No. Substance Limits Potential Uses & Suitable Test Method Reporting
Component Additional Information Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
Flame Retardants ✛
84852-53-9 Decabromodiphenyl ethane (DBDPE)
32534-81-9 Pentabromodiphenyl ether (PentaBDE)
32536-52-0 Octabromodiphenyl ether (OctaBDE)
1163-19-5 Decabromodiphenyl ether (DecaBDE)
With very limited exceptions, flame-
Various All other Polybrominated diphenyl ethers (PBDEs) retardant substances, including All materials: EN ISO 17881-1:2016
79-94-7 Tetrabromobisphenol A (TBBP A) the entire class of organohalogen
flame retardants, should no longer
59536-65-1 Polybromobiphenyls (PBB) be applied to materials during
production.
3194-55-6 Hexabromocyclododecane (HBCDD) 10 ppm each 5 ppm each
Listed here are examples of flame-
3296-90-0 2,2-bis(bromomethyl)-1,3-propanediol (BBMP) retardant substances used historically
across the apparel and footwear
13674-87-8 Tris(1,3-dichloro-isopropyl) phosphate (TDCPP) industry. It is not intended to be a
complete list
25155-23-1 Trixylyl phosphate (TXP)
126-72-7 Tris(2,3,-dibromopropyl) phosphate (TRIS)
All materials: 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)
23
AFIRM Restricted Substances List | 2021
CAS No. Substance Limits Potential Uses & Suitable Test Method Reporting
Component Additional Information Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
Formaldehyde ✛
Extractable:
All materials except Leather:
DIN EN 16711-2:2016
Extractable: Arsenic and its compounds can be Extractable:
used in preservatives, pesticides, and Leather: DIN EN ISO 17072-1:2019
7440-38-2 Arsenic (As) 0.2 ppm 0.1 ppm
defoliants for cotton, synthetic fibers, Total:
Total: 100 ppm paints, inks, trims, and plastics. Total: 10 ppm
All materials except Leather:
DIN EN 16711-1:2016
Leather: DIN EN ISO 17072-2:2019
24
AFIRM Restricted Substances List | 2021
CAS No. Substance Limits Potential Uses & Suitable Test Method Reporting
Component Additional Information Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
Extractable:
All materials except Leather:
Cadmium compounds may be DIN EN 16711-2:2016 Extractable:
Extractable: used as pigments (especially in red, Leather: DIN EN ISO 17072-1:2019 0.05 ppm
7440-43-9 Cadmium (Cd) 0.1 ppm orange, yellow and green); as a
Total: Total: 5 ppm
Total: 40 ppm stabilizer for PVC; and in fertilizers,
biocides, and paints. All materials except Leather:
DIN EN 16711-1:2016
Leather: DIN EN ISO 17072-2:2019
Textiles:
DIN EN 16711-2:2016 with EN ISO
17075-1:2017 if Cr is detected
Though typically associated with
Leather: EN ISO 17075-1:2017
Extractable: leather tanning, Chromium VI also Extractable:
and EN ISO 17075-2:2017 for
may be used in the “after-chroming”
18540-29-9 Chromium VI ✛ Leather: 3 ppm confirmation in case the extract Leather: 3 ppm
process for wool dyeing (Chrome
Textiles 1 ppm causes interference. Alternatively, EN Textiles: 0.5 ppm
salts applied to acid-dyed wool to
ISO 17075-2:2017 may be used on
improve fastness).
its own.
Ageing test: ISO 10195:2018 Method
A2 is used at brand discretion.
Extractable:
Cobalt and its compounds can be All materials except Leather:
Adults: 4 ppm DIN EN 16711-2:2016 Extractable:
7440-48-4 Cobalt (Co) used in alloys, pigments, dyestuff,
0.5 ppm
Children and and the production of plastic buttons. Leather: DIN EN ISO 17072-1:2019
babies: 1 ppm
25
AFIRM Restricted Substances List | 2021
CAS No. Substance Limits Potential Uses & Suitable Test Method Reporting
Component Additional Information Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
Extractable:
All materials except Leather:
Extractable: DIN EN 16711-2:2016
May be associated with alloys,
Adults and plastics, paints, inks, pigments and Leather: DIN EN ISO 17072-1:2019 Extractable:
7439-92-1 Lead (Pb) children: 1 ppm surface coatings. Total: 0.1 ppm
Babies: 0.2 ppm Crystal or “lead glass” is exempt from Non-metal: CPSC-CH-E1002-08.3 Total: 10 ppm
Total: 90 ppm total Lead restrictions.
Metal: CPSC-CH-E1001-08.3
Lead in paint and surface coatings:
CPSC-CH-E1003-09.1
Extractable:
All materials except Leather:
DIN EN 16711-2:2016 Extractable:
Extractable: Mercury compounds can be present
in pesticides and as contaminants in Leather: DIN EN ISO 17072-1:2019 0.02 ppm
7439-97-6 Mercury (Hg) 0.02 ppm
caustic soda (NaOH). They may also Total: Total: 0.1 ppm
Total: 0.5 ppm be used in paints.
All materials except Leather:
DIN EN 16711-1:2016
Leather: DIN EN ISO 17072-2:2019
Extractable:
Extractable: 1 ppm All materials except Leather:
DIN EN 16711-2:2016
Release (metal parts): Nickel and its compounds can be Extractable:
used for plating alloys and improving Leather: DIN EN ISO 17072-1:2019
Prolonged skin 0.1 ppm
7440-02-0 Nickel (Ni) ✛ contact: corrosion-resistance and hardness Release:
of alloys. They can also occur as Release:
0.5 µg/cm²/week EN 12472:2005+ A1:2009 and 0.5 μg/cm²/week
impurities in pigments and alloys. EN 1811:2011+A1:2015
Eyewear frames:
0.5 µg/cm²/week Release (eyewear frames):
EN 16128:2015
26
AFIRM Restricted Substances List | 2021
CAS No. Substance Limits Potential Uses Suitable Test Method Reporting
Component Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
Paints & Coatings: Antimony and its compounds can be ASTM F2923:2020 Extractable:
7440-36-0 Antimony (Sb) Extractable: used as a Flame Retardant in paints,
60 ppm as well as a colorant in pigments. * 5 ppm
a contaminant
27
AFIRM Restricted Substances List | 2021
CAS No. Substance Limits Potential Uses Suitable Test Method Reporting
Component Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
Release (metal
parts): Nickel and its compounds can be Release:
used for plating alloys and improving EN 12472:2005+A1:2009 and Prolonged skin
Prolonged skin
the corrosion-resistance and EN 1811:2011+A1:2015 contact:
7440-02-0 Nickel (Ni) ✛ contact:
hardness of alloys. They can also 0.5 μg/cm²/week
0.5 µg/cm²/week
Pierced part:
occur as impurities in pigments and
alloys.
* Pierced part:
0.2 μg/cm²/week
0.2 µg/cm²/week
28
AFIRM Restricted Substances List | 2021
CAS No. Substance Limits Potential Uses & Suitable Test Method Reporting
Component Additional Information Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
Monomers ✛
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
924-16-3 N-nitrosodibutylamine (NDBA) using GC/MS, with LC/MS/MS
Can be formed as by-product in the verification if positive.
100-75-4 N-nitrosopiperidine (NPIP) 0.5 ppm each 0.5 ppm each
production of rubber. Alternatively, LC/MS/MS may
930-55-2 N-nitrosopyrrolidine (NPYR) be performed on its own.
EN ISO 19577:2019
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)
29
AFIRM Restricted Substances List | 2021
CAS No. Substance Limits Potential Uses & Suitable Test Method Reporting
Component Additional Information Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
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 All materials:
Various Trimethyltin (TMT) used as biocides (e.g., antibacterials), CEN ISO/TS 16179:2012 or 0.1 ppm each
catalysts in plastic and glue production, EN ISO 22744-1:2020
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
Various Triphenyltin (TPhT) products and heat transfer material.
Ortho-phenylphenol ✛
All materials:
OPP is used for its preservative 1 M KOH extraction, 16 hours at 90
90-43-7 Ortho-phenylphenol (OPP) 1000 ppm properties in leather or as a carrier in degrees C, derivatization and analysis 100 ppm
polyester dyeing processes. § 64 LFGB B 82.02-08 or DIN EN
ISO 17070:2015
Ozone-depleting Substances ✛
30
AFIRM Restricted Substances List | 2021
CAS No. Substance Limits Potential Uses & Suitable Test Method Reporting
Component Additional Information Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
Various Perfluorooctane Sulfonate (PFOS) and related substances 1 µg/m2 total 1 µg/m2 total
PFOA and PFOS may be present as
unintended byproducts in long-chain
and short-chain commercial water-,
oil-, and stain-repellent agents. PFOA
may also be used in polymers like
Various Perfluorooctanoic Acid (PFOA) and its salts 25 ppb total Polytetrafluoroethylene (PTFE). All materials: EN ISO 23702-1 25 ppb total
Refer to Appendix A for the full list
of substances and CAS Numbers
included in this restriction. In
addition to this list, all PFOA-related
substances are prohibited from use.
Various PFOA-related substances 1000 ppb total 1000 ppb total
All materials:
May be found in natural fibers, ISO 15913/DIN 38407 F2 or
Various See Appendix B for a complete list. 0.5 ppm each 0.5 ppm each
primarily cotton. EPA 8081/EPA 8151A or
BVL L 00.00-34:2010-09
31
AFIRM Restricted Substances List | 2021
CAS No. Substance Limits Potential Uses & Suitable Test Method Reporting
Component Additional Information Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
Phthalates ✛
28553-12-0 Di-Iso-nonylphthalate (DINP)
117-84-0 Di-n-octylphthalate (DNOP)
117-81-7 Di(2-ethylhexyl)-phthalate (DEHP)
26761-40-0 Diisodecylphthalate (DIDP)
85-68-7 Butylbenzylphthalate (BBP)
84-74-2 Dibutylphthalate (DBP)
Esters of ortho-phthalic acid
84-69-5 Diisobutylphthalate (DIBP) (Phthalates) are a class of organic
compound commonly added to
84-75-3 Di-n-hexylphthalate (DnHP) plastics to increase flexibility. They
are sometimes used to facilitate the
84-66-2 Diethylphthalate (DEP) molding of plastic by decreasing its
131-11-3 Dimethylphthalate (DMP) melting temperature.
Phthalates can be found in: Sample preparation for all materials:
131-18-0 Di-n-pentyl phthalate (DPENP) CPSC-CH-C1001-09.4
• Flexible plastic components
84-61-7 Dicyclohexyl phthalate (DCHP) (e.g., PVC) Measurement:
1,2-Benzenedicarboxylic acid, di-C6-8-branched alkyl • Print pastes Textiles:
71888-89-6 500 ppm each
esters, C7-rich • Adhesives GC/MS, EN ISO 14389:2014
Total: 1000 ppm (7.1 Calculation based on weight 50 ppm each
117-82-8 Bis(2-methoxyethyl) phthalate • Plastic buttons
of print only; 7.2 Calculation based
• Plastic sleevings on weight of print and textile if print
605-50-5 Diisopentyl phthalate (DIPP)
• Polymeric coatings cannot be removed).
131-16-8 Dipropyl phthalate (DPRP) All materials except textiles:
Listed here are all legally restricted
27554-26-3 Diisooctyl phthalate (DIOP) phthalates as well as those included GC/MS
on the REACH substances of very
68515-50-4 Di-hexylphthalate, branched and linear (DHxP) high concern (SVHC) candidate list
71850-09-4 Diisohexyl phthalate (DIHxP) at the time of publication. Suppliers
should assume that the AFIRM RSL
1,2-Benzenedicarboxylic acid, di-C7-11-branched and includes all phthalates on the SVHC
68515-42-4 list—whether itemized here or not—
linear alkyl esters (DHNUP)
since the list is updated frequently.
1,2-Benzenedicarboxylic acid
84777-06-0
Dipentyl ester, branched and linear
1,2-Benzenedicarboxylic acid, di-C6-10-alkyl esters or
68648-93-1 mixed decyl and hexyl and octyl diesters with ≥ 0.3% of
dihexyl phthalate; 1,2-Benzenedicarboxylic acid, mixed
68515-51-5 decyl and hexyl and octyl diesters; 1,2-Benzenedicarboxylic
acid, di-C6-10-alkyl esters
776297-69-9 n-Pentyl-isopentylphthalate (nPIPP)
32
AFIRM Restricted Substances List | 2021
CAS No. Substance Limits Potential Uses Suitable Test Method Reporting
Component Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
Quinoline ✛
33
AFIRM Restricted Substances List | 2021
CAS No. Substance Limits Potential Uses Suitable Test Method Reporting
Component Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
UV Absorbers / Stabilizers ✛
3846-71-7 UV 320
For informational
purposes only. Used as UV Absorbers for Plastics
AFIRM (PVC, PET, PC, PA, ABS, and
2440-22-4 Drometrizole
recommends other Polymers), Rubber, and
testing to assess Polyurethane.
content levels.
34
AFIRM Restricted Substances List | 2021
CAS No. Substance Limits Potential Uses Suitable Test Method Reporting
Component Sample Preparation & Measurement Limit
Materials in Limits above which
Finished Product test results should
be reported
35
AFIRM Restricted Substances List | 2021
36
AFIRM Restricted Substances List | 2021
37
www.afirm-group.com