AAFA Releases 25th Edition of Restricted Substances List (RSL) and Comparison

Recently, the American Apparel and Footwear Association (AAFA) released the 25th edition of its Restricted Substances List (RSL). The list serves as an open resource for association members and the entire industry, providing a reference for all prohibited and restricted chemicals and substances in finished apparel, footwear, accessories, and home textiles. It clarifies the most stringent regulations globally. The report also includes an appendix regarding reporting requirements, covering U.S. state regulations for reporting chemicals in children's products, as well as European reporting rules.

The 25th edition of the RSL covers 16 categories and includes more than 250 chemicals. It is updated to reflect changes or additions to laws and regulations that restrict or ban the use of certain chemicals in finished apparel, footwear, accessories, and home textiles. The RSL was first published in 2007 and is compiled by the AAFA's Restricted Substances List Working Group, which regularly reviews and updates the list to reflect global regulatory changes.

- Covered Substances: Includes materials and chemicals banned or restricted by regulations in finished products, excluding production processes and packaging materials. It does not cover product safety regulations outside of chemical management, such as those for toys and automotive textiles.

   - AP and APEO: Different countries and regions have varying restrictions on chemicals like nonylphenol (NP) and nonylphenol ethoxylates (NPEO), with specific limits and testing methods in places like Taiwan, South Korea, and the EU.

   - Aromatic Amines: Various countries have restrictions on multiple aromatic amines, with differing regulations and testing methods across regions.

   - Polychlorinated Dibenzo-p-Dioxins and Furans: Countries like Germany set strict limits on these substances, and the U.S. EPA provides industry testing methods.

   - Disperse Dyes: The EU and others impose limits on various disperse dyes, with differing concentrations and applicable product categories.

   - Flame Retardants: Several U.S. states and other countries restrict various flame retardants, with different product categories and limit requirements, using solvent extraction combined with instrumental analysis for testing.

   - Formaldehyde: Countries like China and the EU have formaldehyde limits, with varying standards for different countries and product types.

   - Heavy Metals: Includes extractable and soluble heavy metals, with clear regulations for lead, cadmium, and others in various countries.

   - Other Substances: Includes azo dyes, organotin compounds, polycyclic aromatic hydrocarbons (PAHs), pesticides, PFAS, phthalates, solvents, and more, with varying restrictions.

- Terminology Explanation: Provides definitions and clarifications of professional terms and abbreviations used in the list for better understanding.

- Reporting Requirements: 

   - Appendix IA: Lists the EU's SVHC (Substances of Very High Concern) reporting and registration requirements.

   - Appendix IB: Details reporting requirements for certain chemicals in children's products across various U.S. states.

Compared to the 2023 edition, the 2025 RSL adjusts regulations and testing methods for several chemicals, aligning the list with the latest industry standards and regulatory requirements.

- AP and APEO: Updated based on new proposals from the EU and Morocco, exempting second-hand clothing from some regulations.

- Aromatic Amines: Updates to regulations in Egypt, Indonesia, and Japan, along with new rules in Saudi Arabia, India, and Morocco. Testing methods for 4-amino-azo-benzene have also been adjusted.

- Disperse Dyes: The 2025 version adds 14 disperse dyes to South Korea's safety quality standard (KC Mark) and includes new regulations for the UAE and India.

- Flame Retardants: Maryland's regulations on flame retardants are incorporated, with updated testing methods for brominated diphenyl ethers, new limits for POPs (persistent organic pollutants), and upcoming changes in Japan.

- Formaldehyde: Deletes prior provisions for non-direct skin-contact fabrics, and adds restrictions from Egypt, Morocco, and India to the notes section, aligning with the REACH regulation for non-leather textiles (75 ppm limit).

- Heavy Metals (Extractable): The 2025 version adds heavy metal standards from Saudi Arabia, India, Morocco, and Egypt, updating stricter regulations on hexavalent chromium (Cr VI) and chromium (Cr), along with updated testing methods.

- Heavy Metals (Soluble): Updated testing methods and regulatory references for heavy metals in South Korea and Taiwan.