Feature

Chemicals of
Future Concern
By Nicola Davies

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Vol. 15, No. 5

September/October 2015

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Feature

C

hemicals play a crucial role in the textile industry.
Without chemicals, the production of yarn, fabric,
garments, and other textile products would be close
to impossible on an industrial basis. In addition, the
available textile products would be whatever color the
color the natural fiber was when it was harvested—since
synthetic and manmade fibers require chemistry, and
even “natural” dyes are also chemicals. And many of the
high performance attributes beloved by both brands and
consumers would simply not exist.
However, chemicals are a tool that must be used
carefully. While a great many chemicals are useful in
textile manufacturing, some of those chemicals are
harmful to humans or the environment. The challenge
is in identifying which chemicals are of concern, and in
developing safer alternatives that are still effective.

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Feature

REACH
REACH (the Registration, Evaluation, Authorization, and Restriction of Chemicals), a European
Union (EU)-wide regulation for chemicals, is based
on the principle that it is the industry’s responsibility and duty to ensure that chemical substances
placed on the EU market are used in a safe manner,
says Mikko Väänänen, press officer at the European
Chemicals Agency (ECHA). He explained that as
part of REACH regulation, substances of very high
concern (SVHCs) are identified and included in
the Candidate List. When a substance is listed in
the Candidate List, EU importers or manufacturers
of articles containing these substances must notify
ECHA within six months of its inclusion in the list.
ECHA has received notifications reporting the use of
five SVHCs in fabrics or textiles:
•• three phthalates—di; (2-ethylhexyl)phthalate
(DEHP), dibutyl phthalate (DBP), and diisobutyl
phthalate (DiBP)
•• decabromodiphenyl ether (decaBDE), and
•• short-chain chlorinated paraffins (SCCPs)
Information from registration dossiers indicate the
possible use of four other SVHCs in textiles: hexabromocyclododecane (HBCD), boric acid, disodium
tertaborate anhydrous, and sodium dichromate.

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As far as banned/restricted substances are concerned, Väänänen says, “The REACH Regulation
already restricts the use of certain substances in
textiles, due to their risk for human health (workers and/or consumers) and/or the environment. For
example, this is the case for polybromobiphenyls and
polybrominatedbiphenyls (PBB), some organostannic compounds, and azocolorants and azodyes,
which are restricted in textile articles via entries 8,
20, and 43 of Annex XVII to REACH, respectively
(non-exhaustive list).”
Other chemicals like perfluorooctanesulfonic
acid (PFOS), nickel, dimethylfumarate (DMFu),
and some brominated flame retardants are also
restricted under REACH. Denmark has sought a
ban on hexavalent chromium in leather. Phthalates
are included in the Authorization List published by
ECHA. Lisa Anfält from ECHA has commented that
the proposals are under consideration.
In 2005, the US Environmental Protection Agency
(EPA) also issued a significant new use regulation
regarding the use of six polybrominated diphenyl
ethers (PBDEs) in textiles, and proposed a significant new use rule for decaBDE and HBCD in 2012.

Of Very High Concern
According to REACH article 57, SVHCs fall into one
of the following categories:

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Feature

•• they are either carcinogenic, mutagenic, or toxic
to reproduction (CMR);
•• they are persistent, bio-accumulative, and toxic
(PBT), or very persistent and very bio-accumulative (vPvB); and/or
•• they are “substances of equivalent level of concern,” such as endocrine disruptors.
The majority of these substances are unregulated,
with no data available. In addition, of the known
hazardous chemicals used in the textile industry,
most are yet to be completely phased out and substituted with safer alternatives. Consequently, various
government and private organizations, member
states, companies, and non-governmental organizations (NGOs) have their own Restricted Substances
Lists (RSL), which includes chemicals that are
banned or restricted for use in products or manufacturing processes by regulation or law.

Restricted Substance Lists
Company and organization’s RSLs often also include
non-legislated chemicals identified as hazardous.
These RSLs are updated on a regular basis and
are communicated throughout the supply chain.
Danielle Iverson, government relations manager at
American Apparel & Footwear Association (AAFA),
says, “The AAFA Restricted Substances List is a
valuable resource for identifying chemicals used in
apparel, footwear, and home textiles that have been
restricted or prohibited by regulation.”

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Gloria Conti, regulatory assistance officer at the
Department of Toxic Substances Control (DTSC)
in California, USA, adds that their Safer Consumer
Products regulations may touch on this. They have
currently identified a “first-priority products” list,
including tris (1,3-dichloro-2-propyl) phosphate
(TDCP) that is often used in padded sleeping products for children. However, a global RSL isn’t possible
due to several factors, including but not limited to:
different products and target markets, country regulations, and testing methods. Nevertheless, many RSLs
more or less contain the same chemicals.

Zero Discharge
On behalf of the Textile Exchange, a global nonprofit working on textile sustainability, the Director
of Corporate Responsibility at the Outdoor Industry Association, Beth Jensen, said that the two key
collaborative working groups looking specifically at
chemicals management in the apparel and footwear
sector are the Chemicals Management Working
Group (a partnership between Outdoor Industry
Association and the Sustainable Apparel Coalition)
and the Zero Discharge of Hazardous Chemicals
effort. These groups are leveraging one another’s
tools and efforts to minimize duplication of work
wherever possible—particularly given the significant number of companies who are members of
both groups.
The Zero Discharge of Hazardous Chemicals, an
initiative of a non-profit organization known as
International Chemical Secretariat ChemSe based in

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Sweden, issues a Manufacturing Restricted Substances List for the apparel and footwear industry to
prohibit or restrict the use of hazardous chemicals.
The group includes big companies like Nike, Adidas,
Puma, and H&M. Their RSL not only includes
chemicals found in finished products, but also the
ones used and discharged during manufacturing.
Certain isomers of chlorobenzenes and chlorotoluenes, azo dyes (of carcinogenic or equivalent
concern), flame retardants, glycols, halogenated
solvents, and phthalates are included in the list.
However, the mapping of the chemicals is nonexhaustive in nature.

The latest update of the SIN list includes bisphenol F
and bisphenol S, which were once used to replace
bisphenol A but were equally harmful. Similarly, PBTs
were replaced by persistent organic pollutants (POPs).

Searching for Solutions

Design for the Environment (DfE) is a partnership
program of the US EPA, which offers an Alternatives Assessment Program for stakeholders to choose
safer alternatives. Iverson explains that alternatives
assessment provides a basis for informed decisionmaking by developing an in-depth comparison of
potential human health and environmental impacts.
DfE applied this approach to find alternatives to
substances including nonylphenol ethoxylate (NPE)
surfactants, phthalates, decaBDE, HBCD, and bisphenol A. EPA releases the final reports on its website,
after multiple assessment reports, including all the
safer alternatives and their assessments to see if they
are more or equally harmful.

Now that these chemicals are banned or restricted
to use, the industry must find safer alternatives to
them. Väänänen recommends the SUBSPORT project for specific details about possible substitutes to
chemicals of concern, including examples of replacements. SUBSPORT, a project of Kooperationsstelle
Hamburg IFE GmbH, is a database of substitutions
for hazardous chemicals in the textile sector. It also
has a Restricted and Priority Substances Database
containing 32 lists of substances. The lists can be
categorized into five groups:
•• International agreements
•• EU regulatory lists
•• Governmental lists
•• NGOs
•• Trade union lists
•• Company lists
SUBSPORT lists the restricted substances along with
each of the lists where they appear, to give a clear
picture about what is banned and by whom.

Substitutions

One of the most common sources that lists chemicals of concern is the Substitute It Now! (SIN) list by
ChemSec. The list carries SVHCs on the basis of the
criteria set by REACH. The list is regularly updated
and is recognized by such bodies as the European
Commission and the United Nations Environment
Programme. Various health, environmental, and
consumer NGOs, companies, investors, and regulators use SIN lists for sustainable substitution work
and informed decisions. As of February 2013, there
were 626 substances termed as SVHCs by ChemSec.
DOI: 10.14504/ar.15.5.2

ChemSec Director, Anne-Sofie Andersson, notes that,
“The SIN List update focuses on sustainable innovation, on developing products that are truly safer in
the long run.” It not only identifies the substances to
be phased out but also conducts Substances Alternative Assessments to move towards safer alternatives to
hazardous substances.

Alternatives

Chemicals of Future Concern
Recently, EU member states unanimously voted to
amend REACH’s Entry 46 of Annexure XVIII, relating to nonylphenol and nonylphenol ethoxylates (NPs
and NPEs). These chemical compounds are toxic to
aquatic life and biodegrade into endocrine disruptors.
REACH already bans these chemicals’ use in textile
manufacturing within Europe. This new REACH
amendment means that in the near future, the ban
will extend to textile products imported into the EU
that are manufactured using these chemicals. NPEs
are very popular in textile auxiliary formulations
and used widely across the entire textile manufacturing supply chain, from pesticide formulations used
in growing cotton to spinning yarn, knitting and
weaving, dyeing and printing, and even finishing and
laundering. This legislation would mean, in effect, a
broad ban against these chemicals across the entire
textile supply chain if manufacturers wish to sell textile products in Europe.
Slowly but surely, the textile industry is working to
clean up its act.

September/October 2015

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