1. Background

The ZDHC Manufacturing Restricted Substances List (ZDHC MRSL) is a list of chemical substances banned from intentional use in the processing of textile materials, leather, rubber, foam, adhesives and trims used in textiles, apparel, and footwear industry. Intentional use means the substance used deliberately in a chemical product to achieve a desired look or functionality.

The ZDHC MRSL goes beyond the traditional approaches to chemical restrictions, which only apply to finished products (Restricted Substances List - RSL) and is focused on consumer safety. The MRSL approach also helps protect workers, local communities, and the environment from the possible impacts of harmful chemicals.

Chemical formulations covered by restrictions in the ZDHC MRSL include, but are not limited to, cleaners, adhesives, paints, inks, detergents, dyes, colourants, auxiliaries, coatings and finishing agents used during raw material production, wet processing, process machinery maintenance, wastewater treatment, sanitation, and pest control. ZDHC MRSL limits apply to substances in commercially available formulations, not those from earlier stages of chemical synthesis.

Using chemical formulations that conform to the ZDHC MRSL allows suppliers to assure themselves, and their customers, that banned chemical substances are not intentionally used during production and manufacturing processes.

The ZDHC Roadmap to Zero Programme would like to acknowledge the vital role of the experts comprising the MRSL Council who independently and objectively evaluated the proposed additions/ revisions to the ZDHC MRSL V3.1 and made decisions.

2. Purpose

The ZDHC MRSL offers brands and suppliers a single, harmonised list of chemical substances banned from intentional use during manufacturing and related processes in supply chains of the textile, apparel, and footwear (including leather, rubber and foam) industries (the Industry).

Version 3.1 applies to textiles, leather, rubber, foam and adhesives. Recognising that these materials use different processes, search filters can be used to search the limits for each material.

The ZDHC MRSL does not replace legal or brand-specific restrictions on harmful substances in materials or finished products.

3. NOTES

The ZDHC MRSL 3.1 published by ZDHC Foundation does not guarantee the following:

1. Compliance with, or to take the place of, legal or regulatory requirements. Examples might include: stricter legal, local or regional regulatory requirements on the use, storage and transport of chemical products; or other requirements relating to the handling and disposal of chemical products, which shall supersede any requirements as set forth in this document.

2. Compliance with, or conformance to, any national or international environmental or workplace safety requirements, including, but not limited to, relevant regulations and/or standards.

3. Nor do the ZDHC MRSL 3.1 replace any national or international environmental or workplace safety requirements including, but not limited to, regulations and/ or standards.

The ZDHC MRSL 3.1 is not intended nor can be used as a statement of legal requirements.

ZDHC refers to the UN GHS (Globally Harmonized System of Classification and Labelling of Chemicals) as the internationally recognised standard for hazardous material classification and labelling. All the other National/Regional existing schemes, derived from the implementation of the GHS, have to be considered included in the list of the accepted ZDHC standards for this purpose. To simplify the ZDHC MRSL V3.1 comprehension, ZDHC uses GHS throughout as its reference for Hazard Statements and Pictograms in SDS and labels in order to avoid local variables.

4. DISCLAIMERS

ZDHC has made every reasonable effort to make sure that the content and information contained in the ZDHC MRSL 3.1 is as accurate and correct as possible at the time of publication. ZDHC makes no claims, promises, or guarantees about the accuracy, completeness, or adequacy of the contents of this document.

In no event will ZDHC (and/or any related ZDHC majority owned legal entities) or the Directors or staff thereof be liable and ZDHC expressly disclaims any liability of any kind to any party for any loss, damage, or disruption caused:

1. By errors or omissions, whether such errors or omissions result from negligence, accident, or any other cause and/or;

2. From any use, decision made or action taken or any other kind of reliance on the ZDHC MRSL 3.1 by a reader or user of it and/or;

3. For any results obtained or not obtained from the use of the ZDHC MRSL 3.1.

For the avoidance of doubt this Disclaimer applies to all related documents produced by ZDHC, specifically: ZDHC Wastewater Guidelines, ZDHC Sludge Reference Document, ZDHC Wastewater and Sludge Laboratory Sampling and Analysis Plan and ZDHC Wastewater Industry Implementation Approach etc.

5. ZDHC MRSL Chapters

5.1 Chapter 1: ZDHC MRSL

This applies to chemical formulations and substances used during the wet processing of substrates (Textile, Leather, Polymers -Rubber, Foam, Adhesives)

The MRSL substances are listed with applicable CAS numbers and provided with Applicability filters for substrates (Textile, Leather, Polymers -Rubber, Foam, Adhesives), Supplier Guidance, Formulation Limit and Methods of Analysis.

Supplier Guidance includes:

• No intentional use: these substances are banned from intentional use in facilities that process raw materials and manufacture finished products

• Not applicable: these substances are not applicable to the specific substrates

• No restriction: these substances are not restricted for the specific substrates

Formulation limits are concentration limits for the substances in commercial chemical formulations available from chemical manufacturers. These limits ban intentional use while allowing for reasonable expected manufacturing impurities, which should be consistently achievable by responsible chemical manufacturers.

Methods of Analysis describe general techniques of testing and wherever available, specific test methods.

In the ZDHC MRSL Table, R,F,A stands for Rubber, Foam and Adhesives

5.2 Chapter 2: ZDHC MRSL Candidate List

Substances proposed for addition to the ZDHC MRSL update, as described in the Principles and Procedures, as they lack safer alternatives at scale or more information on the same needs to be collected. Substances on the Candidate List encourages the innovation of alternatives.

5.3 Chapter 3: ZDHC MRSL Archived Substances

Substances without strong evidence of current use in Industry, but with clear evidence of historical use. The Archived Substances should not be reintroduced by a chemical manufacturer in their commercial chemical products. This list should be reviewed by ZDHC Approved MRSL Certifier through the chemical product’s Safety Data Sheet or any other relevant document to confirm absence of these substances in the chemical formulation that is being certified for ZDHC MRSL Conformance.

6. Process for ZDHC MRSL Revision

The ZDHC MRSL is a living document and since its initial release in 2015 the ZDHC MRSL has been regularly updated. The update process is described in ZDHC MRSL Principles and Procedures.

7. Transition Period

After the release of a new version of the ZDHC MRSL a transition period applies. This lets the Industry prepare for the implementation of the new version. The current transition period is twelve months, beginning on 01 November 2022. During this time, both versions of the ZDHC MRSL remain active and it’s possible to certify against them.