The ZDHC Manufacturing Restricted Substances List (ZDHC MRSL) is a list of chemical substances. These substances are banned from intentional use in facilities processing textile materials, leather, rubber, foam, adhesives and trim parts in textiles, apparel, and footwear. 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 MRSL goes beyond the traditional approaches to chemical restrictions, which only apply to finished products (Product Restricted Substances List - PRSL). This approach helps to protect consumers while minimising the possible impact of banned hazardous chemicals on production workers, local communities, and the environment.
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.
The ZDHC Foundation Roadmap to Zero Programme would like to acknowledge the vital role of the experts comprising the MRSL Advisory Council who independently and objectively evaluated the proposed compound additions to the MRSL and made the decision on the compounds added to this version of the ZDHC MRSL.
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 and rubber) industries (the Industry).
Version 2.0 applies to textiles, leather, rubber, foam and adhesives, recognising that these materials use different processes. Filters for each material ensure limits reflect the processes.
The information in this ZDHC MRSL V2.0 is provided for information only. Whilst ZDHC takes every reasonable effort to make sure that the information is as accurate as possible, ZDHC makes no claims, promises, or guarantees about the accuracy, completeness, or adequacy of the contents of this document.
"Meeting the requirements of the ZDHC MRSL V2.0 does not
a) replace applicable national environmental or workplace safety restrictions. Worker exposure to chemical substances listed in this document, along with other hazardous substances, must not exceed occupational exposure limits
b) guarantee compliance with or take the place of legal or regulatory requirements relating to the use, storage, and transport of chemical products."
The ZDHC MRSL V2.0 does not replace legal or brand-specific restrictions on hazardous substances in finished products, including the material components of them.
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
a) by errors or omissions, whether such errors or omissions result from negligence, accident, or any other cause and/or
b) from any use, decision made, action taken, or any other kind of reliance on the ZDHC MRSL V2.0 by a reader or user of it and/or
c) for any results obtained or not obtained from the use of the ZDHC MRSL V2.0
d) by any updates to the ZDHC MRSL V2.0
This applies to chemical formulations and substances used during creation and wet processing of textile fibres, and during creation and processing of (coated) fabrics, leather, rubber, foam and adhesives.
Group A substances are banned from intentional use in facilities that process raw materials and manufacture finished products.
Group B substances are restricted to concentration limits in chemical formulations commercially available from chemical suppliers. These limits ban intentional use while allowing for reasonable expected manufacturing impurities, which should be consistently achievable by responsible chemical manufacturers.
Found in Chapter 2 of the ZDHC MRSL. Proposed ZDHC MRSL additions can meet listing criteria, as described in the Principles and Procedures, yet lack safer alternatives at scale. Including such substances on the Candidate List encourages the innovation of alternatives.
Archived substances, or those without strong evidence of current use in Industry, but with clear evidence of historical use.
The ZDHC MRSL is a living document. It is updated as needed to expand the materials and processes covered and to add substances that should be phased out of the value chain. The Principles and Procedures document contains and explains the process used to update the ZDHC MRSL. Part of this process allows anyone to submit suggested changes to it. This includes the limits for existing compounds, the addition of new compounds, or delisting compounds through the ZDHC MRSL Submission Platform, which will be launched in the coming months.
ZDHC MRSL Update Principles and ProceduresAfter the release of a new version of the ZDHC MRSL a transition period applies. This lets the Industry prepare for implementation of the new version. The current transition period is twelve months, beginning on January 1st 2020. During this time, both versions of the ZDHC MRSL remain active and it’s possible to certify against them.
MRSL Industry Standard Implementation Approach
Appendix
Change Log
Potential Uses in Apparel and Footwear Textile Processing
APEOs can be used as or found in: detergents, scouring agents, spinning oils, wetting agents, softeners, emulsifier/dispersing agents for dyes and prints, impregnating agents, de- gumming for silk production, dyes and pigment preparations, polyester padding and down/feather fillings.
Potential Uses in Apparel and Footwear Textile Processing
These substances have biocidal properties, making it useful for Multiple preservation applications.
In most situations, deliberate use is not permitted. However, it should be noted that Permethrin is approved for use on PT18 under BPR and is permitted for use on wool curtains and carpets, rugs and floor coverings. Permethrin is permitted for PPE use (EU 2016/425, EPA registered product, APVMA Registered Product, PMRA Registered Product, etc.). Also, its use is sometimes stipulated for certain end uses such as military. All efforts should be made to maximise the durability of the chemical finish and to minimise losses to the environment.
Potential Uses in Apparel and Footwear Textile Processing
These are used occasionally as flame retardants in certain industries. In leather formulations, these are also used as fat liquoring agents.
Potential Uses in Apparel and Footwear Textile Processing
Chlorobenzenes and Chlorotoluenes (chlorinated aromatic hydrocarbons) can be used as carriers in the dyeing process of polyester or wool/polyester fibres. They can also be used as solvents.
Potential Uses in Apparel and Footwear Textile Processing
Chlorophenols are polychlorinated compounds used as preservatives or pesticides. Pentachlorophenol (PCP) and tetrachlorophenol (TeCP) have been used in the past to prevent mould when storing/ transporting raw hides and leather. They are now regulated and should not be used.
Potential Uses in Apparel and Footwear Textile Processing
Azo dyes and pigments are colourants that incorporate one or several azo groups (-N=N-) bound with aromatic compounds. Thousands of azo dyes exist, but only those that degrade to form the listed cleavable amines are restricted. Azo dyes that release these amines are regulated and should no longer be used for the dyeing of textiles. Please find a non-exhaustive list of dyes which can form restricted amines in the appendix.
Potential Uses in Apparel and Footwear Textile Processing
Most of these substances are regulated and should no longer be used for the dyeing of textiles.
Potential Uses in Apparel and Footwear Textile Processing
Disperse dyes are a class of water- insoluble dyes that penetrate the fibre system of synthetic or manufactured fibres and are held in place by physical forces without forming chemical bonds. Disperse dyes are used in synthetic fibre (e.g. polyester, acetate, polyamide). Restricted disperse dyes are suspected of causing allergic reactions and should no longer be used for dyeing of textiles.
Potential Uses in Apparel and Footwear Textile Processing
Navy Blue Colourant is regulated and should no longer be used for the dyeing of textiles.
Potential Uses in Apparel and Footwear Textile Processing
Flame retardant chemicals are rarely used to meet flammability requirements in children’s clothing and adult products. They should no longer be used in apparel and footwear.
All Halogenated Flame Retardants are banned from intentional use that means including but not exclusive the list below;
Potential Uses in Apparel and Footwear Textile Processing
In apparel and footwear, glycols have a wide range of uses including as solvents for finishing/ cleaning, printing agents, and dissolving/ diluting fats, oils, and adhesives (e.g. in degreasing or cleaning operations).
Potential Uses in Apparel and Footwear Textile Processing
In apparel and footwear, halogenated solvents are used as finishing/ cleaning and printing agents, for dissolving/ diluting fats, oils and adhesives (e.g. in degreasing or cleaning operations).
Potential Uses in Apparel and Footwear Textile Processing
Organotins are a class of chemicals combining tin and organics such as butyl and phenyl groups. Organotins are predominantly found in the environment as antifoulants in marine paints, but they can also be used as biocides (e.g. antibacterials), catalysts in plastic and glue production and heat stabilisers in plastics/rubber. In textiles and apparel, organotins are associated with plastics/rubber, inks, paints, metallic glitter, polyurethane products and heat transfer material.
Borate, zinc salt can be used as a flame retardant but also in paints, pigments, and adhesives.
Bisphenol A (BPA) is a precursor chemical used along with other chemicals to create some plastics and resins. It is commonly used to harden plastics.
Thiourea is used in many formulations to increase the solubility.
Contaminant of dispersing agents in disperse dyes.
Respirable particles of silica are often generate during the process of sand blasting.
AEEA is used a.o. in chelating agents, surfactants and fabric softeners.
Potential Uses in Apparel and Footwear Textile Processing
PFOA and PFOS may be present as unintended by-products in long-chain commercial water, oil and stain repellent agents. PFOA also may be in used in the production for polymers like polytetrafluoroethylene (PTFE).
Potential Uses in Apparel and Footwear Textile Processing
Esters of ortho-phthalic acid (phthalates) are a class of organic compounds commonly added to plastics to increase flexibility. They sometimes are used to facilitate moulding of plastic by decreasing its melting temperature. Phthalates can be found in:
- Flexible plastic components (e.g. PVC)
- Print pastes
- Adhesives
- Plastic buttons
- Plastic sleevings
- Polymeric coatings
Potential Uses in Apparel and Footwear Textile Processing
Oil containing PAHs are added to rubber and plastics as a softener or extender and may be found in rubber, plastics, lacquers, and coatings. Within the footwear producing industry, PAHs are often found in the outsoles of footwear and in printing pastes for screen prints. PAHs can be present as impurities in carbon black dyestuffs.
Potential Uses in Apparel and Footwear Textile Processing
Although typically associated with leather tanning, chromium VI also may be used in the dyeing of wool (after the chroming process).
Potential Uses in Apparel and Footwear Textile Processing
These are frequently used in formulations to be stable to the influences of light and UV
Potential Uses in Apparel and Footwear Textile Processing
These Volatile Organic Compounds (VOC) should not be used in textile auxiliary chemical preparations. They are associated with solvent-based processes like solvent-based polyurethane coatings and glues/ adhesives. They should not be used for any kind of facility cleaning or spot cleaning.
Potential Uses in Apparel and Footwear Textile Processing
Used for indigo and to manufacture AZO Dyes (especially the leather dyes).
Potential Uses in Apparel and Footwear Textile Processing
ADCA is used as a foaming/ blowing agent for rubber applications.
Potential Uses in Apparel and Footwear Textile Processing
Green dye
Potential Uses in Apparel and Footwear Textile Processing
Flame retardant chemicals are rarely used to meet flammability requirements in children’s clothing and adult products.
Potential Uses in Apparel and Footwear Textile Processing
Formaldehyde has many uses in printing, interlinings, stiffeners, etc.
Potential Uses in Apparel and Footwear Textile Processing
Used as water repellent, stain repellent and in certain cases to improve the colour fastness properties.
Potential Uses in Apparel and Footwear Textile Processing
Phenol is not deliberately used in textiles or footwear but trace amounts of phenol can be found in many chemical formulations.
Potential Uses in Apparel and Footwear Textile Processing
There are many uses for solvents from adhesives, coated textiles, prints, etc.
Potential Uses in Apparel and Footwear Textile Processing
Besides in dyes and pigments, metals are used as raw material for trims and other components.
Potential Uses in Apparel and Footwear Textile Processing
Most of these substances are regulated and should no longer be used for the dyeing of textiles.
Potential Uses in Apparel and Footwear Textile Processing
Dye
Potential Uses in Apparel and Footwear Textile Processing
In the past, it was used to make several types of polymers, resins, and textiles, but its use is now highly restricted.