Restricted Substance Problem Solution Prevention Library Heavy Metals Formaldehyde Aromatic Amines Disperse Dyes Misc. APEO’s Organotins Phthalates

Problem #1 Formaldehyde Soft hand screen print using discharge printing technique Printer performed a strike off Strike off approved for appearance Printer could not meet formaldehyde requirements of the brand because the ink system used Zinc Formaldehyde Sulfoxylate (ZFS) catalyst Formaldehyde

Problem #1 Formaldehyde Discharge ink systems require chemicals to break down the color of the dyed garment Many discharge systems contain formaldehyde Printer worked with ink supplier to optimize printing concentrations, curing times and temperatures Reduced but did not remove 100% of formaldehyde in the final prints. Product could not be used on children’s garments. Problem #1 Formaldehyde

Problem #1 PREVENTION: Formaldehyde Printer developed a quality control process to manage print recipes Curing times and temperatures kept consistent to meet RSL requirements for adult products Printer looked for a non-formaldehyde catalyst system for discharge designs. Printer and garment factory only show protos to brand that meet RSL requirements Formaldehyde

Problem #2 Formaldehyde Urea formaldehyde resins are common chemicals used in durable press resins Resins are used to prevent wrinkles and stiffen fabrics Resin was applied to the backing fabric on the cap to maintain its shape Backing fabric was less than 1% of the weight of the cap, but the amount of formaldehyde in the resin exceeded RSL limits by almost 200% Formaldehyde

Problem #2 Formaldehyde Caps were not able to ship while solutions and alternatives were investigated Some materials were washed to reduce the formaldehyde Some other materials were replaced with alternatives No process to control the formaldehyde could not be established Developed a new material that would meet the performance needs and RSL requirements. Formaldehyde

Problem #2 Formaldehyde PREVENTION: Low level formaldehyde failures were still common in the cap factories Factory had not switched materials for all customers Contamination from drying units and factory air handling units Phase out of all formaldehyde containing chemicals was the only way to guarantee 100% compliance Formaldehyde

Problem #3 Formaldehyde Urea formaldehyde resins are common chemicals used in durable press resins Resins are used to trap wrinkles and stiffen fabrics Cotton t-shirt designed by brand to have wrinkled effect by using durable press resin treatment Garment had formaldehyde concentration above RSL limits Formaldehyde

Problem #3 Formaldehyde Wrinkle finish had been cured for too short a time Cure temperature was also too low Process changes improved durability and RSL compliance Always follow manufacturer guidance for process conditions Always tell chemical supplier your compliance needs Formaldehyde

Problem #3 Formaldehyde PREVENTION: In some cases a chemical on an RSL can be used Conditions must be carefully controlled to manage finished product compliance Work with high quality chemical suppliers Always follow chemical supplier guidelines Formaldehyde

Problem #4 Formaldehyde Formaldehyde releasing melamine resin is commonly used as a crosslinker in pigment printed garments and will cause formaldehyde failures An alternative approach is to use a blocked diisocyanate crosslinker which is formaldehyde free Isocyanates can be sensitizing and carginogenic so proper curing is required Formaldehyde

Problem #4 Formaldehyde Diisocyanate crosslinker must be fully cured, used in correct ratios, and dried off Printer will have to work with chemical supplier to develop proper conditions depending on equipment, temperature, and humidity Measures must be taken to prevent occupational hazards when utilitizing diisocyanate crosslinkers Formaldehyde

Problem #4 Formaldehyde PREVENTION: In this case chemical supplier provided formaldehyde free option because printer requested it, but printer did not ask if any new problems were created ES&H must also be considered when utilizing new technologies Work closely with suppliers, technical professionals, and laboratories when starting new techniques Formaldehyde

Problem #5 Formaldehyde Cotton fabric failed Formaldehyde children’s Formaldehyde standard Supplier knew that Formaldehyde was contained in the raw chemicals applied to the fabric Supplier had worked with chemical supplier to control the concentration applied to meet Brand’s formaldehyde requirements Formaldehyde

Problem #5 Formaldehyde Fabric supplier checked their production record and found out a typo in the batch formula which caused the formaldehyde concentration to exceed RS requirement Supplier has changed their quality control procedures to review the formula before official production to avoid the same mistakes in the future. Formaldehyde

Problem #5 Formaldehyde PREVENTION: The only 100% method to meet RS requirements is to eliminate the use of chemicals on an RSL If a supplier knows they are using a chemical on an RSL they must establish and carefully monitor control procedures to ensure compliance Supplier should also increase testing for affected products during development and production Formaldehyde

Problem #6 Formaldehyde Formaldehyde was found in a Full Grain Leather material Leather supplier initiated investigation and found out that Formaldehyde was used in one of the re-tanning chemical without any intended chemical function Formaldehyde

Problem #6 Formaldehyde As a short-term solution, Leather supplier took strict measurement of decreasing the % usage of the Formaldehyde containing chemical in their formula to reduce Formaldehyde content level in their finished products For long-team action, Leather supplier found a Formaldehyde free chemical to replace the contaminated chemical in their re-tanning process. Formaldehyde

Problem #6 Formaldehyde PREVENTION: In some cases a chemical on an RSL can be used Conditions must be carefully controlled to manage finished product compliance Work with high quality chemical suppliers Always follow chemical supplier guidelines When possible search for formaldehyde free alternatives Formaldehyde

Problem #1 Aromatic Amines Brand designed a corded children’s sweater Factory chose the cord supplier because it was considered a “standard” item Cord supplier used a dyestuff that contained prohibited aromatic amines Aromatic Amines

Problem #1 Aromatic Amines Product was already manufactured so the only solution was an expensive decision not to sell the product Lots of draw cords available to meet RSL Dyestuff from quality chemical company with little to no cost impact Aromatic Amines

Problem #1 Aromatic Amines PREVENTION: RS requirements must be communicated to all suppliers Laws require product compliance A small component prevented the entire garment from being sold Aromatic Amines

Problem #1 Cadmium found in outer PVC (polyvinyl chloride) layer of soccer ball PVC commonly contains heavy metal stabilizers PVC also often contains phthalates for flexibility Cadmium was used as a stabilizer Cadmium can also be used in pigments Heavy Metals

Problem #1 PVC layer was substituted with a TPU (thermoplastic polyurethane) TPU was tested to be RSL compliant TPU had performed better for feel and durability Heavy Metals

Problem #1 PREVENTION: When investigating new materials or production techniques brands and suppliers have to work together to meet a variety of goals including: - price - performance - quality - safety Heavy Metals

Problem #2 Red paint used on trim of an infants shoe found to contain lead exceeding RSL limits. Lead was used as a pigment in the paint Lead is acutely toxic in high concentrations Heavy Metals

Problem #2 Brand voluntarily recalled product at a cost of $6.7 million Factory began more complete testing program for sourced raw materials Lead in raw material will still be lead in finished product Heavy Metals

Problem #2 Heavy Metals PREVENTION: Source raw materials from reliable suppliers with a well controlled manufacturing process Compliance of raw materials will lead to compliant finished products Heavy Metals

Problem #3 PU (polyurethane) coated fabric was found to contain high levels of lead PVC and phthalates had been eliminated from the product Lead could be used as a stabilizer or pigment Not likely caused by contamination Heavy Metals

Problem #3 Heavy Metals Brand gave RSL requirements to garment factory Not all of the requirements were communicated to PU fabric vendor Factory is expected to communicate RSL to their suppliers Heavy Metals

Problem #3 Heavy Metals PREVENTION: Brands include all members of supply chain in RSL training Garment factories must fully communicate all brand requirements to their downstream suppliers Strategically test products at all stages of production Heavy Metals

Problem #4 Lead was detected in the coating on the top cover fabric of some sock liners Heavy metals including lead are often used in low cost pigments and inks Lead pigment was used in the heat transfer on the sock liner. Heavy Metals

Problem #4 Heavy Metals PREVENTION: Brands include all members of supply chain in RSL training Garment factories must fully communicate all brand requirements to their downstream suppliers Consider even the smallest components in the RS compliance scenario Strategically test products at all stages of production Heavy Metals

Problem #5 Heavy Metals Chromium was detected on wool/nylon fabric It appeared the mill had used a metalized dye This same mill had already has the same problem before Mill provided dye recipe and dye lot records and the recipe was not the problem During mill audit brand reviewed dyes and auxiliary chemicals – all okay Heavy Metals

Problem #5 Heavy Metals PREVENTION: Determined that mill had old stock of fabric that had failed previously Mill had submitted wrong sample to laboratory for testing Be aware of your inventory management systems If all product is not RS compliant, provide clearly marked storage areas ***It is a best practice to produce only compliant materials in order to avoid contamination issues. Heavy Metals

Problem #6 Heavy Metals Printed heat transfer failed for mercury Mercury can be used as a pigment In this case the source of the mercury was determined to be a cleaning solvent which contaminated a mixing beaker Heavy Metals

Problem #6 Heavy Metals PREVENTION: Heat transfer supplier eliminated suspected cleaning agent Changed their process to mix inks in disposable mixing containers Established time frames for keeping custom mixed inks Printer already had a separate mixing kitchen for this brand due to PVC requirements Heavy Metals

Problem #1 Phthalates Many screen print inks contain PVC PVC screen prink inks often contain phthalates Phthalates are used to soften ink and prevent cracking Printed t-shirts did not meet phthalate requirements for DEHP All print chemicals were tested phthalate free prior to printing Phthalates

Problem #1 Spray adhesive used to hold garment in place during printing contained DEHP Adhesive contaminated finished garment Printer substituted a different spray adhesive to achieve compliance Phthalates

Problem #1 Phthalates PREVENTION: Contamination is a big problem in RSL compliance When developing a program think about everything that touches the product The best approach is to make sure all raw materials meet the RSL requirements Phthalates

Problem #2 Plasticizers are commonly used in plastics and foams to increase flexibility and improve performance Many phthalate based plasticizers have been banned as toxic or reproductive hazards Manufactured claimed to use acetyltributylcitrate (ATBC) as plasticizer alternative in flip flop sandals ATBC is considered a safer plasticizer alternative Phthalates

Problem #2 Consumer complaints that the flip flops had tacky feeling and were removing lacquer finish on wood floors Laboratory analysis detected tributycitrate (TBC) instead of ATBC as manufacturer claimed TBC is a known solvent for decoating furniture Manufactured substituted TBC as a cheaper alternative for ATBC Phthalates

Problem #2 Phthalates PREVENTION: Manufacturers must stick to recipes described to brands Any substitutions should be approved by brand Chemical substitutions should not be made on price alone without safety, quality, performance impact Phthalates

Problem #1 Scouring agent is used to remove oils and fats from textiles Many scouring agents contain APEO’s (alkylphenol ethoxylates) as a surfactant APEO’s will remain on the fabric after the scouring process APEO’s

Problem #1 Vendor chose scouring agent because it removed all oils for even dyeing Vendor new it contained APEO’s Vendor did not know brand was concerned about APEO’s on finished product Vendor sourced an APEO free alternative scour agent with no cost increase APEO’s

Problem #1 APEO’s PREVENTION: Communication Alternatives exist for most restricted chemicals Just ask for them APEO’s

Problem #2 APEO’s APEO was detected in an insole board Supplier investigated fibers used to produce the board and confirmed no APEO’s were used Emulsion used to coat fiber board was contaminated with APEO’s Supplier switched to a new batch of emulsion and component passed RS testing APEO’s

Problem #2 PREVENTION: Contamination is a big problem in RSL compliance When developing a program think about everything that touches the product Chemicals and tools must be properly handled, stored, and sanitized to prevent contamination. APEO’s

Problem #3 APEO’s NPEO was detected in pig skin leather NPEO is usually associated with the degreasing agents Their previous source of degreasing agent is from Japan and known not to contain NPEO A ban on raw materials exported from Japan forced them to change to an alternate source NPEO source was identified as new degreasing agent. APEO’s

Problem #3 APEO’s PREVENTION: When switching suppliers, for any reason, always share RS requirements with new supplier A thorough RS testing program should focus testing on high risk items, unknown materials, or inexperienced suppliers APEO’s

Problem #1 Foil screen prints on children’s t-shirts found to contain organotins Organotins are often used as heat stabilizers in printing and transfer processes Organotins were found through testing of the foil backing adhesive Organotins

Problem #1 Print house had MSDS for all foil print papers and adhesives All chemical suppliers were contacted to see if they used organotins Some of the cheap adhesives contained organotins Organotins

Problem #1 Organotins PREVENTION: Communication High quality adhesive chemicals should be requested Non-organotin heat stabilizer alternatives are available Organotins

Problem #1 Phenol was detected in the adhesive used to manufacture shoes during a random audit Chemical supplier believed that there was no Phenol in their adhesive Supplier individually tested each of the chemical used to manufacture adhesive to detect for Phenol. Misc.

Problem #1 One of the chemicals used to produce adhesive had small residual of Phenol Phenol used in the manufacturing but was supposed to be removed during processing Supplier reviewed the chemical recovery process to ensure complete recovery of Phenol Misc.

Problem #1 PREVENTION: Establish routine testing procedure for presence of restricted substances in all process chemicals - Especially if a restricted chemical is a known precursor. Misc.

Problem #2 Molded black rubber logo failed on Polyaromatic Hydrocarbons (PAHs) Rubber raw material supplier confirmed that one of the rubber raw materials, Naphthenic oil, contained PAHs Misc.

Problem #2 Rubber supplier reformulated material and substituted naphthenic oil out of formula RS testing of the improved sample showed the new formula is RS compliant Misc.

Problem #2 PREVENTION: RS requirements must be communicated to all down stream suppliers Down stream suppliers must understand RS requirements and impacts of raw material choices Misc.

Problem #3 PFOA was detected in a webbing (65% Polyester + 35% recycled PET) Previous test of material met RS requirements Supplier told brand that a non-wicking treatment had been applied to the material to provide water repellency since the last RS testing. Misc.

Problem #3 MSDS for the non-wicking chemical showed PFOA content and tests failed RS requirements Supplier worked with the non-wicking additive supplier and replaced it with a non-wicking additive which is PFOS/PFOA free Misc.

Problem #3 Misc. PREVENTION: Review MSDS to see if any restricted chemicals are present, evaluate usage and process conditions *(MSDS will not include low percentage chemicals and chemical concentration in finished product will depend on chemical and application. MSDS should not be used to determine RS compliance.) Alternatives exist for most restricted chemicals – ask for them Misc.

Problem #4 Small amount of Volatile Organic Compounds (VOC) was detected in the ink raw materials at screen print facility Printer investigated and discovered contamination from solvent supplier recycling solvent tanks Misc.

Problem #4 Misc. PREVENTION: Chemicals and tools must be properly handled, stored, and sanitized to prevent contamination. Know the contents of spot cleaners and other cleaners because they will be used in contact with finished products Any chemical supplier to a facility must know the RS requirements to avoid contamination Misc.

Problem #5 Phenol was detected on silk fabric with a print during pre-production testing By analysing individual raw materials the thickener (guar gum) was identified to be contaminated Printer switched from guar gum to alginate thickener to avoid contamination problems Misc.

Problem #5 PREVENTION: Misc. Pre-production testing provided time to seek out alternatives and achieve chemical compliance Misc.

Problem #6 Black cotton / rayon socks were a high volume carryover item No customer complaints for , until a cluster of 5 complaints for skin irritations within 1 month Samples tested for pH, formaldehyde, restricted dyes – all tests negative Samples pulled from store stock were noted to have a “solvent” smell Misc.

Problem #6 SOLUTION: Misc. Socks were tested for VOC’s and found to contain Dimethylformamide, methylene chloride, and acetone Supplier was found to be lubricating the knitting yarn with an unlabelled solvent with no MSDS information SOLUTION: Production was stopped immediately All current stock/shipments destroyed Supplier is under review and production in their facility has been suspended Supplier required to prove factory corrective action plan before production can resume Misc.

Problem #1 Disperse Dyes Restricted disperse dye was found in a woven label All the yarns used to make this label were from well known suppliers and there was no history of RSL failure Supplier tested all yarns used to make this label & no restricted disperse dye was detected Disperse Dyes

Problem #1 Disperse Dyes Only remaining component was the backer Testing of the backer only produced a positive result for restricted disperse dye Backer was changed and supplier destroyed all the inventory of failed backer color Disperse Dyes

Problem #1 Disperse Dyes PREVENTION: Laws require product compliance A small component or part of a component can cause a product to be non-compliant Disperse Dyes

Restricted Substance Problem Solution Prevention Library Heavy Metals Formaldehyde Aromatic Amines Disperse Dyes Misc. APEO’s Organotins Phthalates