EUEB special session on hazardous substance verification Textile product group 15th April 2015, Brussels Joint Research Centre, Institute for Prospective Technological Studies

Chemicals and process criteria Structure of the old criteria 10. Sizing and spinning preparations Spinning Pre-treatment Dyeing Finishing Printing Wet processing 16. Bleaching agents 17-24 Dye criteria - Impurities - Dye restrictions 25. Printing 26. Formaldehyde 28. Flame retardants 29. Anti-felting 30. Fabric finishes 14. Chemicals and chemical preparations 15. Detergents, softeners and complexing agents 27. Wastewater discharges from wet processing 33. Energy and water use

Chemicals and process criteria Structure of the new criteria - Sizing and spinning preparations Spinning Pre-treatment Dyeing Finishing Printing - Bleaching agents 13. Restricted Substance list - SVHC’s - Biocides - Auxilliaries and surfactants - Dyes and carriers - Heavy metals - Functional treatments - Accessories 14. Hazard class substitution - Dyeing, printing, finishing - Hazard class restrictions 15. Process efficiency - Dyeing, printing, finishing - BAT technique listing - Treatment of aerial emissions and wastewater discharges - Detergents, softeners and complexing agents

C13: Restricted Substance List (RSL) Criterion text ‘The final product and the production recipes used to manufacture the final product shall not contain the hazardous substances listed in the Restricted Substance List at or above the specified concentration limits or according to the specified restrictions. The RSL can be found in Appendix 1. The RSL shall be communicated to suppliers and agents responsible for the spinning, dyeing, printing and finishing stages of production. Verification and testing requirements are specified in the RSL for each production stage and for the final product. Laboratory testing, where required, shall be carried out for each product line based on random sampling. Testing shall be carried out annually during the license period in order to demonstrate ongoing compliance with the RSL. ‘ 2 2

C13: Restricted Substance List (RSL) Grouping of restrictions By production sites…. Fibre and yarn spinning Bleaching and pretreatment Dye houses Printing processes Finishing processes General requirements…. All production stages (includes SVHC restriction) Final product ‘safety net’… The final product Verification also required for hazard classifications 2 2

C13: Restricted Substance List (RSL) Assessment and verification ‘The applicant shall provide a declaration of compliance with the RSL supported by evidence as applicable to the substances and production recipes used to manufacture the final product. The requirements are indicated in the RSL and include: - declarations obtained from those responsible for related production stages, - declarations from chemical suppliers, and - test results from laboratory analysis of samples of the final product. Declarations obtained from production stages shall be supported by safety data sheets (SDS) for production recipes and, where necessary, declarations from chemical suppliers. ‘ 2 2

C13: Restricted Substance List (RSL) How was the RSL proposed to work? SVHC/Candidate List Biocides Auxilliaries and surfactants Cardigan - Knitted - Wool and acrylic blend - Dyed red - Metal zip Dyes and carriers Heavy metals Printing Functional treatments Accessories 2 2

C13: Restricted Substance List (RSL) Step 1: Is risk-based testing required? SVHC/Candidate List Biocides Protection during transport Auxilliaries and surfactants Dyes and carriers Potential use of azo dyes Heavy metals Printing Functional treatments Accessories 2 2

C13: Restricted Substance List (RSL) Step 2: Relevant RSL substances? SVHC/Candidate List DMAc residue on acrylic Biocides Auxilliaries and surfactants Potential use of APEO’s Dyes and carriers Potential use of sensitising, metal complex and chrome mordant dyes Heavy metals Extractable heavy metals Accessories Metal accessories Functional treatments Shrink resistant finish Printing 2 2

C13: Restricted Substance List (RSL) Step 3: Existing Oeko-tex 100 testing? SVHC/Candidate List DMAc residue on acrylic ✓ Biocides Auxilliaries and surfactants Potential use of APEO’s ✓ Dyes and carriers Potential use of sensitising, metal complex and chrome mordant dyes ✓ Heavy metals Extractable metals ✓ Accessories Nickel and chrome Functional treatments Shrink resistant finish 2 2

C13: Restricted Substance List (RSL) Step 4: Check/agree with Competent Body Proposed assessment and verification Oeko-tex 100 test results (1 yr old) + declarations from suppliers DMAc residue test Declaration of non-use Alkylphenol testing Sensitising dye testing Declaration on non-use: metal complex and chrome mordant dyes Extractable metal testing Metal migration testing 2 2 Declaration of finish applied

C13: Restricted Substance List (RSL) Step 5: Carry out required testing DMAc residue test Oeko-tex 100 test results - Biocides - APEO (breakdown) - Sensitising dyes - Extractable metals ✓ Biocide declaration of non-use Alkylphenol testing Sensitising dye testing Declaration on non-use: metal complex and chrome mordant dyes Declarations - Dyeing and finishing stages - Transportation ✓ Extractable metal testing New accredited testing - DMAc - Extractable metals - Metal migration ✓ Metal migration testing Declaration of finish applied 2 2

C14: Substitution of hazardous substances in dyeing, printing and finishing processes Summary of overall requirement (1) ‘Substances applied to fabrics and knitted panels during dyeing, printing and finishing processes which remain on the final product and, in accordance with Regulation (EC) No 1272/2008 of the European Parliament and of the Council (1) or Council Directive 67/548/EC (2), meet the criteria for classification with the hazard classes or risk phrases listed in Table 5 shall not be used unless they have been specifically derogated. These restrictions shall also apply to functional substances incorporated into man-made fibres during their manufacturing. ‘ 2 2

C14: Substitution of hazardous substances in dyeing, printing and finishing processes Summary of overall requirement (2) Dyeing, printing or finishing process chemistry shall be screened for hazardous substances that may remain on the final product Distinction made between functional substances, residual substances and contaminants Main focus is on verifying hazard classifications of substances used in production recipes Hazard classes will be related to their relevance along the life cycle of the product In some cases this is used as the basis for derogation conditions 2 2

How does it differ from previous criteria? C14: Substitution of hazardous substances in dyeing, printing and finishing processes How does it differ from previous criteria? 10. Auxilliaries and finishing agents for fibres and yarns 15. Detergents, fabric softeners and complexing agents 22. Dyes that are carcinogenic, mutagenic or toxic to reproduction 28. Flame retardants 30. Fabric finishes 32. Coatings, laminates and membranes

C14: Substitution of hazardous substances in dyeing, printing and finishing processes Assessment and verification requirements Declarations of compliance from production sites and, where necessary chemical suppliers, for those substances that may remain on the final product: Biocides Dyestuffs and pigments Auxilliary carriers, levelling agents and dispersing agents Optical brighteners Print thickeners, binders and plasticisers Flame retardants and synergists Cross linking agents Water, dirt and stain repellents 2 2

C14: Substitution of hazardous substances in dyeing, printing and finishing processes Substance groups derogated for specific hazards

C14: Substitution of hazardous substances in dyeing, printing and finishing processes Substance groups derogated under specific conditions

C14: Substitution of hazardous substances in dyeing, printing and finishing processes Verification of derogation conditions

Types of derogation conditions C14: Substitution of hazardous substances in dyeing, printing and finishing processes Types of derogation conditions BAT measures that minimise exposure of the workforce and/or the environment e.g. handling of dyes in powder form, aerial VOC emissions BAT measures that minimise the concentration of residues on the final product e.g. optimised dosing of auxilliaries Statutory need for a final product function e.g. in order to meet regulatory requirements Achievement of more durable final product finishes e.g. as defined by EN or ISO standards

Thank you for your attention Nicholas Dodd Tel. +34 954 488 728  e-mail nicholas.dodd@ec.europa.eu Contact -