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

2. 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

3. 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

4. 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

5. 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

6. 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

7. 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

8. 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

9. 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

10. 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

11. 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

12. 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

13. 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

14. 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

15. 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

16. 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

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

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

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

20. 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

21. Thank you for your attention
Nicholas Dodd
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