1. www.intertek.com1 Neyamul Hasan Intertek Consumer Goods Bangladesh 24 Nov-2012 RESTRICTED SUBSTANCES IN CONSUMER GOODS (WITH SP. REFERNCE TO TEXTILES & APPARELS)

2. www.intertek.com2 RSL means the Restricted Substances List Chemicals that are health hazards - Carcinogenic - Toxics - Sensitizing – allergenic RSL

3. www.intertek.com3 Common List of Restricted Substances $ Allergenic Disperse Dyes $ Azo Dyes $ Heavy metal content $ Nickel Release $ Cadmium $ Chromium VI $ Lead $ Formaldehyde $ Phenol content $ Dimethyl Fumarate (DMF) $ Carcinogenic dyes Dyes $ Phthalates $ Triclosan $ PCBs $ APEOs $ Pesticide $ Flame Retardant $ Organotin compounds $ COC

4. www.intertek.com4 RS - Azo Azo dyes (which degrade to form one of the carcinogenic amines listed on the restricted substance list) Description:Azo dyes incorporate one or several azo groups (-N=N-) bound with aromatic compounds. Thousands of azo dyes exist, however, only those which can degrade to form the listed amines are restricted. Maximum permissible limit: 30 mg/kg in finished articles or in dyed parts Where they may be found: In textiles and apparel, azo dyes (which may degrade to form 22 listed amines) may be found in dyed fiber or leather. ToxicityAmines are Considered as Carcinogenic

5. www.intertek.com5 RS - Azo Allergy from textile dyes in Leg & Abdomen area

6. www.intertek.com6 RS - APEOs APEO/AP (Alkyphenol Ethoxylates/Alkylphenols) Description:NPEOs/OPEOs are included in the group of non-ionic surfactants called alkylphenol ethoxylates (APEOs). NPEOs and OPEOs can degrade to NP and OP respectively. Maximum limit: 0.1 % in preparations Where they may be found: APEOs are used in detergents, scouring agents, wetting agents, softeners, emulsifier/dispersing agents for dyes and prints. In leather tanning, APEO is used in de-greasing, finishing etc. In silk production for de-gumming. APEO could also be present in dyes and pigment preparations.. ToxicityAPEO can cause cancer, disrupt hormone system and reduce fertility. Important Info Our statistical data says: SILK is the most potential groups of fiber where APEOs get fail very frequently.

7. www.intertek.com7 RS – Disperse Dyes Sensitizing Disperse Dyes Description:Disperse dyes is a group of dyes generally used to dye synthetic fiber, eg, Polyester. Maximum permissible limit: Not detected (<5 mg/l) Where they may be found: Disperse dyes are used to dye synthetic or manufactured fibers (polyester, acetate, and polyamide). Other Dyes:Navy Blue or Blue colorant as a dye mixture also kind of disperse dyes. ToxicitySome of Disperse dyes suspected to cause allergic reactions.

8. www.intertek.com8 RS - Formaldehyde Formaldehyde Description:Formaldehyde is a volatile compound used widely in apparel and textile manufacturing as an anti-creasing and an anti-shrinking agent. In addition, formaldehyde is often used in polymeric resins (e.g. phenol-formaldehyde and urea-formaldehyde). Maximum permissible limits 20 ppm 0-36 months, 75 ppm for Adult Where it may be found: In apparel and textiles, formaldehyde could be found in artificially stiffened fabric. Since formaldehyde is volatile, cross contamination of material may occur. ToxicityIt is an irritant to eyes, nose, lung and may cause allergic reactions. Suspected carcinogen.

9. www.intertek.com9 RS - Phenols Pentachlorophenol (PCP) Description:PCP is a polychlorinated compound used as a preservative to wood, leather, and textiles (Natural Fiber). Where it may be found: PCP has been used as an antifungal in textiles, leather, and some wood products. Specially during storing & Transportation PCP is used as insect killer. Regulation/Direc tive /Legislation Legislation - 91/73/EEC prohibits the marketing and use of PCP and its salts and esters in substances or preparations in a concentration equal to or greater than 0,1 % by mass.

10. www.intertek.com10 RS – Organotin Organotin Compounds Description:Organotins are a class of chemicals combining tin and organics such as butyl and phenyl groups. Where they may be found: In textiles and apparel, organotins may be associated with plastics, inks, paints, and heat transfer material. Mostly they used as antifoulants in paints, but they can also be used as biocides (antibacterials) and / or heat stabilizer in plastics Toxicity3 Listed Organotin (i.e. Monobutyl tin trichloride, Tetrabutyl tin, Monoheptyl tin trichloride) Suspected to be endocrine disrupters

11. www.intertek.com11 RS - PVC Polyvinyl chloride (PVC) Description:PVC (also known as vinyl) is a chlorinated polymer used extensively. Generally, PVC is used for soft plastic accessories like badges or zip pullers, as coating on textiles for rainwear, as prints etc. Limit: Not detected in toys and products intended to be in mouth Where it may be found: PVC can be found in plastic items and trim in apparel and textiles. In addition, PVC can often be found in screen prints and inks. ToxicityEnvironmentally persistent, and their manufacture and disposal often results in highly toxic wastes (e.g. DIOXINS)

12. www.intertek.com12 RS - Phthalates Phthalates Description:Colorless, odorless liquids which are used as “ plasticizers ” Soften the polyvinyl chloride plastic (PVC), Rubber products, paints, printing inks, adhesives, lubricants and some Cosmetics. Where they may be found:In textiles and apparel, phthalates may be associated with flexible plastic components, trims and screen prints. Toxicity6 Listed Phthalates Very low volatility, do not readily dissolve in water and are persistent in the environment They are suspected to be carcinogenic and to disturb the hormone system

13. www.intertek.com13 RS - Nickel Nickel Description:Nickel is an abundant metal often combined with other metals to create alloys with increased hardness and resistance to corrosion. Where it may be found:In textiles and apparel, nickel may be associated is mostly with metal accessories. Very rarely could be found in clothing, paints, inks, trims and plastics. ToxicityIt can cause allergenic reaction to human beings

14. www.intertek.com14 Effect of Nickel Poisoning Earring containing Nickel and dermal effects observed

15. www.intertek.com15 RS - Lead Lead Description:Lead is a naturally occurring metal important to the production of batteries, fuels, paints, plastics (as a heat stabilizer), ceramics and solders. Where it may be found: In textiles and apparel, lead may be associated with plastics, paints, inks, pigments, and metal components. ToxicityLead can affect the central nervous system (particular children) and can damage the kidneys and immune system Lead is one of the potential risky & common RS in the field of CG

16. www.intertek.com16 Adverse effect of Lead to Human

17. www.intertek.com17 Adverse effect of Lead to Human

18. www.intertek.com18 Adverse effect of Lead to Human

19. www.intertek.com19 RS - Cadmium Cadmium Description:Cadmium is a naturally occurring and abundant metal that does not easily corrode (rust). Maximum permissible limit: 100 mg/kg Where it may be found:In textiles and apparel, cadmium may be associated with plastics, pigments (particularly red, orange, yellow, and green), and as a surface layer for metals. ToxicityIn like other Heavy Metals Cadmium also anticipated to be carcinogens.

20. www.intertek.com20 RS – Chromium VI Chromium VI Description:Chromium is a kind of metal that can exist in three main forms (Chromium (0), Chromium (III), and Chromium (VI). In nature, Cr (III) is the predominate form, Cr (0) and Cr (VI) do not occur in nature or are rare. Where it may be found:In textiles and apparel, chromium may be associated with plastics, pigments and mainly in tanned leather.

21. www.intertek.com21 Effect of Heavy Metal Poisoning Arsenic Poisoning

22. www.intertek.com22 RS – Dimethyl Fumarate DMFu (Dimethyl Fumarate) Description:DMF is a stable compound classified as irritant and even harmful for the skin, eyes, mucous membranes and upper respiratory tracts, by simple contact. Limit: 1 mg / kg (the lab should have a method detection limit of < 0.1 mg/kg) Where it may be found:This chemical substance is a BIOCIDE and could be found in Textiles/Apparel, Leather and most likely in Silica Gel, etc. ToxicitySevier Instant Irritation

23. www.intertek.com23 Common RS Requirement (based on current regulations/legislation) – EU & USA RS EU MarketUSA Market Applicability General Requirement Applicability General Requirement Azo√30 ppmNA Phthalates√1000 ppm√ Formaldehyde√20, 75 ppm√ pH√Variable√variable LeadNA√90/300 ppm PVC√ND DMFu√0.1 ppmNA Allergenic Disperse Dyes √1, 5 mg/lNA Carcinogenic Dyes√1, 5 mg/lNA Chlorophenols (PCP/TeCP) √1 ppmNA APEOs√1000 ppmNA Organotin√ 1 ppm NA COCs√ 1, 2 ppm NA Solvents√ ND NA Crhomium VI√3 ppm / NDNA Sol. Heavy Metals, ASTM F963 NA√Element wise Mig. of Heavy Metals, EN 71-3 √Element wiseNA Cadmium√100ppm√

24. www.intertek.com24 Major RS Tests requirement - Component/material- wise (For EU Market) RS Natural Fiber Synthetic Fiber Blend (Natural + Synthetic)) Synthetic Leathers, Inks, Thermoplasti cs, etc Metals Leather / Coated Leathers Trims Azo√√√√√ Phthalates√ Formaldehyde√√√√ Cadmium√ PVC√√ Al. Disperse Dyes√√√ Carcinogenic Dyes√√√ Chlorophenols (PCP/TeCP) √√√ APEOs√√√√ Organotin√√√√√ COCs√√ pH√√√√√ Crhomium VI√ Heavy Metals√√√√√√ Nickel Release√

25. www.intertek.com25 Major RS Tests Requirement - Component/material- wise (For US Market) RS Natural Fiber Synthetic Fiber Blend (Natural Synthetic)) Inks, Coating, Thermoplastics, etc Metals (Children) Non-Metals Substrate Phthalates√ Formaldehyde√√√ pH√√√ Lead√√√ Sol Heavy Metals√

26. www.intertek.com26  Raw Fibre,  Dyes and Chemicals  Ancillary Chemicals  Poor Process control - Poorly controlled reactions = Risk - Reactions are controlled by… - Ratio of reagents, Temperature, pH & Time  Many RSL failures due to non-deliberate application - Unspecified chemicals in a formulation - Unlabelled drums in the store - Unlabelled buckets by the machine Common Sources of RS in Textile/Apparel Industry

27. www.intertek.com27 PRODUCTION CONTROL Chemicals Textile Accessories Production Final product Sources of RS in Textile/Apparel Industry

28. www.intertek.com28 Chemicals inside the products Fibre Oil Size Dyes Auxiliaries Print paste Pigment Plastic Metal Synthetic fibre Natural fibre Detergents Button Zipper Sequin Accessories Wet processing Spinning Knitting Weaving Washing Final Products Red color indicates source of Restricted chemicals Sources of RS in Textile/Apparel Industry

29. www.intertek.com29 How to avoid RS failure Very Basic: Production Control: - Adequate knowledge on RSL - Record of chemical products used - Require necessary information about chemical products - Follow SOP All chemicals must have: - MSDS (Material Safety Data Sheet) - Compliance declaration to RSL - Labelled containers

30. www.intertek.com30 How to avoid RS failure - Educate the supply chain Brands Factories Vendors Other suppliers Agents, traders Brands are responsible for educating factories on the RSL, and the supplier is responsible for educating vendors on the RSL as well. Make sure all of your subcontractors, accessory suppliers, dye mills, print mills, tanneries, chemical suppliers etc. are aware of the brand’s specific RSL restrictions and have the latest updated version available. Only do business with RSL compliant companies. Use and encourage the use of dyestuffs, pigments and textile auxiliaries from reputable manufacturers.

31. www.intertek.com31 How to avoid RS Failure Risk Assessment: Technical Managers must risk assess each product to decide if: - A product needs testing? - What it needs to be tested for? When Deciding What to Test - All new suppliers are deemed high risk and will be subject to a high test frequency in their first season until a level of confidence is established. - All suppliers who have historically performed well are deemed as low risk and can only be subjected to random testing. All infant, babies, and children’s products are considered high risk

32. www.intertek.com32 RSL Failur Frequent Failure observed in Products Manufactured in Bangladesh $Allergenic Disperse Dyes (mainly in Polyester Dyes) $Azo Dyes $Formaldehyde $SCCP (mainly in leather) $ Phthalates (soft plastics $ APEOs $ Lead in Paint $ Lead in Metal $ Chromium VI (leather)

33. www.intertek.com33 One Year Analyzed Data RS% FailureRemarks Azo Dyes4.6% Disperse Dyes3.8% Carcinogenic Dyes0% Phthalates6.8% Organotin0.3% Phenols (PCP/TeCP)1.6% COCs0.37% Formaldehyde9% Lead in Coating4.3% Lead in metals6.0% Lead in Non-metals3.7% APEOs13%

34. www.intertek.com34 CPSIA Key Regulations in consumer Products

35. www.intertek.com35 US CPSIA Background Key Definitions Key Requirements CPSIA Reform Bill – HR 2715 Recent Activity

36. www.intertek.com36 CPSIA – Consumer Product Safety Improvement Act It is targeted mostly toward "children's products", which are defined as any consumer product designed or intended primarily for children 12 years of age or younger. History

37. www.intertek.com37 Background - CPSIA Signed into Law on August 14, 2008 Scope: Consumer Products (as defined in CPSA) Key Requirements o Lead and Phthalate Content o Certification  General Certificate of Conformity (GCC)  Children’s Product Certificate (CPC) o Mandatory Toys standard (ASTM F963) o Third Party Testing for children’s product

38. www.intertek.com38 Key Definitions “Children’s Product”: a consumer product designed or intended primarily for children 12 years of age or younger. “Children’s Toy”: a consumer product designed or intended by the manufacturer for a child 12 years of age or younger for use by the child when the child plays. “Child Care Article”: a consumer product designed or intended by the manufacturer to facilitate sleep or the feeding of children age 3 and younger, or to help such children with sucking or teething.

39. www.intertek.com39 Lead Requirements (CPSIA Section 101) Total Lead in Surface Coating Requirement: 90ppm Total Lead Content (Substrate) 14 Aug 2009 – 300ppm 14 Aug 2011, 100ppm – HR 2715

40. www.intertek.com40 Phthalate Prohibition (CPSIA Section 108) From February10 th, 2009, it became unlawful for anyone to sell: Any children’s toy or child care article that contains concentrations of more than 0.1% of DEHP, DBP or BBP Any children’s toy that can be placed in a child’s mouth or child care article that also contains concentration of more than 0.1% of DINP, DIDP or DnOP Toys that can be placed in the mouth are: toys that can be kept in the mouth by a child so that it can be sucked or chewed, or toys or parts of toys with one dimension less than 5 cm.

41. www.intertek.com41 General Certification of Conformity (sec: 102) General Certification of Conformity  Product description  Date of production  Place of production  Place Product was tested All rules enforceable by CPSC: (Adult and Children product) Certification based on Third-Party Testing: - Stating the product was being tested in approved Third-party lab for Certain Tests. - Products without certificate or with a false certificate will be destroyed

42. www.intertek.com42 Third Party Testing Requirement Third party testing for most of children’s product rules are already in place. The CPSC published accreditation requirements for 3 rd party testing for ASTM F963 and phthalate content on August 3 rd and August 10 th – 2011 respectively. Certification based on 3 rd party testing will be required for applicable children’s products manufactured on and after January 1, 2012: http://www.cpsc.gov/about/cpsia/accredited.html Total lead content (Substrate) Phthalate content ASTM F963

43. www.intertek.com43 CPSIA third party testing – Example Timeline Rules/Standard/Ban Non-Children ’ s Products GCC requirement Children ’ s Products CPC based on Third party Testing requirement Lead paint on Children ’ s Products (16 CFR part 1303) Not ApplicableDecember 21, 2008 Small Parts (16 CFR part 1501)Not Applicable15 February 2009 Lead in Metal components of Chidren ’ s metal Jewelry (sec 101 of the CPSIA) Not Applicable23 March 2009 16 CFR 1500.48 & 49 – Sharp points and sharp edges Not Applicable Sept ‘ 2009 Total Lead content in metal children ’ s products and in non-metal children ’ s products (sec 101 of the CPSIA) Not Applicable 31 Dec ’ 2011 Ban on Lead-in-paint in Paint and on Furniture 10 Feb ’ 2010 Not Applicable Flammability of Vinyl Plastic (16 CFR part 1611) 26 Jan ’ 201119 Oct ’ 2010 Flammability on Wearing Apparel (16 CFR 1610) 26 Jan ’ 201116 Nov ’ 2010 Phthalates (sec 108 of the CPSIA)Not Applicable 31 Dec ’ 2011 Flammability of Children ’ s Sleepwear (16 CFR part 1615 & 1616) Not Applicable 17 Feb ’ 2011

44. www.intertek.com44 GCC = General Certificate of Conformity CPC = Children’s Product Certificate COC = Certificate of Conformity IOR = Importer of Record DM = Domestic Manufacturer CPSIA = Consumer Product Safety Act of 2008 HR 2715 = House Resolution 2715 (CPSIA reform legislation passed in 2011) CPSC = U.S. Consumer Product Safety Commission Commonly Used Acronyms

45. www.intertek.com45 www.intertek.com33 Valued Quality. Delivered.