SAFEGUARDS | Consumer Products NO. 095/16

The American Apparel & Footwear Association (AAFA) has published the 17th edition of the Restricted Substance List (RSL), updating the list of banned or restricted chemicals and substances in finished home textile, apparel and footwear products.

The AAFA is a national trade association representing apparel, footwear and other sewn products companies and their suppliers by providing a variety of tools to facilitate compliance in the global marketplace. AAFA assists the industry in creating a safer and sustainable supply chain.  The latest AAFA RSL Release 17 [1] was published with the major changes outlined in Table 1.

Table 1 – Outline of the AAFA RSL changes from Release 16 to Release 17

Restricted Substance, Test Method, Limit and Comments Modification
Sections Changes
  • Added Japan as other countries that regulate Arylamines with test method: Textile: JIS L1940; Leather: ISO 17234-1:2010/-2:2011
Flame Retardants


  • Changed the restriction limit from “Prohibited” to “0.1% by weight”
  • Added amendment Regulation (EU) 2015/2030 for POPs Regulation (EC) No. 850/2004 Annex I
  • Changed POPs limit for articles should not above 0.15% by weight
Fluorinated Greenhouse Gases
  • Removed Regulation (EC) No. 842/2006

Restriction for Textiles, Leather, Metal Parts, Plastics and Plastic Film, Surface Coatings and Printing - Lead:

  • Added European Union REACH Regulation (EC) N0. 1907/2006 Annex XVII with restriction limit – Total Lead: 500 ppm; Rate of lead release of Lead: ≤ 0.05 μg/cm2/h (0.05 μg/g/h)
  • Added test method for Total lead: Total Digestion (industry practice – not specified by the regulation) and Rate of lead release: DIN54233-4
  • Added to comments - This restriction is applicable to products which are supplied to the general public, and can be placed in the mouth by children. This restriction will apply from 1 June 2016.
  • Updated Denmark regulation to Statutory Order no. 856 of September 5, 2009

Restrictions for Metal Parts – Nickel:

  • Updated test methods for Nickel release by EN 1811:2011+A1:2015 for non-coated item; EN 12472:2005+A1:2009 and EN 1811:2011+A1:2015 for coated item


  • Removed Poland in Comments
  • Added to Comments – US Minnesota Statutes, chapter 325F regulate formaldehyde in children’s products (<8 years old), <500 ppm

Nonyl phenolethoxylates

  • Changed the restriction limit from “1000 ppm” to “100 ppm”
  • Amended the regulation as European Union REACH Regulation (EC) No. 1907/2006 Annex XVII entry 46a (will apply from 3 Feb 2021) and European Union REACH Regulation (EC) No. 1907/2006 Candidate List

Polycyclic aromatic hydrocarbons (PAH)

  • Changed the test method for European Union from “ZEK 01.4-08 (recommended)” to “AfPS GS 2014:01 PAH”

Dimethyl Fumarate

  • Removed in Comments – Spain (Footwear), EU (products), France: Are suspended for one year the importation and marketing for free or expensive, seats and footwear containing dimethyl fumarate (EC number: 210-849-0).
  • Added 1,2-benzenedicarboxylic acid, di-C6-10-alkyl esters; 1,2-benzenedicarboxylic acid, mixed decyl and hexyl and octyl diesters with ≥ 0.3% of dihexyl phthalate (CAS #: 68515-51-5 / 68648-93-1) (EC No. 201-559-5)

Other changes from Release 16 to Release 17:

  • Updated the REACH SVHC Candidate List in Appendix I – Reporting
  • Removed the Appendix III – Non-regulated substances on the AFIRM RSL Guidance which do not otherwise appear in the AAFA RSL

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