Foreign Trade News: The American Apparel And Footwear Association (AAFA) Released The 25Th Version Of The List Of Restricted Substances

On February 6, 2025, the American Apparel and Footwear Association released the 25th version of the Restricted Substance List (RSL). As an open resource for the members of the Association and the whole industry, the list provides the industry with references to all banned and restricted chemicals and substances in finished clothing, footwear, accessories and household textiles, and clarifies the most stringent relevant regulations worldwide. The report also contains an appendix on reporting requirements, covering the states in the United States that are required to report chemicals in children's products, as well as relevant reporting rules in Europe.

1、 Main contents

The 25th edition of the restricted substances list covers 16 categories, including more than 250 chemicals, and has been updated according to new or changed regulations and laws that restrict or prohibit certain chemicals in finished clothing, footwear, accessories and household textiles. The list of restricted substances was first released in 2007 and prepared by the Working Group on the List of Restricted Substances of the American Clothing and Footwear Association. The Working Group will regularly review and update the list to reflect the latest global regulatory changes.

1. List content

(1) Covered substances: including materials, chemicals, etc. that are restricted or prohibited to be used in finished products due to laws and regulations. They do not involve the material restrictions in the production process and packaging materials, nor do they cover specific fields such as toys, automobile textiles, and the contents of product safety regulations that are not chemical management.

(2) Substance classification

AP and APEO: Different countries and regions have different restrictions on nonylphenol (NP), nonylphenol ethoxylate (NPEO), etc. For example, Taiwan, South Korea, and the European Union have specific limit regulations and detection methods.

Aromatic amines: Many countries restrict a variety of aromatic amines, and regulations and detection methods vary from region to region.

PCDDs and furans: Germany and other countries have set strict limit standards for different groups of such substances, and the United States Environmental Protection Agency has relevant industry detection methods.

Disperse dyes: The EU and other countries have limited requirements for a variety of disperse dyes, and some dyes have different limited concentrations and applicable product ranges in different countries.

Flame retardants: Some states and other countries in the United States impose restrictions on a variety of flame retardants, involving different product categories and limit requirements. Most of the detection methods are solvent extraction combined with instrumental analysis.

Formaldehyde: China and the European Union have restrictions on the content of formaldehyde, and different countries and product types have different limit standards.

Heavy metals: including extractable and soluble heavy metals. Different countries have clear regulations on the limits and detection methods of lead, cadmium and other heavy metals.

Other substances: such as azo dyes, organotin compounds, polycyclic aromatic hydrocarbons, pesticides PFAS、 Phthalates, solvents, etc., are limited to varying degrees.

2. Terminology and reporting requirements

Term explanation: explain the professional terms and abbreviations involved in the list for easy understanding.

Reporting requirements: Appendix IA lists the SVHC reporting and registration requirements in the EU market; Appendix IB shows the reporting requirements for chemicals of high concern in children's products in some US states.

2、 Update content

Compared with the 2023 version, the 2025 version of RSL has adjusted a variety of regulations and detection methods related to chemical substances in order to make the list more consistent with the latest industry norms and regulatory requirements.

AP and APEO: updated according to the new proposals of the European Union and Morocco to include second-hand clothing in the exemption scope.

Aromatic amine: update relevant laws of Egypt, Indonesia and Japan, and add laws and regulations of Saudi Arabia, India and Morocco. At the same time, the test method for 4 - aminoazobenzene was also adjusted.

Disperse dyes: restrictions on 14 kinds of disperse dyes have been added to the KC Mark standard in South Korea, and regulations on disperse dyes in the United Arab Emirates and India have been included.

Flame retardant: Incorporate relevant regulations of Maryland on flame retardant, update the test method of brominated diphenyl ether, adjust the limit values and regulatory requirements of Switzerland and persistent organic pollutants (POP), and explain the limit changes to be implemented in Japan.

Formaldehyde: In view of the regulation of REACH that the limit value of formaldehyde in non leather textiles is 75 ppm, the relevant provisions on indirect skin contact of formaldehyde in the original list are deleted. At the same time, restrictions on formaldehyde in Egypt, Morocco and India are added in the notes.

Heavy metals (extractable): in the annotation part, the heavy metal standards of Saudi Arabia, India, Morocco and Egypt are fully included, the stricter restrictions on hexavalent chromium (Cr (VI)) and chromium (Cr) in Egypt are updated, and the test methods are updated simultaneously.

Heavy metals (soluble): update the test methods and regulations cited in South Korea and Taiwan of China on the solubility limit of heavy metals.

(Source: website of Ministry of Commerce)