ASOS Brand Suppliers (effective from March 2018)
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ASOS Chemical Policy and Restricted Substance List (RSL) ASOS Brand Suppliers (effective from March 2018) For ASOS, 'Fashion with Integrity' means managing all aspects of our business transparently and appropriately. We want our customers to enjoy their fashion secure in the knowledge that, when buying from ASOS, they are buying from a responsible company that is actively working to deliver fashion with both integrity and respect for people, animals and the environment, on a sustainable long-term basis. ‘Fashion with Integrity’ therefore encompasses the chemicals that are used in any aspect of our products, our fabrics, our components and our packaging. As a valued supplier to ASOS, this document explains what we need you to do help us deliver Fashion with Integrity with regard to the chemicals used to manufacture products supplied to ASOS. Key Principles Eliminate Harmful Chemicals As ASOS continues to build its sustainability commitment, we aim to reduce environmental impact and eliminate the use of harmful chemicals to protect worker/consumer health and the environment. Compliance to Global Legislations ASOS has developed a Restricted Substance List (RSL), which outlines the acceptable limits of potentially toxic or harmful substances which can be present in finished products. This RSL has been developed to comply with legislative and regulatory requirements of global trading territories ASOS sells within, including REACH and Proposition 65. ASOS expects all our suppliers (including brands) to supply products that comply with applicable global legislative and regulatory requirements and take responsibility for keeping up to date with any legislative changes. Suppliers should be risk-assessing all materials and product for compliance as part of product development process. Industry Collaboration Chemical compliance and safer chemistry can be overwhelming and we cannot do it alone. We commit to working with our supply chain, industry associations and leaders to accelerate industry efforts towards safer, sustainable chemistry inputs, processes and outputs. Action for Suppliers ASOS requires suppliers to ensure all products and packaging meet the limits set out in our RSL. To ensure compliant product, suppliers must: Communicate our RSL and ZDHC’s MRSL (Manufacturing Restricted Substance List) upstream to material, component and chemical suppliers. Source materials/components responsibly at development/order stage by requesting declarations, recognised certifications and/or test reports from your suppliers showing compliance to our RSL. Map material/component sources to establish compliant sources. Test materials/components for high-risk chemicals and submit mandatory chemical testing to the requirements specified in our Global Testing Manual to your technologist prior to Gold Seal Approval. Highlight any non-conformance with our RSL prior to starting production/delivery. Respond swiftly to ASOS’ request to see evidence of compliance in cases of customer complaints or enforcement authority challenge. Refer to our Chemical Policy Guidelines to implement better chemical management practices. 1 Version 1 March 2018
ASOS Actions on Chemical Failures As soon as the brand becomes aware of any product that may not comply with our RSL you shall notify ASOS immediately. You must provide evidence of compliance and product information required in the format set out below. You agree to co-operate with all reasonable requests to provide such information as necessary to demonstrate evidence of testing and product compliance. Dealing with complaints and enforcement authority challenges: In the event that: a) ASOS receives notice that it has resold a product supplied by you that does not comply with our RSL; or b) ASOS carry out testing on your Products and determine a failure to comply with our RSL; or c) ASOS receives a complaint from our customer, we will take steps to immediately withdraw the Product from further sale. ASOS will not accept products, which fail to comply with our RSL and reserves the right to: Reject non-compliant products and require a replacement with compliant Products; Require re-working of the Products to comply with the ASOS RSL; Test and/or conduct a Product recall; Cancel any undelivered order/s; Discount / price reduction of delivered orders; Apply service credits Apply monetary deductions including but not limited to covering the cost of paying fines to an enforcement authority Account for any lost profits incurred by ASOS including but not limited to as a result of a Product recall and making goodwill payments. Destroy or safely dispose of products (at supplier’s cost) Reject stock (supplier to arrange and pay for the cost of storage and collection) Recover associated costs from suppliers Product information required to be submitted by suppliers, when non-compliance is detected: Product name/description Product SKU PO number Quantity of affected product supplied to ASOS Name of restricted substance present in product CAS number The level of Restricted Substance detected and as a percentage of the weight of the individual component within the Product(s). Weight of product Details of product testing (include testing for lead) Details of other orders which may be affected 2 Version 1 March 2018
Version: 4 Issue Date: March 2018 Revision Date: January 2019 KEY: RESTRICTED SUBSTANCE LIST FOR ADULT PRODUCTS & PACKAGING C - Carcinogenic CO - Contamination B - Bioaccumulative RSL (Restricted Substance List): The ASOS RSL applies to all fabrics, components, products and packaging. The RSL details the global requirement for restricted substances and respective limits in finished goods. For some high risk materials we require mandatory testing to be submitted per order, this is communicated in our Global Testing ED - Endocrine Disruptor Manual. Increasingly there will be a need to apply chemical tests in production, and more of these may become mandatory in future revisions. Suppliers not already doing so should begin to assess their ability to evidence compliance to the ASOS RSL through testing or through other means. If you become aware that any Product(s) may or do contain any restricted substance(s), please notify ASOS immediately - compliance@asos.com and your retail/technical contact. ● ● ● I - Irritant M - Mutagenic high risk - medium risk - low risk R - Reprotoxic widely used detected S - Sensitisation frequently occasionally T - Toxic MRSL (Manufacturing Restricted Substance List): As ASOS continues to look at environmental impact of hazardous chemicals, it is becoming increasingly important for us to understand conformance on input chemistry. Please ask your upstream suppliers to ensure raw materials, finished components and chemical suppliers are meeting detected VP - Very Persistent the limits set out in the ZDHC MRSL. The ZDHC MRSL can be found at http://www.roadmaptozero.com/fileadmin/pdf/MRSL_v1_1.pdf Applicable Materials Exposure & Hazard ASOS Requirement Environment Legislation Legislative Requirement Plastic, Consumer Test Method for for Finished Products Worker Health Health Substance Standard/Eco-Label for Finished Products Synthetic Natural Synthetic Coating / Paper / Potential Uses Summary Legislation Leather Rubber Metal Glass Comments by Country (maximum allowable limit) materials Fibres Fibres Printing Card (maximum allowable limit) inc. PU,PVC Test method: ● ● ● ● ● ● ● Textile: BS EN ISO 18254-1: 2016 NPEO: Leather: ISO 18218-1:2015 APEO/NPEO are auxiliary chemicals used in various EU: REACH - Entry 46a and 46b of amending Annex VP NPEO is the biggest source of NP present in the Alkylphenols & Alkylphenol XVII of REACH Regulation (EC) No 552/2009 Textile: BS EN ISO 18254-1: 2016 Textile materials: 100 mg/kg industries. They are good emulsifiers and wetting agents T environment. NP is a potent endocrine disrupter Ethoxylates (previous Regulation (EC) No 1907/2006 (effective Leather and polymer materials: 1000mg/kg Requirement: and thus have been widely employed in different industrial T to the aquatic environment and can cause (APEO, NP, OP, NPEO, OPEO) Leather: ISO 18218-1:2015 NPEO: and domestic detergents. They also co-formulants in ED date: 3rd February 2021) NP: 1000 mg/kg Textile materials: 100 mg/kg pesticides and biocides. ED feminization in some male fish. Leather and polymer materials: 1000mg/kg NP: 1000 mg/kg EU: REACH - Entry 43 of Regulation (EC) No Textile: ISO 14362-1:2017 Leather: ISO 17234-1 30 mg/kg ● ● ● ● ● 552/2009 amending Annex XVII of EC Inventory - 4-aminoazobenzene confirmation: (artificial leather) (vivid colours (22 banned arylamines) Regulation No 1907/2006 Textile: ISO 14362-3:2017 (Footwear only) especially red, Leather: ISO 17234-2 orange and Test method: yellow are Textile: ISO 14362-1:2017 highest risk) Textile: GB/T 17592:2011 Textile: 20 mg/kg; Leather: ISO 17234-1 China: Textile: GB 18401-2010 Leather: GB/T 19942 Leather: 30mg/kg; 4-aminoazobenzene confirmation: Leather: GB 20400-2006 Under basic chemical or enzymatic conditions, 4-Aminoazobenzene confirmation: (23 banned arylamines ) Textile: ISO 14362-3:2017 Footwear: GB 25038-2010 Azo dyes and pigments are colourants containing at least some azo dyes may release aromatic amines Textile: GB/T 23344 Footwear: 30 mg/kg Leather: ISO 17234-2 Azo Dyes one azo bond (-N=N-) within the molecule. They are C C which are classified as carcinogens. These commonly used as colorant in textile and apparel industry. regulated Azo dyes should no longer be used in Requirement: colouring textiles. Textile: ISO 14362-1:2017 30 mg/kg Leather: ISO 17234-1 AU: Australian Competition and Consumer 30 mg/kg 4-aminoazobenzene confirmation: xylidine) Commission Safety Guidance (22 banned arylamines) Textile: ISO 14362-3:2017 Leather: ISO 17234-2 30 mg/kg India: Environmental (Protection) Act - (22 banned arylamines) EU: Entry 66 of Annex XVII of REACH Regulation (EC) No 1907/2006 (effective date: 2nd Jan 2020) Regulation (EC) No 1907/2006 200mg/kg ● ● EU: Regulation (EU) No 10/2011 Regulation (EU) No 10/2011 ≤ 0.6 mg/kg (migration) Test method: Regulation (EU) No 10/2011 Bisphenol A is commonly used as a monomer in plastic, C BPA Bisphenol A expoxy resion and polycarbonate. e.g. plasticware for M Requirement: food. EU: REACH Regulation (EC) No 1907/2006 - SVHC Regulation (EU) No 10/2011 0.1% per product, up to one tonne total R Candidate List US: California Proposition 65 3 µ/d EU: Entry 23 of Regulation (EC) No 552/2009 Substrate: Plastic, metal in jewellery: 100 mg/kg; ● ● ● ● ● ● amending Annex XVII of REACH Regulation (EC) No EN1122 Surface coating/paint on article: (coated metals - 1907/2006 1000 mg/kg; red, oranges, Paint: Not detected yellow and Test method: green are Non metal: EN 1122 highest risk) ICP-OES, GC-MS, UV-VIS, HPLC- Metal: Acid digestion Cadmium is a naturally occurring and abundant metal. In EU: REACH Regulation (EC) No 1907/2006 - SVHC DAD, HPLC-MS and colorimetric Cadmium 0.1% per product, up to one tonne total apparel, cadmium is used as a colourant and stabiliser in Heavy metals are suspected carcinogens and (Total) Candidate List method Requirement: plastics, pigments and coatings. Cadmium can also be C C are banned from intentional use in textiles. Substrate: Plastic, metal in jewellery: 100 mg/kg; found in fertilisers, biocides and paints. Surface coating/paint on article: 300 mg/kg; Paint: Not detected US: California Proposition 65 - Ref: RG-10-514803 (consolidation with Case No. RG 10-545680 and RG Acid Digestion/AAS 300mg/kg 10-545687) ● ● (deep/saturated shades are Chromium (VI) is known to be carcinogenic and Test method: highest risk) is corrosive to skin. Skin contact with certain Chromium VI EU: Entry 47 of Commission Regulation (EU) No 301/2014 amending Annex XVII of REACH ISO 17075-2: 2017 with ageing (80°C for 24 hours at less than 5% None detected (3mg/kg) IISO 17075-2: 2017 with ageing (80°C for 24 hours at less than 5% RH) In textiles and apparel, chromium (VI) is usually associated with plastics, dyes and tanned leather - predominantly from C C chromium (VI) compounds can cause skin ulcers. Potassium dichromate (VI) and other chromium Regulation (EC) No 1907/2006 RH) Requirement: the potassium dichromate two-bath tanning process. S S (VI) compounds are banned, and residues in 3 mg/kg chromium (III) tanning agents are restricted.
Version: 4 Issue Date: March 2018 Revision Date: January 2019 KEY: RESTRICTED SUBSTANCE LIST FOR ADULT PRODUCTS & PACKAGING C - Carcinogenic CO - Contamination B - Bioaccumulative RSL (Restricted Substance List): The ASOS RSL applies to all fabrics, components, products and packaging. The RSL details the global requirement for restricted substances and respective limits in finished goods. For some high risk materials we require mandatory testing to be submitted per order, this is communicated in our Global Testing ED - Endocrine Disruptor Manual. Increasingly there will be a need to apply chemical tests in production, and more of these may become mandatory in future revisions. Suppliers not already doing so should begin to assess their ability to evidence compliance to the ASOS RSL through testing or through other means. If you become aware that any Product(s) may or do contain any restricted substance(s), please notify ASOS immediately - compliance@asos.com and your retail/technical contact. ● ● ● I - Irritant M - Mutagenic high risk - medium risk - low risk R - Reprotoxic widely used detected S - Sensitisation frequently occasionally T - Toxic MRSL (Manufacturing Restricted Substance List): As ASOS continues to look at environmental impact of hazardous chemicals, it is becoming increasingly important for us to understand conformance on input chemistry. Please ask your upstream suppliers to ensure raw materials, finished components and chemical suppliers are meeting detected VP - Very Persistent the limits set out in the ZDHC MRSL. The ZDHC MRSL can be found at http://www.roadmaptozero.com/fileadmin/pdf/MRSL_v1_1.pdf Applicable Materials Exposure & Hazard ASOS Requirement Environment Legislation Legislative Requirement Plastic, Consumer Test Method for for Finished Products Worker Health Health Substance Standard/Eco-Label for Finished Products Synthetic Natural Synthetic Coating / Paper / Potential Uses Summary Legislation Leather Rubber Metal Glass Comments by Country (maximum allowable limit) materials Fibres Fibres Printing Card (maximum allowable limit) inc. PU,PVC ● ● (PU only) (PU only) EU: Annex XIV of REACH Authorisation List. PD CEN ISO/TS 16189:2013 1000mg/kg Test method: DMFa is fatal if inhaled, is toxic if swallowed, R PD CEN ISO/TS 16189:2013 DMFa is mainly used as solvent, and the manufacture of R causes severe skin burns and eye damage, may Dimethylformamide (DMFa) adhesives, synthetic leathers, fibres, and surface coatings. T cause cancer, may damage fertility or the Requirement: unborn child and may cause allergy or asthma 1000mg/kg S symptoms or breathing difficulties if inhaled. ICP-OES, GC-MS, UV-VIS, HPLC- EU: REACH Regulation (EC) No 1907/2006 - SVHC DAD, HPLC-MS and colorimetric 0.1% per product, up to one tonne total Candidate List method Test method: ● ● ● ● ● ● DMFu is mainly applied in leather products to avoid EU: Entry 61 of Regulation (EU) No 412/2012 In house method, GC-MS analysis Skin itching, irritation, redness and acute deterioration during storage and transportation. It has been Dimethyl Fumarate (DMFu) amending Annex XVII of REACH Regulation (EC) No In house method, GC-MS analysis 0.1 mg/kg found in silica gel sachets and will evaporate onto the S S respiratory difficulties are symptoms of exposure 1907/2006 Requirement: to DMFu. leather or other materials to protect them from mould. 0.1 mg/kg Test method: ● Some of them possess irritant properties such as DIN 54231 Disperse dyes are water-insoluble colorants that are mainly Disperse dyes skin irritation, itchy, stuffy noses, sneezing and (Allergenic and Carcinogenic) Germany: LFGB §64 DIN 54231 5 mg/L used for colouring polyester, nylon and cellulose acetate S S sore eyes. Restricted disperse dyes should no Requirement: textile fibres. longer be used for the dyeing of textiles. 5 mg/L ● (artificial ● (Footwear ● (Footwear ● (Footwear ● ● ● ● ● Test method: leather) only) only) only) Arsenic, Cadmium, Mercury, Lead and Chromium (VI) are GB/T 17593.2 (Footwear only) banned in textile production. Refer to individual descriptions for Cadmium, Lead and Chromium (VI). Arsenic, Cadmium, Mercury, Lead and Extractable Heavy Metals China: GB 25038-2010 GB/T 17593.2 Requirement: Arsenic is found in cotton farming as a preservative, Chromium (VI) . See individual metals for more pesticide and defoliant. Mercury is found in pesticides and detail. as a contaminant in Caustic Soda (NaOH). Mercury compounds have been used in paints and surface coatings. EU: PBB - Entry 8 of Regulation (EC) No 552/2009 ● ● ● ● (where finishes (where finishes (where finishes (where finishes amending Annex XVII of REACH Regulation (EC) No are applied) are applied) are applied) are applied) 1907/2006 (previously restricted under Directive 83/264/EEC); OctaBDE - entries 45 of Regulation PBB, TRIS, TEPA - Not Detected; (EC) No 552/2009 amending Annex XVII of REACH In-house method: GC-MS/ GC- OctaBDE - 1000 mg/kg Regulation (EC) No 1907/2006; TRIS and TEPA - NPD/MS/LC-MS analysis DecaBDE - 1000 mg/kg entries 4 and 7 of Regulation (EC) No 552/2009 amending Annex XVII of REACH Regulation (EC) No 1907/2006; DecaDBE - Entry 67 Annex XVII (EU) 2017/227 (effective date: 2nd March 2019) Test method: In-house method; GC-MS/ GC-NPD/MS /LC-MS analysis Requirement: Flame Retardants EU: POPs - Commission regulation (EU) No. PBB, TRIS, TEPA, TCEP, TDCPP, PentaBDE, OctaBDE, DecaBDE: Flame retardants are used in a wide range of products like automobiles, electronics and textiles because of their C C These kinds of flame retardants are suspected to 757/2010 amending annex I of Regulation (EC) No Usage Ban be carcinogenic and mutagenic. 850/2004 of the European Parliament and of the TetraBDE, HexaDBE, HeptDBE: 10 mg/kg stability and heat resistance. M M Council concerning Persistent Organic Pollutants Antimony trioxide, SCCP, TBB, TBBPA, TBPH, TCPP: 1000 PentaBDE, TetraBDE, HexaDBE, HeptDBE - 10 (POPs). PentaBDE (entries 44 of Regulation (EC) No In-house method: GC-MS/ GC- mg/kg mg/kg; 552/2009 amending Annex XVII of REACH NPD/MS/LC-MS analysis HBCDD - 100mg/kg HBCDD - 100mg/kg Regulation (EC) No 1907/2006); TetraBDE, HexaDBE, HeptaDBE - commission regulation No 757/2010. HBCDD - EU regulation 2016/293 amending Regulation (EC) No 850/2004. PentaBDE, OctaBDE, DecaBDE, TCEP, TDCPP : Usage ban US: State Legislations: Washington, Maine, Oregon, In-house method: GC-MS/ GC- New York, Vermont NPD/MS/LC-MS analysis Antimony trioxide, HBCDD, SCCP, TBB, TBBPA, TBPH, TCPP :1000 mg/kg
Version: 4 Issue Date: March 2018 Revision Date: January 2019 KEY: RESTRICTED SUBSTANCE LIST FOR ADULT PRODUCTS & PACKAGING C - Carcinogenic CO - Contamination B - Bioaccumulative RSL (Restricted Substance List): The ASOS RSL applies to all fabrics, components, products and packaging. The RSL details the global requirement for restricted substances and respective limits in finished goods. For some high risk materials we require mandatory testing to be submitted per order, this is communicated in our Global Testing ED - Endocrine Disruptor Manual. Increasingly there will be a need to apply chemical tests in production, and more of these may become mandatory in future revisions. Suppliers not already doing so should begin to assess their ability to evidence compliance to the ASOS RSL through testing or through other means. If you become aware that any Product(s) may or do contain any restricted substance(s), please notify ASOS immediately - compliance@asos.com and your retail/technical contact. ● ● ● I - Irritant M - Mutagenic high risk - medium risk - low risk R - Reprotoxic widely used detected S - Sensitisation frequently occasionally T - Toxic MRSL (Manufacturing Restricted Substance List): As ASOS continues to look at environmental impact of hazardous chemicals, it is becoming increasingly important for us to understand conformance on input chemistry. Please ask your upstream suppliers to ensure raw materials, finished components and chemical suppliers are meeting detected VP - Very Persistent the limits set out in the ZDHC MRSL. The ZDHC MRSL can be found at http://www.roadmaptozero.com/fileadmin/pdf/MRSL_v1_1.pdf Applicable Materials Exposure & Hazard ASOS Requirement Environment Legislation Legislative Requirement Plastic, Consumer Test Method for for Finished Products Worker Health Health Substance Standard/Eco-Label for Finished Products Synthetic Natural Synthetic Coating / Paper / Potential Uses Summary Legislation Leather Rubber Metal Glass Comments by Country (maximum allowable limit) materials Fibres Fibres Printing Card (maximum allowable limit) inc. PU,PVC ICP-OES, GC-MS, UV-VIS, HPLC- EU: REACH Regulation (EC) No 1907/2006 - SVHC DAD, HPLC-MS and colorimetric ● ● ● ● ● ● 0.1% per product, up to one tonne total (artificial (permanent (permanent Candidate List method leather) crease finishes crease finishes (Footwear only) are highest risk) are highest risk) Test method: Textiles: ISO 14184-1 Despite its multi-function properties, Leather: ISO 17226-2 (by UV method) Formaldehyde is a volatile organic compound whose formaldehyde is an irritant that sensitizes mucous chemical properties make it suitable to be used as an anti- membranes. clothing specifically marketed as suitable for Requirement: creasing and anti-shrinking agent. It can be co-polymerized T Formaldehyde AU: Australian Competition and Consumer people with sensitive skin: 30 mg/kg clothing specifically marketed as suitable for people with with phenol or urea to form polymeric resins. In textiles and I When inhaled formaldehyde may cause Commission Safety Guidance ISO 14184-1 garments which contact the skin: 100 mg/kg sensitive skin: 30 mg/kg apparel, formaldehyde may be found in stiffened and S headaches, a burning sensation in the throat, other garments or fabrics: 300 mg/kg Direct skin contact: 75 mg/kg permanent press fabrics. and difficulty breathing, and can trigger or Non-direct skin contact: 300 mg/kg aggravate asthma symptoms Footwear: 75 mg/kg For Textile & Leather: China: Textile: GB 18401-2010 Textile: GB/T 2912.1 Direct skin-contact = 75mg/kg; Leather: GB 20400-2006 Leather: GB/T 19941 Non-Direct skin-contact = 300 mg/kg Footwear: GB 25038-2010 For footwear: 75 mg/kg ● ● ● ● ● ● ● (coated ● ● EU: Entry 63 of Regulation (EC) No 836/2012 (non-jewellery metals are amending Annex XVII of REACH Regulation (EC) No In-house method; Acid digestion only) highest risk) 0.05% (500mg/kg) 1907/2006/ Commission Regulation (EU) with AAS 2015/628 Test method: Jewellery: EPA 3050B / 3051A / 3052 Non-jewellery: Metal: CPSC-CH-E1001-08.3 Lead is a metal which can be found naturally in many ores. Lead is a suspected carcinogen and can Jewellery: Non-metal: CPSC-CH-E1002-08.3 Catalysts used to synthesize paint, plastic, pigment inks and Lead (Total) Class 1 component* - no requirement Surface coating: CPSC-CH-E1003-09.1 coatings may contain lead. As a result, traces of lead C CO adversely affect the central nervous system, Jewellery: kidneys and the immune system. Class 2 component - Electroplated metal; compounds may remain in the finished product. EPA 3050B / 3051A / 3052 6.0% Requirement: US: Jewellery: California metal containing jewellery law Unplated metal; 1.5% Non-jewellery: Plastic or rubber including acrylic, Surface coating: 90 mg/kg; Non-jewellery: California Proposition 65* Metal: CPSC-CH-E1001-08.3 polystyrene, plastic beads and stones and Accessible substrate: 90 mg/kg (bag); 100 mg/kg (others) CGC-00-313596/ 03-427020/ 05-440570/ 03- Non-metal: CPSC-CH-E1002-08.3 polyvinyl chloride (PVC); 200 ppm Accessible substrate with PVC: 200 mg/kg 41631/ RG13663979, CGC-11-509211 Surface coating: CPSC-CH-E1003- Paint or surface coating; 600 ppm 09.1 Class 3 component - Material other than Class 1 or 2; 600 ppm Non-jewellery: Surface coating: 90 mg/kg; Accessible substrate: 90 mg/kg (bag); 100 mg/kg (others) Accessible substrate with PVC: 200mg/kg Test method: ● ● ● ● ● (non-jewellery Non-coated: Non-coated: only) ASTM D5517(extraction with ASTM D5517(extraction with artificial saliva) EU: Annex XVII artificial saliva) Lead is a metal which can be found naturally in many ores. Regulation (EC) No. 1907/2006. Lead is a suspected carcinogen and can Coated: Catalysts used to synthesize paint, plastic, pigment inks and Lead (Release) Coated: EN 12472:2005 + A1:2009 and ASTM D5517(extraction with coatings may contain lead. As a result, traces of lead C CO adversely affect the central nervous system, kidneys and the immune system. EN 12472:2005 + A1:2009 and artificial saliva) compounds may remain in the finished product. ASTM D5517(extraction with artificial saliva) Requirement: Non-coated: EN 1811:2011 + A1:2015 (nickel ● migration) (shiny metals Test method: EU: Entry 27 of Regulation (EC) No 552/2009 Direct and prolong contact with skin: are highest risk) Coated: Non-coated: amending Annex XVII of REACH Regulation (EC) No EN 1811:2011 + A1:2015 EN 12472:2005+A1:2009 (wear 1907/2006 Coated: and corrosion) EN 12472:2005+A1:2009 In metal components, nickel can migrate to the Nickel is a naturally occurring metal. In textiles and Sunglasses: Sunglasses: surface of the metal causing skin irritation or Nickel (Release) EN 16128:2015 EN 16128:2015 apparel, nickel can be found in paints, inks, plastic and S high levels of skin allergy in some consumers, metal accessories. particularly in prolonged skin contact. Requirement: Direct and prolong contact with skin: Coated item; GB/T 28485 and China: GB 28480-2012 GB/T 19719 article) Non-coated item; GB/T 19719
Version: 4 Issue Date: March 2018 Revision Date: January 2019 KEY: RESTRICTED SUBSTANCE LIST FOR ADULT PRODUCTS & PACKAGING C - Carcinogenic CO - Contamination B - Bioaccumulative RSL (Restricted Substance List): The ASOS RSL applies to all fabrics, components, products and packaging. The RSL details the global requirement for restricted substances and respective limits in finished goods. For some high risk materials we require mandatory testing to be submitted per order, this is communicated in our Global Testing ED - Endocrine Disruptor Manual. Increasingly there will be a need to apply chemical tests in production, and more of these may become mandatory in future revisions. Suppliers not already doing so should begin to assess their ability to evidence compliance to the ASOS RSL through testing or through other means. If you become aware that any Product(s) may or do contain any restricted substance(s), please notify ASOS immediately - compliance@asos.com and your retail/technical contact. ● ● ● I - Irritant M - Mutagenic high risk - medium risk - low risk R - Reprotoxic widely used detected S - Sensitisation frequently occasionally T - Toxic MRSL (Manufacturing Restricted Substance List): As ASOS continues to look at environmental impact of hazardous chemicals, it is becoming increasingly important for us to understand conformance on input chemistry. Please ask your upstream suppliers to ensure raw materials, finished components and chemical suppliers are meeting detected VP - Very Persistent the limits set out in the ZDHC MRSL. The ZDHC MRSL can be found at http://www.roadmaptozero.com/fileadmin/pdf/MRSL_v1_1.pdf Applicable Materials Exposure & Hazard ASOS Requirement Environment Legislation Legislative Requirement Plastic, Consumer Test Method for for Finished Products Worker Health Health Substance Standard/Eco-Label for Finished Products Synthetic Natural Synthetic Coating / Paper / Potential Uses Summary Legislation Leather Rubber Metal Glass Comments by Country (maximum allowable limit) materials Fibres Fibres Printing Card (maximum allowable limit) inc. PU,PVC ● (rubber, ● Test method: footwear only) (latex and GB/T 24153 rubber are Nitrosamines, and are associated with rubber and latex N-Nitrosamines China: GB 25038-2010 GB/T 24153 Not detected (detection limit: 0.5 mg/kg) highest risk) products, chemical intermediaries and finished cosmetics. C C They are known to be carcinogenic. Requirement: Not detected (detection limit: 0.5 mg/kg) ● ● ● ● ● ● ● (antibacterial (glitter, foil, Test method: BS ISO 17353, GC-MS analysis finishes) plastisol prints Tri-substituted organostannic and binders are The major commercial applications of organotin compounds Organotin compounds are environmental compounds such as highest risk) EU: Entry 20 of Regulation (EC) No 276/2010 Requirement: are as plastic heat stabilisers, catalytic agents, industrial S pollutants and particularly harmful and toxic to Organotin Compounds amending Annex XVII of REACH Regulation (EC) No BS ISO 17353, GC-MS analysis weight of tin Tri-substituted organostannic biocides and antifouling for paints. In textiles organotins ED T the aquatic organisms. They can damage liver, 1907/2006 are associated with plastics/rubber, inks, paint, metallic ED kidneys, and cause disruption of the endocrine by weight of tin glitter, PU and heat transfer material. system. ICP-OES, GC-MS, UV-VIS, HPLC- ● ● ● ● EU: REACH Annex XVII Entry 68 (effective date: 4th DAD, HPLC-MS and colorimetric (water repellent (water repellent (water repellent (water repellent 25ug/kg July 2020) method or stain or stain or stain or stain resistant resistant resistant resistant finishes) finishes) finishes) finishes) ICP-OES, GC-MS, UV-VIS, HPLC- EU: REACH Regulation (EC) No 1907/2006 - SVHC DAD, HPLC-MS and colorimetric 0.1% per product, up to one tonne total Candidate List method Test method: PFOA has been used to provide soil, oil and water CEN/TS 15968: 2014 resistance to textiles, apparels, leather and footwear. In PFOA is classified as a persistent organic Perflurooctanoic acid (PFOA) textile processing, PFOA is also used in polymers like VP pollutant. Requirement: EU: POPs Commission regulation (EU) No. polytetrafluoroethylene (PTFE). Ban 757/2010 amending Regulation (EC) No 850/2004 of the European Parliament and of the CEN/TS 15968: 2010 Ban Council concerning Persistent Organic Pollutants (POPs) , Annex B Textile/carpet/coated consumer product: 1 Norway: Norwegian Product Regulations CEN/TS 15968: 2010 other consumer product: 1000 mg/kg ICP-OES, GC-MS, UV-VIS, HPLC- ● ● ● ● (water repellent (water repellent (water repellent (water repellent EU: REACH Regulation (EC) No 1907/2006 - SVHC DAD, HPLC-MS and colorimetric 0.1% per product, up to one tonne total or stain or stain or stain or stain Candidate List method resistant resistant resistant resistant finishes) finishes) finishes) finishes) Test method: PFOS has been used to provide soil, oil and water CEN/TS 15968: 2014 resistance to textiles, apparels, leather and footwear. In Perflurooctane sulfonates (PFOS) PFOS is classified as a persistent organic textile processing, PFOS is also used as wetting agents to VP pollutant. Requirement: improve the coverage and penetration of substances, and Ban enhance dyeing and as a binder in non-woven fabrics. EU: POPs Commission regulation (EU) No. 757/2010 amending Annex I of Regulation (EC) No 850/2004 of the European Parliament and of the CEN/TS 15968: 2010 Ban Council concerning Persistent Organic Pollutants (POPs) , Annex B
Version: 4 Issue Date: March 2018 Revision Date: January 2019 KEY: RESTRICTED SUBSTANCE LIST FOR ADULT PRODUCTS & PACKAGING C - Carcinogenic CO - Contamination B - Bioaccumulative RSL (Restricted Substance List): The ASOS RSL applies to all fabrics, components, products and packaging. The RSL details the global requirement for restricted substances and respective limits in finished goods. For some high risk materials we require mandatory testing to be submitted per order, this is communicated in our Global Testing ED - Endocrine Disruptor Manual. Increasingly there will be a need to apply chemical tests in production, and more of these may become mandatory in future revisions. Suppliers not already doing so should begin to assess their ability to evidence compliance to the ASOS RSL through testing or through other means. If you become aware that any Product(s) may or do contain any restricted substance(s), please notify ASOS immediately - compliance@asos.com and your retail/technical contact. ● ● ● I - Irritant M - Mutagenic high risk - medium risk - low risk R - Reprotoxic widely used detected S - Sensitisation frequently occasionally T - Toxic MRSL (Manufacturing Restricted Substance List): As ASOS continues to look at environmental impact of hazardous chemicals, it is becoming increasingly important for us to understand conformance on input chemistry. Please ask your upstream suppliers to ensure raw materials, finished components and chemical suppliers are meeting detected VP - Very Persistent the limits set out in the ZDHC MRSL. The ZDHC MRSL can be found at http://www.roadmaptozero.com/fileadmin/pdf/MRSL_v1_1.pdf Applicable Materials Exposure & Hazard ASOS Requirement Environment Legislation Legislative Requirement Plastic, Consumer Test Method for for Finished Products Worker Health Health Substance Standard/Eco-Label for Finished Products Synthetic Natural Synthetic Coating / Paper / Potential Uses Summary Legislation Leather Rubber Metal Glass Comments by Country (maximum allowable limit) materials Fibres Fibres Printing Card (maximum allowable limit) inc. PU,PVC ● ● (flexible ● (flexible plastic plastic ICP-OES, GC-MS, UV-VIS, HPLC- 0.1% per product, up to one tonne total components components EU: REACH Regulation (EC) No 1907/2006 - SVHC DAD, HPLC-MS and colorimetric and PU/PVC and PU/PVC Candidate List method 18 phthalates coatings are coatings are highest risk) highest risk) Test method: CPSC-CH-C1001-09.3 Predominantly found as plasticisers in flexible plastic Requirement: products such as children toys, and coated textiles e.g. PVC, ED ED Phthalates are endocrine disruptors, impairing Phthalates For PVC - DEHP, BBP, DnHP, DBP, DIDP: 600 mg/kg (each) PU. They are also used as fixatives, detergents, lubricating EC fertility, impacting aquatic life and are possible DINP: 1000 mg/kg oils and solvents. C C carcinogens. For Other plastics - DEHP, BBP, DBP, DIDP, DnHP, DINP, DIBP, For PVC - DEHP, BBP, DnHP, DBP, DIDP: 600 DCHP, DPENP: 1000 mg/kg (each) mg/kg (each) DINP: 1000 mg/kg US: California Proposition 65* - Ref CIV 10- CPSC-CH-C1001-09.3 For Other plastics - DEHP, BBP, DBP, DIDP, 00641/114CV267501/ CGC - 11-511836 DnHP, DINP, DIBP, DCHP, DPENP: 1000 mg/kg (each) EU: Entry 22 of Annex XVII of REACH Regulation (EC) No 1907/2006 BS EN ISO 17070:2015 PCP: 1000mg/kg ● ● ● ● ● (artificial leather) (Footwear only) EU: POPs Persistent Organic Pollutants, Annex A BS EN ISO 17070:2015 PCP: 1000mg/kg 2015 Test method: Textile / Leather: LFGB § 64 BVL B82.02.8, GC-ECD analysis; Chlorophenols are polychlorinated compounds used as Polyester / polyester-blend / printed fabric: Modified § 64 preservatives and pesticides. PCP and TeCP have been used T T Some Chlorophenols are toxic when inhaled, LFGB BVL B82.02.8 with alkaline digestion ingested or absorbed through the skin. Long term Polychlorinated Phenols (PCP) Textile / Leather: LFGB § 64 BVL as mould prevention for leather / hides, and as R R CO reproductive effects, liver and kidney damage, B82.02.8, GC-ECD analysis; preservatives in print pastes, but are now regulated and Germany: Gefahrstoff Verordnung (Hazardous Polyester / polyester-blend / Requirement: should not be used. C C and suspected carcinogens. PCP: 5 mg/kg PCP: 5 mg/kg Substances Ordinance), Annex IV, No.12 printed fabric: Modified § 64 LFGB Footwear: PCP, 2,3,5,6-TeCP: Not Detected BVL B82.02.8 with alkaline digestion GB/T 18414.1 or China: GB 25038-2010 PCP, 2,3,5,6-TeCP: not detected GB/T 18414.2 Sum of 18 PAHs: 10 mg/kg Sum of ANA, ANY, ANT, FLU, PHE, FLT, PYR: ● (recycled ● ● (rubber is with reference to AfPS GS 2014:01 10 mg/kg plastics are highest risk, Germany: Germany GS mark PAK, GC-MS analysis BaP, BeP, BaA, CHR, BbF, BjF, BkF, DBA, IPY, highest risk, particularly BPE : 0.5 mg/kg (each) particularly black) NAP: 2 mg/kg black) Test method: with reference to AfPS GS 2014:01 PAK, GC-MS analysis EU: Entry 50 of Commission Regulation (EC) No PAHs are produced by the incomplete combustion of with reference to AfPS GS 2014:01 BaP, BeP, BaA, CHR, BbF, BjF, BkF, DBA: organic materials such as wood, oil, and animal fats. PAHs 1272/2013 amending Annex XVII of REACH Polycyclic Aromatic Hydrocarbons Regulation (EC) No 1907/2006 PAK, GC-MS analysis 1.0 mg/kg (each) Requirement: are less water-soluble, evaporable and degradable and C C Many of these organic molecules are considered (PAHs) Sum of 18 PAHs: 10 mg/kg attach themselves to organic particulate matter. PAH T to be carcinogenic, mutagenic and toxic to the Sum of ANA, ANY, ANT, FLU, PHE, FLT, PYR: 10 mg/kg contaminations have been found in rubber and various M M aquatic environment. BaP, BeP, BaA, CHR, BbF, BjF, BkF, DBA, IPY, BPE : 0.5 mg/kg plastics, and as contaminants in black carbon pigments. (each) NAP: 2 mg/kg ICP-OES, GC-MS, UV-VIS, HPLC- EU: REACH Regulation (EC) No 1907/2006 - SVHC DAD, HPLC-MS and colorimetric 0.1% per product, up to one tonne total Candidate List method EU: Commission Regulation (EU) 2015/2030 ● ● ● ● amending Annex I of Regulation (EC) No 850/2004, ISO 18219: 2015 1500mg/kg POPs Test method: SCCPs are used as flame retardants or plasticisers in SCCPs are persistent and toxic in the Short Chain Chloroparaffins ISO 18219: 2015 plastics, rubbers, inks, paints, adhesives and coatings. They VP environment, suspected carcinogens and (SCCP) (C10 - C13) may also be found as impurities in fat-liquoring agents in C I repeated exposure causes skin dryness and Requirement: leather production. T cracking. 1000 mg/kg ICP-OES, GC-MS, UV-VIS, HPLC- EU: REACH Regulation (EC) No 1907/2006 - SVHC DAD, HPLC-MS and colorimetric 0.1% per product, up to one tonne total Candidate List method Test Method: ● Arsenic, Cadmium, Mercury, Lead and Chromium (VI) are (PVC artificial GB 21550 Section 5.4 banned in textile production. Refer to individual leather) descriptions for Cadmium, Lead and Chromium (VI). Refer to individual descriptions for Cadmium, Soluble heavy metal China: GB 21550-2008 GB 21550 Section 5.4 Requirement: Arsenic is found in cotton farming as a preservative, Lead and Chromium (VI). pesticide and defoliant. Mercury is found in pesticides and as a contaminant in Caustic Soda (NaOH). Mercury compounds have been used in paints and surface coatings.
Version: 4 Issue Date: March 2018 Revision Date: January 2019 KEY: RESTRICTED SUBSTANCE LIST FOR ADULT PRODUCTS & PACKAGING C - Carcinogenic CO - Contamination B - Bioaccumulative RSL (Restricted Substance List): The ASOS RSL applies to all fabrics, components, products and packaging. The RSL details the global requirement for restricted substances and respective limits in finished goods. For some high risk materials we require mandatory testing to be submitted per order, this is communicated in our Global Testing ED - Endocrine Disruptor Manual. Increasingly there will be a need to apply chemical tests in production, and more of these may become mandatory in future revisions. Suppliers not already doing so should begin to assess their ability to evidence compliance to the ASOS RSL through testing or through other means. If you become aware that any Product(s) may or do contain any restricted substance(s), please notify ASOS immediately - compliance@asos.com and your retail/technical contact. ● ● ● I - Irritant M - Mutagenic high risk - medium risk - low risk R - Reprotoxic widely used detected S - Sensitisation frequently occasionally T - Toxic MRSL (Manufacturing Restricted Substance List): As ASOS continues to look at environmental impact of hazardous chemicals, it is becoming increasingly important for us to understand conformance on input chemistry. Please ask your upstream suppliers to ensure raw materials, finished components and chemical suppliers are meeting detected VP - Very Persistent the limits set out in the ZDHC MRSL. The ZDHC MRSL can be found at http://www.roadmaptozero.com/fileadmin/pdf/MRSL_v1_1.pdf Applicable Materials Exposure & Hazard ASOS Requirement Environment Legislation Legislative Requirement Plastic, Consumer Test Method for for Finished Products Worker Health Health Substance Standard/Eco-Label for Finished Products Synthetic Natural Synthetic Coating / Paper / Potential Uses Summary Legislation Leather Rubber Metal Glass Comments by Country (maximum allowable limit) materials Fibres Fibres Printing Card (maximum allowable limit) inc. PU,PVC Test method: GB 28480-2012 ● ● ● Arsenic, Cadmium, Mercury, Lead and Chromium (VI) are banned in textile production. Refer to individual Requirement: descriptions for Cadmium, Lead and Chromium (VI). Refer to individual descriptions for Cadmium, China: GB 28480-2012 Arsenic is found in cotton farming as a preservative, Analysis by ICP Lead and Chromium (VI). pesticide and defoliant. Mercury is found in pesticides and as a contaminant in Caustic Soda (NaOH). Mercury compounds have been used in paints and surface coatings. Total Heavy metal ● Requirement: EU: Directive 94/62/EC packaging and packaging Chromium (VI), Mercury, Lead, Cadmium Directive 94/62/EC Chromium (VI), Mercury, Lead, Cadmium (100mg/kg for sum waste (100mg/kg for sum of four heavy metals) of four heavy metals) Test method: ● VCM is highly toxic, flammable, and GB/T 4615 T T carcinogenic. The production of VCM has been Vinyl chloride monomer (VCM) China: GB 21550-2008 GB/T 4615 (PVC artificial VCM is a building block of PVC VP recognised as a source of dioxins, dioxins are Requirement: leather) C C persistent environmental pollutants. ● China: GB 21550-2008 GB 21550 Section 5.5 (PVC artificial leather) Test method: Volatile organic compounds are associated with solvent- GB 21550 Section 5.5 based processes like PU coatings and adhesives. They Volatile substances (other) should not be used in textile chemical preparations or for T VOC's can be harmful to workers health. Requirement: industrial/machine cleaning. EU: Candles and Diffusers BS EN 16739:2015 Testing: Please see the Global Testing Manual for full mandatory testing requirements. Other Legislations Biocidal Products Regulation (BPR, Regulation (EU) 528/2012) https://echa.europa.eu/regulations/biocidal-products-regulation/legislation California Proposition 65 (Prop 65) https://oehha.ca.gov/proposition-65/proposition-65-list CPSIA https://www.cpsc.gov/Regulations-Laws--Standards/Statutes/The-Consumer-Product-Safety-Improvement-Act (The Consumer Product Safety Improvement Act) EU Cosmetics Regulation https://ec.europa.eu/growth/sectors/cosmetics/legislation_en FD&C ACT https://www.fda.gov/RegulatoryInformation/LawsEnforcedbyFDA/FederalFoodDrugandCosmeticActFDCAct/ucm2005640.htm Federal Food, Drug, and Cosmetic Act RoHS http://ec.europa.eu/environment/waste/rohs_eee/index_en.htm (Restriction of Hazardous Substances Directive) SVHC's Imported SVHCs must be declared to ASOS twice yearly. Chemicals are updated on the SVHC list twice a year. The full list can be obtained here: https://echa.europa.eu/candidate-list-table (Substances of Very High Concern) TSCA https://www.epa.gov/laws-regulations/summary-toxic-substances-control-act (Toxic Substances Control Act) ZDHC MRSL http://www.roadmaptozero.com/fileadmin/pdf/MRSL_v1_1.pdf
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