Chemical RSL Regulations for Textiles, Footwear & Bags

In the production and trade of textiles, footwear and bags, the safety control of chemical substances has become a core challenge that enterprises must face. Importers and manufacturers need to exercise control from the source of the supply chain to ensure that products do not contain any prohibited/restricted chemical ingredients that may harm human health or the environment, and at the same time successfully pass strict regulatory reviews in major global markets. This is not only related to compliance, but also directly affects brand reputation and market competitiveness.

Relying on professional technical support personnel and a dedicated team, JJR LAB provides compliance testing services including REACH, cpsia, AFIRM RSL, ZDHC MRSL, etc.

Restricted Substance Testing Services by Regulation

• Consumer Product Safety Improvement Act (CPSIA)

• reach regulation

• REACH Substances of Very High Concern (SVHC)

• Restriction of Hazardous Substances Directive (RoHS)

• EU Toy Safety Directive

• California Proposition 65

• Packaging and Packaging Waste Directive

• Battery Directive

• Health Canada: DEHP and BISphenol A Testing

• Toxic Substances Control Act (TSCA)

• ZDHC MRSL

• Other Restricted Substance Services

• Restricted Substance compliance Assurance Services

• Restricted Substance List (RSL) Services

Market Requirements

U.S. Market Requirements for Children’s Clothing, Footwear & Bags

Definition: Products designed or intended primarily for use by children aged 12 and younger.

Third-party testing: Must be tested by a CPSC-accredited third-party laboratory.

Children’s Product Certificate (CPC): A Children’s Product Certificate must be issued to certify compliance with all applicable children’s product safety rules.

• Lead content limits (CPSIA Section 101, 16 CFR 1303): Lead content in accessible substrates ≤ 100 ppm; lead content in paint/surface coatings ≤ 90 ppm

• Phthalates (CPSIA sect. 108, 16 CFR 1307): Certain plasticized components ≤ 0.1% (mainly applicable to toys and childcare articles; applicable to clothing/footwear with soft plastic parts, commonly including 8 types such as DEHP, DBP, BBP, DINP)

• Small parts (16 CFR 1501, for children under 3 years old)

• Sharp points/edges (16 CFR 1500.48/49, for children under 8 years old)

• Button Battery Safety Act (16 cfr 1263)

• California Proposition 65

• Per- and polyfluoroalkyl substances (PFAS) (state regulations such as AB 1817)

• Permanent tracking label: Shall be permanently affixed to products and packaging (where practicable) with:

￮ Manufacturer/private labeler name; place and date of production; batch/run number or other traceability information

• Children’s Product Certificate (CPC) + test reports: Shall be retained and provided to distributors/retailers upon request

Specific Requirements for Children’s Clothing

Flammability:

• General children’s clothing: Compliant with 16 CFR Part 1610

• Vinyl plastic film clothing: Compliant with 16 CFR 1611

• Children’s sleepwear: Compliant with 16 CFR Part 1615/1616

Drawstring ban for children’s upper garments:

• Drawstrings at the neck/hood are prohibited for upper garments in sizes 2T–12 (16 CFR Part 1120 + ASTM F1816)

• Hem drawstrings must meet specific length/fixation requirements, otherwise they will be regarded as a substantial hazard

Others: Certain children’s garments (e.g., bibs) may be subject to phthalate restrictions.

U.S. Market Requirements for Adult Clothing, Footwear & Bags

General Certificate of Conformity (GCC):

• Manufacturers/importers must issue a GCC on their own, declaring that the product complies with all applicable CPSC rules.

• Mainly applicable to 16 CFR Part 1610 (flammability standard for clothing textiles) and 16 CFR 1611 (vinyl plastic film clothing).

• Footwear and bags generally do not require flammability testing; GCC is issued as appropriate.

• Third-party laboratory testing is not required (unlike children’s products).

• California Proposition 65

• Per- and polyfluoroalkyl substances (PFAS) (state regulations such as AB 1817)

EU Market Requirements for Clothing, Footwear, Bags & Accessories

• Drawstrings and cords | GPSD, EN 14682

• Flame retardant (TRIS or TDBPP) | Tris(2,3-dibromopropyl) phosphate (TRIS or TDBPP) | REACH Annex XVII entry 4

• Flame retardant (TEPA) | Tris(aziridinyl) phosphinoxide (TEPA) | REACH Annex XVII entry 7

• Polybrominated biphenyls | PBB | REACH Annex XVII entry 8

• Organotin | Organotin | REACH Annex XVII entry 20

• Cadmium | Cadmium | REACH Annex XVII entry 23

• Nickel release | Nickel release | REACH Annex XVII entry 27

• Azo dye | Azo dye | REACH Annex XVII entry 43

• Octabromodiphenyl ether | OctaBDE | REACH Annex XVII entry 45

• Nonylphenol ethoxylates | NPEO | REACH Annex XVII entry 46a

• Chromium VI | Chromium VI | REACH Annex XVII entry 47

• Polycyclic aromatic hydrocarbons | PAHs (8 substances) | REACH Annex XVII entry 50, 72

• Phthalates (Note: Textiles, footwear and bags shall consider entry 51 and entry 72 simultaneously) | REACH Annex XVII entry 51, 52, 72

• Dimethyl fumarate | DMFu (Dimethylfumarate) | REACH Annex XVII entry 61

• Lead | Lead | REACH Annex XVII entry 63

• C9-C14 perfluorocarboxylic acids | C9-C14 PFCAs | REACH Annex XVII entry 68

• Perfluorooctanoic acid and its salts | PFOA and its salts | POPs regulation (EU) 2019/1021

• Short-chain chlorinated paraffins | SCCP | POPs regulation (EU) 2019/1021

• Perfluorooctane sulfonates | PFOS | POPs regulation (EU) 2019/1021

• Hexabromocyclododecane (HBCDD) | Hexabromocyclododecane (HBCDD) | POPs regulation (EU) 2019/1021

• Polybrominated diphenyl ethers (Br=4,5,6,7,10) | PBDE (Br=4,5,6,7,10) | POPs regulation (EU) 2019/1021

• Pentachlorophenol (PCP) | Pentachlorophenol (PCP) | POPs regulation (EU) 2019/1021

• Substances of Very High Concern | SVHC (latest SVHC list: https://echa.europa.eu/candidate-list-table) | REACH regulation

• Disperse dye | Disperse dye | Germany LFGB 30

• Extractable heavy metal | Extractable heavy metal | REACH Annex XVII entry 72

• Benzene | Benzene | REACH Annex XVII entry 72

• Chlororganic Carriers | Chlororganic Carriers | REACH Annex XVII entry 72

• Formaldehyde | Formaldehyde | REACH Annex XVII entry 72

• Solvent | Solvent | REACH Annex XVII entry 72

• Dyes | Dyes | REACH Annex XVII entry 72

• Arylamine salt | Arylamine salt | REACH Annex XVII entry 72

• Quinoline | Quinoline | REACH Annex XVII entry 72

• Siloxanes (D4, D5, D6) | D4, D5, D6 | REACH Annex XVII entry 70

• Methoxychlor | Methoxychlor | POPs regulation (EU) 2019/1021

• Perfluorohexanoic acid, its salts and related substances | PFHxA, its salts and PFHxA-related substances | REACH Annex XVII entry 79

• Perfluorohexane-1-sulfonic acid, its salts and related substances | PFHxS, any of its salts and PFHxS-related compounds | POPs regulation (EU) 2023/1608

• 2-[2-Hydroxy-3,5-di(tert-pentyl)phenyl]-2H-benzotriazole | UV-328 | POPs regulation (EU) 2025/843