California Proposition 65 Settlement (CP65)

Proposition 65 (Called CP65, P65 or Prop 65) is the “Safe Drinking Water and Toxic Enforcement Act of 1986’, a ballot initiative passed overwhelmingly by Californian residents in November 1986.

The Office of Environmental Health Hazard Assessment (OEHHA) administers the Proposition 65 program. OEHHA, which is part of the California Environmental Protection Agency (Cal/EPA), also evaluates all currently available scientific information on substances considered for placement on the Proposition 65 list.

Proposition 65 requires the State to publish a list of chemicals known to cause cancer or birth defects or other reproductive harm. Proposition 65 requires usinesses to provide a "clear and reasonable" warning before knowingly and intentionally exposing anyone to a listed chemical. Over the years, Prop 65 has concluded consent agreements on lead, phthalates and other chemicals on Prop 65 list that were present in a variety of consumer products. In 2009, there were a total of 321 consent agreements with monetary settlement to the tune of $14.6 million. These products have included bibs, key chains, jewelry, cords, bicycles and accessories, aluminum cookware, ceramic ware, glassware, exercise mats, luggage and accessories.

In the first half of 2010, a number of companies have entered into consent agreements under California Proposition 65 (Prop 65) for a variety of consumer products. Some consent agreements have resulted in the establishment of limits for lead, phthalates and 1,4-dioxane as well.

Against Textile and Garment market, Lead is required for some related products (includes Handbags, Purses, Wallets, Footwear* and Belts*) as below requirements by material type:

- Lead in Paint and Surface Coating on accessible components

<= 90ppm (from 1 December 2010)

- Lead in Polyvinyl Chloride PVC (accessible components)

<= 300ppm (from 1 December 2010)

<= 200ppm (from 1 December 2011)

- Lead in Leather / composite leather (assessible components)

<= 600ppm (from 1 December 2010)

<= 300ppm (from 1 December 2011)

- Lead in all other assessible components other than cubic ziconia

<= 300ppm (from 1 December 2010)

* Effective date are extended for 1 year for belts or footwear.

For more details about Prop 65, please browse the below web-sites:
http://ag.ca.gov/prop65/index.php

http://www.oehha.ca.gov/prop65/background/p65plain.html

RSL Released by AAFA (Version 7)

In September 2010, the American Apparel & Footwear Association (AAFA) released the most updated seventh version of their Restricted Substances List (RSL).

For the new version of AAFA, the below new National regulations are included:
- South Korea KC Mark
- Vietnam Temporary Regulation Circular No. 32/2009/TT-BCT
- Oregon SB586
- Eighteenth Regulation on the Amendment of the German Ordinance and Commodities of 3rd August 2010

The major changes from Release 6 to Release 7 as below.
1. Arylamines
- Test method changed to EN ISO 17234-1 for leather

- Add test method GB/T 23344-2009 for confirmation of 4-aminoazobenzene

2. Solvents
- Change limit to 0.1% (mass) by "Each" instead of "Total"
- Add Trichloroethylene CAS#79-01-6 to the list

3. Flame Retardants
- Add SB 596 (Oregon with limit 0.1% by weight for DecaBDE)

4.1 Metal - Restrictions for Textiles
- Addition restriction of Lead content (90ppm) with reference to KC mark
- Specify leachable metals contents (Pb, Cr, Hg, As and Cu) for Chinese regulation FZ/T81014:2008
- Change age from "<24>

4.2 Metal - Restrictions for Leather
- Changed German regulation from "LFGB 30" to "Eighteenth Regulation on the Amendment of the German Ordinance on Commodities of 3rd Auguest 2010
- Test method changed to 64 LFGB 82.02.11 (2008)

4.3 Metal - Restrictions for Surface Coatings and Printing
- Updated Lead restricion (90ppm) with reference to CPSIA
- Test method changed to CPSC-CH-E1003-09
- Added Cadmium content limitation (100ppm) to the list by test method EN1122

5. Formaldehyde
- Updated test method ISO 17226 for formaldehyde in leather
- Removed test method DIN 53315

6. Phthalates
- Added test method CPSC-CH-C1001-09

Germany Bans Chromium (VI) in Leather Products

Chromium (VI) is a chromium species in the oxidation state +6, which is carcinogenic, mutagenic and toxic for reproduction. It is a hazardous substance also can cause skin irritation if contacted with skin. In the past chromium (VI) containing salts of chromic acid have been used for leather tanning leaving some residue in the leather. Most leathers are still tanned by using chromium salts but chromium (VI) has been replaced by safer alternatives, e.g. by using chromium (III) salts for tanning. Due to a potential conversion process of chromium (III) to chromium (VI) this is still occasionally found in consumer products.

European Union Regulation (REACH Annex XVII) restricts chromium (VI) substances but, this is currently limited to non-consumer products. In order to strengthen consumer protection there has been an initiative by Germany to cover consumer products made from leather as well, and Cr 6 already banned by German Consumer Goods Ordinance (18 BedGgstVÄndV).

Substances: Chromium (VI)

Scope: Leather materials in consumer products with body contact
e.g. Toys, Clothing, Watch straps, Leather Furnishure, Bags and etc.

Test method: § 64 LFGB 82.02-11 B

Requirement: ≤ 3 mg/kg

Effective date: 14 August 2010

RSL Released by AAFA

In March 2010, the American Apparel & Footwear Association (AAFA) released the sixth version of their Restricted Substances List (RSL).

The Restricted Substances List (RSL) was created by a special working group of the American Apparel & Footwear Association’s (AAFA) Environment Task Force and will be updated on a regular basis. Chemicals appearing in the AAFA RSL are those specifically related to both apparel and home textiles as well as footwear and that are banned or restricted by a regulation or law. The country laws with the strictest requirement are cited in the RSL.

Chemicals parameters covered in the latest AAFA RSL Release 6:
• Azo dyes
• Disperse dyes
• Navy blue
• Solvents
• Pesticides
• Dioxins and furans
• Asbestos
• Fluorinated greenhouse gases
• Flame retardants
• Heavy metals

(Cadmium/Lead/Chromium/Chromium Vl/Nickel/Arsenic/Mercury/Copper)
• Organotins (TBT/ TPhT/ DBT/ DOT)
• PFOS
• Formaldehyde
• Phthalates (DEHP/ DNOP/ BBP/ DBP / DINP / DIDP)
• Nonyl Phenol/Nonyl
• Henolethoxylates
• Dimethyl Fumarate

You can browse AAFA official web-site for more details

Sources of the RSL information:

http://www.apparelandfootwear.org/UserFiles/File/Restricted%20Substance%20List/AAFARSLFinalRelease6.pdf

Definition of Children's Products under CPSIA

Several CPSIA provisions use the term ‘children’s product’ and it has been defined as "a consumer product designed or intended primarily for children 12 years of age or younger." For this term, several factors are required to be considered when making a determination as to whether a product is "designed or intended primarily for children 12 years of age or younger."

These factors include:
• A statement by the manufacturer describing the intended use of the product, including a label on such product if such statement is reasonable;
• Whether the product is represented in its packaging, display, promotion, or advertising as appropriate for use by children 12 years of age or younger;
• Whether the product is commonly recognized by consumers as being intended for use by a child 12 years of age or younger; and

• The Age Determination Guidelines issued by the Commission staff in September 2002 and any successor to such guidelines.

The new definitions as stated below are presented in the proposed interpretative rule.
"Children's Product” : a consumer product designed or intended primarily for children 12 years of age or younger. The term "designed or intended primarily" applies to those products designed and commonly recognized as intended for use by a population of consumers constituted by a significant proportion of children 12 years old or younger. Products intended for use by children 12 years or younger applies to those products children will physically interact with based on the reasonably foreseeable use and misuse of such products.

"General Use Product" : A consumer product that is not being marketed to or advertised as being primarily intended for use by children 12 years old or younger and that is used by a significant proportion of the population older than 12 years of age.

The information is clearly designed to provide detailed guidance to manufacturers on how to evaluate their consumer products as they attempt to determine whether those products are children's products.

Melamine is a Textile Fiber?

Answer is Yes.

Additional textile fibre name to be added to the list allowed under 2008/121/EC – 2 new Directives and a Proposed Regulation.

Melamine fiber is defined as:
Fibre formed of at least 85% by mass of cross-linked macromolecules made up of
melamine derivatives.

The European Commission has added this new textile fibre name to the list of 47 permitted generic names that may be used in textile product labelling.

• Commission Directive 2009/121/EC of 14 September, 2009, adds the name “Melamine” to the list as item 48 in Annex I and V of the Directive 2008/121/EC.
• A second new Directive 2009/122/EC (14 September, 2009) amends Chapter II of Annex 2 of Directive 96/73/EC to show a new test method (Method 16) for the separation of melamine fibres from cotton and aramid fibres using hot formic acid.

Member states shall bring in to force the laws, regulations and administrative provisions necessary to comply with this directive by 15 September, 2010.

"Bamboo" fabric is just "Rayon"?

Four US sellers of clothing and other textiles products have been charged by the FTC for claiming bamboo fiberc ontent on products manufactured from rayon. The complaints also charge the companies with making false and unsubstantiated “green” claims that the products are manufactured using environment friendly methods, they retain the natural antimicrobial properties of bamboo and that they are biodegradable.

According to the FTC, the companies falsely claimed that their textile productswere "100 % bamboo fiber" when they were essentially rayon. Noted from the Commission (FTC), Rayon is a man-made fiber created from the cellulose found in plants and trees and processed with a harsh chemical thatreleases hazardous air pollutants. Any plant or tree could be used as the cellulose source, including bamboo, so once the cellulose undergoes the regenerating process (rayon or viscose processes) the generic fiber name wouldbe Rayon. According to the Rules and Regulations under the Textile Fiber Products Identification Act 16 CFR 303.7, the definition of Rayon is:

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
A manufactured fiber composed of regenerated cellulose, as well as manufactured fibers composed of regenerated cellulose in which substituents have replaced not more than 15% of the hydrogens of the hydroxyl groups. Where the fiber is composed of cellulose precipitated from an organic solution in which no substitution of the hydroxyl groups takes place andno chemical intermediates are formed, the term lyocell may be used as a generic description of the fiber.
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Therefore, unless a product is made directly with bamboo fiber — often called “mechanically processed bamboo” — it can’t be called bamboo. If your product isn’t made directly of bamboo fiber — but is a manufactured fiber for which bamboo was the plant source — it should be labeled and advertised using the proper generic name for the fiber, such as rayon, or “Rayon made from Bamboo.”