What is Azo dyes?

Azo Dyes are the major colourants in the textile industry. It allows colours with outstanding colorfastness and wide huge spectrum. However, these dyes may split off aromatic amines and some of them are proven carcinogenic (eg. Benzidine)

* where: (1) Azo dye, (2) Original di-azo-components, (3) Linking component with additional amine.

Regulation / Requirement
According to the directive 2002/61/EC, in textile and leather articles that may come into direct and prolonged contact with human skin or oral cavity, the use of azo colourants, which may release 22 banned listed carcinogenic amines.

Testing Methods
- General Textiles: EN14362-1 (=64 LFGB 82.02-2)
- Polyester: EN14362-2 (=64 LFGB 82.02-4)
- Leather: ISO/TS17234 (=64 LFGB 82.02-3)
- Determination of 4-aminoazobenzene (4-AAB) (=64 LFGB 82.02-9)

Limits
Max. 30ppm (each amine)

* In some cases, some clients may set the requirement to 24 banned listed amines or 20ppm. Please kindly contact your testing service provider for solution.

DMF - Dimethy formamide OR Dimethy fumarate?

There are two different chemical substances but with the same short term name "DMF". It may cause you confused. Here below are the clear information briefly and the differences between them.

Dimethyl fumarate

CAS no. 624-49-7

Appearance: Crystal Solid in Sachel

Application: Anti-mould agent

Harmful effect: Skin Allergenic

Dimethy formamide

CAS no. 68-12-2
Appearance: Liquid

Application: Solvent
Harmful effect: Pespiratory Irritation by VOC effect

You can check the previous post for the detail of Dimethyl fumarate. Or you can check the Material Safety Data Sheet (MSDS) of the above chemical substances from your suppliers.

* If you would like to post your ad on this blog, please feel free to contact me for detail.

16 CFR 1610 Flammability Requirement under CPSIA

According to CPSIA, Wearing Apparel Flammability - 16 CFR 1610 is required for both children's and adult's apparels. But certain products may be exempted from testing requirement subjected to following conditions:

Specific Exceptions -

1. Hats, provided they do not constitute or form part of a covering for the neck, face, or shoulders when worn by individuals;
2. Gloves, provided they are not more than 14 inches in length and are not affixed to or do not form an integral part of another garment;
3. Footwear, provided it does not consist of hosiery in whole or part and is not affixed to or does not form an integral part of another garment;
4. Interlining fabrics, when intended or sold for use as a layer between an outer shell and an inner lining in wearing apparel.

Specific Exemptions -

1. Plain surface fabrics, regardless of fiber content, weighing 2.6 ounces per square yard or more; and:
2. All fabrics, both plain surface and raised-fiber surface textiles, regardless of weight, made entirely from any of the following fibers or entirely from combination of the following fibers: acrylic, modacrylic, nylon, olefin, polyester, wool.

Summary of Test Criteria for Specimen Classification
Plain surface textile fabric
Class 1: Burn time is 3.5 seconds or more, then ACCEPTABLE
Class 2: This class is not applicable to plain surface textile fabrics
Class 3: Burn time is less than 3.5 seconds, then NOT ACCEPTABLE

Raised surface textile fabric
Class 1: (1) Burn time is greater than 7.0 seconds; or (2) Burn time is 0-7 seconds with no base burns (SFBB). Exhibits rapid surface flash only, then ACCEPTABLE.
Class 2: Burn time is 4–7 seconds (inclusive) with base burn (SFBB), then ACCEPTABLE.
Class 3: Burn time is less than 4.0 seconds with base burn (SFBB), then NOT ACCEPTABLE.

Important:
Even though the some fabrics may be exempted from the flammability test, the Certificate of Conformity is still required.

Textile product is related to "Intended to be Released"?

Under REACH, textile products, such as Jackets, T-shirts, footwear, bags, etc are defined as "Article". Which article means an object giving a special shape, surface or design during production that determines its function to a greater degree than does its chemical composition.


According to REACH regulation, article itself is not the right candidate for registration unless SVHC found in article. Moreover two criteria should be fulfilled if registration can be triggered as below condition (c).

Substance in Article, if:
a. Not Intended to be released --> No registration
b. Intended to be released and less than 1 t/a --> No registration
c. Intended to be released and more than 1 t/a --> Registration

The concept "Intended to be released" is crucial for manufacturers or importers to consider whether the textile articles are involved in REACH registration process. "Intended release" is a deliberate action and has "added value" function for the article.

Below two examples of "Intended Release".

1. Chemical substances such as dyestuffs, softerner and some agent are applied in textile production and it will be released after washing & finishing cycles, but it is not "Intended to be released".



2. Some chemicals (eg. Aloe Vera) added on the fabric and it has a value-added function for skin care by this chemcial released from the fabric during wearing. This substance in product is "Intended to be released".

Example of GCC

Here below is an example of General Conformity of Certificate (GCC)

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

General Conformity of Certificate

1. Product Description: ____________________________________

2. Safety Regulation Citations:
( ) Wearing Apparel Flammability (16 CFR 1610)
( ) Flammability Standard for Children's Sleepwear (16 CFR 1615 and 1616)
( ) Small Parts (16 CFR Part 1501 and 1500.50 - 53)
( ) Sharp Points and Edges (16 CFR 1500.48 and 49)
( ) Lead Paint Ban (16 CFR 1303)
( ) Lead in substrate CPSIA Section 101 (Lead in substrate)
( ) Phthalates CPSIA Section 108
( ) Flammability of Carpets and Rugs (16 CFR 1630 and 1631)
( ) Flammability of Mattress Pads (16 CFR 1632)


3. Importer/ Private Labeler’s or Domestic manufacturer’s Information:

Importer/ Private Labeler’s OR Domestic manufacturer’s name: ___________________________________________________
Full address: _____________________
Telephone number: _________________________
Manufacturer’s contact: _______________________________

4. Record Holder’s Information:
Name: __________________________________
Full Address: ____________________________________

Telephone number: _______________________________

5. Date of Manufacture:

Month__________ Year_____________

6. Date of testing:

Date of Third Party testing: _____________________________

TPCA (Third Party Conformity Assessment Body):
Place of TP testing: ____________________________________
TPCA name: __________________________________________
TPCA address: ________________________________________
TPCA telephone number: ________________________________

* The above information are just for reference only and it may be changed subjected to CPSC's updated requirement.

EU Concerns on DMF!

Background of the concerns

Since the beginning of 2008, there have been continuous reports by consumers in Europe suffering from rashes and other symptoms as a result of sitting on sofas and recliners from China. These sofas were found to contain sachets of the anti-moulding agent Dimethyl Furamate (DMF); inserted into such consumer products as an anti-fungal agent (to prevent moulding) during transportation. In some of the products, as much as ten times the usual quantity was placed inside sofas and chairs. Crystals of DMF contained in the sachets were placed between the cover and foam of the sofas, in which this substance is harmful in contact with the skin.

Since then, a popular French distribution chain has found footwear sold in its stores to have been contaminated by the same substance and has had complaints of skin damage as a result. Immediately, the company recalled all stock from the stores and is recalling the affected products from their consumers in an attempt to prevent further instances and to protect their brand image.


What is DMF?

The substance dimethyl fumarate is a white crystalline powder and has many names but can be identified by the CAS number as shown below.
Substance Name: Dimethyl Fumarate (DMF)
Substance CAS No. 624-49-7

The crystals of DMF transformed into toxic gases, particularly when exposed to heat. These gases can then pass through clothes to case the rash. It is harmful in contact with the skin and if in contact with the eyes could result in serious damage. Although, this substance must not be used in products, but there is the potential for it to come in to contact with the skin or the eyes. This is not just limited to upholstered furniture and footwear, it applies to all products where there is a potential for skin contact.

PS.

There is a similar short term with DMF but if different substances as below, that may confused in market.

Dimethyl Fumarate (富馬酸二甲酯)

Substance CAS No. 624-49-7

Dimethyl Formamide ((N.N-二甲基甲酰胺)*

Substance CAS No. 68-12-2

* Will discuss by the another post later for another DMF (Dimethyl Formamide).