53 SVHCs of REACH

On 20 June 2011, the European Chemical Agency (ECHA) has recently announced that the 7 new SVHCs from the Consultation List are added to the current Candidate List of 46 SVHCs. The Candidate List now contains 53 SVHCs listed as below.

5-tert-butyl-2,4,6-trinitro-m-xylene (Musk xylene)
CAS. No. 81-15-2
vPvB

Hexabromocyclododecane (HBCDD)
CAS. No. 134237-50-6, 134237-51-7 and 134237-52-8
PBT

Alkanes, C10-13, chloro (Short Chain Chlorinated Paraffins) (SCCP)
CAS. No. 85535-84-8
PBT, vPvB

4,4’-Diaminodiphenylmethane (MDA)
CAS. No. 101-77-9
C, Cat.2

Dibutyl phthalate (DBP)
CAS. No. 84-74-2
R, Cat.2

Bis (2-ethylhexyl) phthalate (DEHP)
CAS. No. 117-81-7
R, Cat.2

Benzyl butyl phthalate (BBP)
CAS. No. 85-68-7
R, Cat.2

Anthracene
CAS. No. 120-12-7
PBT

Cobalt dichloride
CAS. No. 7646-79-9
C, Cat.2

Sodium dichromate
CAS. No. 7789-12-0 and 10588-01-9
C, Cat.2
M, Cat.2
R, Cat.2

Diarsenic pentoxide
CAS. No. 1303-28-2
C, Cat.1

Diarsenic trioxide
CAS. No. 1327-53-3
C, Cat.1

Lead hydrogen arsenate
CAS. No. 7784-40-9
C, Cat.1
R, Cat.1

Triethyl arsenate
CAS. No. 15606-95-8
C, Cat.1

Bis(tributyltin) oxide (TBTO)
CAS. No. 56-35-9
PBT

Anthracene oil
CAS. No. 90640-80-5
PBT, vPvB
C, Cat.2

Anthracene oil, anthracene paste, distn, lights
CAS. No. 91995-17-4
PBT, vPvB
C, Cat.2
M, Cat.2

Anthracene oil, anthracene paste, anthracene fraction
CAS. No. 91995-15-2
PBT, vPvB
C, Cat.2
M, Cat.2

Anthracene oil, anthracene low
CAS. No. 90640-82-7
PBT, vPvB
C, Cat.2
M, Cat.2

Anthracene oil, anthracene paste
CAS. No. 90640-81-6
PBT, vPvB
C, Cat.2
M, Cat.2

Coal tar, pitch, high temp.
CAS. No. 65996-93-2
PBT, vPvB,
C, Cat.2

Diisobutyl phthalate (DIBP)
CAS. No. 84-69-5
R, Cat.2

2,4-Dinitrotoluene
CAS. No. 121-14-2
C, Cat.2

Tris(2-chloroethyl)phosphate
CAS. No. 115-96-8
R, Cat.2

Aluminiosiliate, Refractory Ceramic Fibres
Zirconia Aluminosilicate, Refractory Ceramic Fibres
Index No. 650-017-00-8
C, Cat.2

Lead chromate
CAS. No. 7758-97-6
C, Cat.2
R, Cat.1

Lead chromate molybdate sulphate red (CI Pigment Red 104)
CAS. No. 12656-85-8
C, Cat.2
R, Cat.1

Lead sulfochromate yellow (CI Pigment Yellow 34)
CAS. No. 1344-37-2
C, Cat.2
R, Cat.1

Acrylamide
CAS. No. 79-06-1
C, Cat.2
M, Cat.2

Trichloroethylene
CAS. No. 79-01-6
C, Cat.2

Boric acid
CAS. No. 10043-35-3 and 11113-50-1
R, Cat.2

Disodium tetraborate, anhydrous
CAS. No. 1330-43-4, 12179-04-3 and 1303-96-4
R, Cat.2

Tetraboron disodium heptaoxide, hydrate
CAS. No. 12267-73-1
R, Cat.2

Sodium chromate
CAS. No. 7775-11-3
C, Cat.2
M, Cat.2
R, Cat.2

Potassium chromate
CAS. No. 7789-00-6
C, Cat.2
M, Cat.2

Ammonium dichromate
CAS. No. 7789-09-5
C, Cat.2
M, Cat.2
R, Cat.2

Potassium dichromate
CAS. No. 7778-50-9
C, Cat.2
M, Cat.2
R, Cat.2

Chromium trioxide
CAS. No. 1333-82-0
C, Cat.1
M, Cat.2

Acid generated from chromium trioxide and their oligomers:
Chromic acid
Dichromic acid
Oligomers of chromic acid and dichromic acid
CAS. No. 7738-94-5 and 13530-68-2
C, Cat.2

2-Ethoxyethanol
CAS. No. 110-80-5
R, Cat.2

2-Methoxyethanol
CAS. No. 109-86-4
R, Cat.2

Cobalt (di)acetate
CAS. No. 71-48-7
C, Cat.2
R, Cat.2

Cobalt (II) carbonate
CAS. No. 513-79-1
C, Cat.2
R, Cat.2

Cobalt dinitrate
CAS. No. 10141-05-6
C, Cat.2
R, Cat.2

Cobalt (II) sulphate
CAS. No. 10124-43-3
C, Cat.2
R, Cat.2

2-Ethoxyethyl acetate
CAS. No. 111-15-9
R, Cat.1B

Strontium chromate
CAS. No. 7789-06-2
C, Cat.1B

1,2-Benzenedicarboxylic acid, di-C7-11-branched and linear alkyl esters (DHNUP)
CAS. No. 68515-42-4
R, Cat.1B

Hydrazine
CAS. No. 7803-57-8 and 302-01-2
C, Cat.1B

1-Methyl-2-pyrrolidone
CAS. No. 872-50-4
R, Cat.1B

1,2,3-Trichloropropane
CAS. No. 96-18-4
C, Cat.1B
R, Cat.1B

1,2-Benzenedicarboxylic acid, di-C6-8-branched alkyl esters (DIHP)
CAS. No. 71888-89-6
R, Cat.1B

Please refer to previous posts for REACH details:

What are SVHCs (Part 1)
What is REACH (Part 2)

100ppm of LEAD Now!

On July 13, 2011 the Commission (CPSC) voted (3-2) to accept the CPSC staff recommendation to lower the Lead content limits in substrates to the CPSIA statutory level of 100 parts per million (ppm).

The new total lead content limit, which is called for in the Consumer Product Safety Improvement Act (CPSIA), goes into effect on August 14, 2011 for manufacturers, importers, retailers and distributors of children's products.

Due to a stay of enforcement that is already in place until December 31, 2011, the CPSC will not enforce the CPSIA requirement for independent third party testing for total lead content. The stay of enforcement does not apply to children’s metal jewelry, which currently must undergo independent third party testing.

The rule applies to all materials in children’s products unless otherwise excluded under sections 16 CFR 1500.87 through 1500.91 of the Code of Federal Regulations, which address “inaccessible component parts”, exemptions for “certain electronic devices” and other “certain materials or products”, as well as procedures for requesting exemptions.

The new 100 ppm lead content limit is not applicable to inaccessible (internal) parts of children’s products and certain component parts of children’s electronic devices such as electronic connectors and plugs, including
headphone/earphone plugs.

Lead content levels for children's products are different from the levels Congress set for Lead in paint or surface coatings. The limit for lead in paint or surface coatings is .009 percent. The .009 percent level has been in place since August 14, 2009 and independent third party testing is required for all paints or surfaces coatings used on children's products.

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.”

CPSIA Updates - Tracking Lables for Children's Products

According to 'Consumer Product Improvement Act of 2008’ (CPSIA), Section 103 requires that; all manufacturers of children’s products must place permanent distinguishing marks on the product and its packaging to provide certain identifying information.

This section allows the Commission to require labels to include elements which will allow the manufacturer and the ultimate consumer to as certain:
• Manufacturer or private labeler (source of product)
• Date and place of manufacture
• Batch, run or lot number
• Other identifying characteristics


The permanent tracking label is required for all children’s products (up to age 12) and their packaging which are manufactured on or after August 14, 2009 (1). The aim of Section 103 is to provide for effective traceability of children’s products in the event of a recall and to allow the ultimate consumer to as certain traceable information of the product.


Congress indicated in the requirement that the tracking labels will be required “to the extent practicable”. This recognizes that it might not be practical to have a permanent label or mark on very small items. The tracking label must also be on the packaging of a product.


The new labeling provision requires that the tracking label must appear permanently on the product and any packaging. Therefore, placing the required information on hangtags or adhesive labels is not acceptable.


Therefore, some of the concerns are outlined below:
• Unclear provisions for items such as socks, gloves, small toys, jewelry items, etc where it is not practicable to use a permanent tracking label directly on the item.
• Batch’ number is not clearly defined.
• ‘Permanent’ and ‘permanently attached’ has not been clearly defined.
• Manufacturers need time to develop labels or other methods of marking that work for their individual products and situations once CPSC issue rules for implementing the tracking labels.


On 13 May, 2009, the Consumer Products Safety Commission (CPSC) denied the request for a stay of enforcement of the tracking label under section 103 ofthe CPSIA (3). Therefore, this provision will go into effect for items manufactured on or after August 14, 2009. The CPSC is currently working on guidance for tracking labels.


In general existing laws define a permanent label to be such that that it can not be removed without destroying or defacingthe label, and shall not be affixed to any part which is easily detached from the product and shall be affixed in a readily accessible position. The format and position of the label on the product is determined by the manufacturer.

Composite Test is allowed by CPSC?

Yes, the Consumer Product Safety Commission (CPSC) recently published a Standard Operating Procedure (SOP) for determining Lead content (Pb) in paint and other similar surface coating materials dated on April 26, 2009 . The new method has an option to test different materials in a composite manner. The rules for accreditation for lead in paint for compliance with 16 CFR 1303 remains unchanged and existing accreditations remain valid.

Below are the highlights of the method:

• Wet paints are dried prior to testing,
• For products coated with paint or a similar surface coating, remove and digest the coating,
• Solvents such as methylene chloride (dichloromethane) may be used to soften the paint prior to removal,
• CPSC considers that it is a reasonable practice to composite up to 3 colors and that any sample having greater than 80 % of the limit for lead in paint (72 ppm) in any of the composited paints should be retested.

___________________________________________________________

Lead Content
Regulation: 16 CFR 1303

Scope: (Paint and similar surface coating material)

Requirement:

Max. is 90ppm (Individual Test)

(Refer to prev. blog: http://textilebulletin.blogspot.com/2008/12/new-us-reguation-cpsia-part-2-lead.html)

Max. is 72ppm (3-in-1 Composite Test)

* Less than 72ppm, Pass

* No Conclusion: if result is the range >72ppm and <270ppm

(further individual test must be conducted)

* More than 270ppm, Fail

Limits of DimethylFumarate (DMF) is Fixed Now!

Commission Decision has already published the requirements of Dimethyl Fumarate.

2009/251/EC
Commission Decision of 17 March 2009 requiring Member States to ensure that products containing the biocide Dimethylfumarate are not placed or made available on the market, and it is applied for all products with 0.1mg/kg or less of DMF.

You can refer to my previous posts about DMF.
Ban of Dimethyl Fumarate (DMF)!
DMF - Dimethy formamide OR Dimethy fumarate?
EU Concerns on DMF!

Ban of Dimethyl Fumarate (DMF)!

In 2008, a number of consumers in some countries such as France, Finland, Poland, Sweden and the United Kingdom were exposed to products containing DMF and experienced health problems such as skin itching, irritation, redness, burns and acute respiratory difficulties. An EU wide ban on the use of DMF in all consumer goods is designed to eliminate the chronic health risks and in particular the allergic reactions suffered by some consumers when they are exposed to this substance.

Existing Rules

DMF is already banned for use in the manufacture of goods in the EU, since biocidal products containing DMF are not authorised under the Biocides Directive (98/8/EC). However, manufacturers outside the EU may use these unauthorised biocides and then export their products to the EU.

The Actions

In December 2008, France adopted a decree banning the importation and placing on the market of seating and footwear containing DMF for 1 year. The French Decree also requires the recall of all seating and footwear which visibly contains, or the packaging of which visibly contains, DMF. In January2009, Belgium issued a Decree to ban all articles containing DMF on the market. Spain is considering introducing a measure.

EU

Scope: Consumer Product

Regulation: To be finalized

Belgium

Scope: Articles and Products

Regulation: Minister for Public health and the Minister for Consumer Protection, Ministerial Decree concerning the prohibition of placing articles and products containing DMF on the market

(Belgian Official Journal, 12 January2009)

France

Scope: Seating and Footwear (for 1 year)

Regulation: Ministry for the Economy, Industry and Employment, Decree of 4 December 2008
suspending the placing on the market of seats and footwear containing DMF from the Market
(French Official Journal, Text 17 of 108 , 10 December 2008)

You can refer to my previous posts about DMF.

DMF - Dimethy formamide OR Dimethy fumarate?

EU Concerns on DMF!

Reference:

http://europa.eu/rapid/pressReleasesAction.do?reference=IP/09/190&format=HTML&aged=0&language=EN&guiLanguage=en

PFOS in Textile

PFOS (Perfluoroctane sulfonates) is the substances for surface treatment applications for giving the surface material with repellent properties against water, oil and soil and softer handfeeling. In textile industry, the application likes rainwear, upholstery fabric, curtain material, workwear, bed sheeting...etc.

As PFOS has the properties with water resistance, machanical load, intense heat and stable on the laundering and drycleaning processes. So, PFOS is widely applied in coated fabric in textile market nowadays.

When PFOS applied as a finishing treatment to textile materials, the perfluorocarbon chain tends to be orientated away from the surface, lowering the surface energy of the material, thereby forming a flexible replelling barrier and preventing anything from interacting with the fiber surface.

PFOS are regarded as inert chemicals and biologically inactive. But, PFOS were classified by Scientific Committee on Health and Environmental Risks (SCHER) as very presistent, bio-accumulative and toxic (PBT) chemical compounds. Therefore, new EU Directive 2006/122/EC was issued.

EU Directive 2006/122/EC

Perfluoroctane sulfonates

C8F17SO2X (where X = OH, metal salt, halide amide and other derivatives including polymers)

(1) May not be placed on the market or used as a substance or constituent of preparations in a concentration equal to or higher than 0.005% by mass;

(2) May not be placed on the market in semi-finished products or articles, or parts thereof, if the concentration of PFOS is equal to or higher than 0.1% by mass;

Or, for textiles or other coated materials. If the amount of PFOS is equal to or higher than 1ug/m2 of the coated material.

Remarks
* PFOA is also a related substance of PFOS, which chemical at the heart of this Class Action lawsuit is Ammonium Perfluorooctanoate, commonly referred to as C8, C-8, or APFO.

1-Year Stay of Enforcement for the CPSIA

One Year Stay of Testing and Certification Requirements for Certain Products

The U.S. Consumer Product Safety Commission is already voted to issue a one year stay of enforcement for certain Testing and Certification requirements for manufacturers and importers of regulated products, including products intended for children 12 years old and younger. These requirements are part of the Consumer Product Safety Improvement Act (CPSIA), which added certification and testing requirements for all products subject to CPSC standards or bans.

It means that the commission will not enforce the testing and certification portion of the Act. Manufacturers and importers of children products will not need to test or certify to these new requirements, but will need to meet the lead and phthalates limits, mandatory toy standards and other requirements.

The stay does not apply to:
1. Four requirements for third-party testing and certification of certain children products subject to:
- The ban on lead in paint and other surface coatings;
- The standards for full-size and non full-size cribs and pacifiers;
- The ban on small parts; and
- The limits on lead content of metal components of children jewelry.
2. Certification requirements applicable to ATV.
3. Pre-CPSIA testing and certification requirements; and

4. Pool drain cover requirements of the Virginia Graeme Baker Pool & Spa Safety Act.

Please kindly visit for the stay by CPSC in detail:

http://www.cpsc.gov/cpscpub/prerel/prhtml09/09115.html

22 or 24 Banned Amines Substances of Azo Dyes Regulation?

According to Commission of the European Communities: Directive 2002/61/EC, there are 22 banned amines substances as below.

4-aminodiphenyl/xenylamine/Biphenyl-4-ylamine (CAS no. 92-67-1)
Benzidine (CAS no. 92-87-5)
4-chloro-o-toluidine (CAS no. 95-69-2)
2-naphthylamine (CAS no. 91-59-8)
o-aminoazotoluene/4-o-tolylazo-o-toluidine/4-amino-2’,3-dimethylazobenzene (CAS no. 97-56-3)
2-amino-4-nitrotoluol/5-nitro-o-toluidine (CAS no. 99-55-8)
p-chloranilin/4-chloroaniline (CAS no. 106-47-8)
2,4-diaminoanisole/4-methoxy-m-phenylenediamine (CAS no. 615-05-4)
4,4'-diaminodiphenylmethane/4,4-methylenedianiline (CAS no. 101-77-9)
3,3'-dichlorobenzidine/3,3’dichlorobiphenyl-4,4’-ylenediamine (CAS no. 91-94-1)
3,3'-dimethoxybenzidine/o-dianisidine (CAS no. 119-90-4)
3,3'-dimethybenzidine/4,4’-bi-o-Toluidine (CAS no. 119-93-7)
3,3'-dimethyl-4,4'-diaminodiphenylmethane/4,4’-methylenedi-o-toluidine (CAS no. 838-88-0)
p-cresidin/6-methoxy-m-toluidine (CAS no. 120-71-8)
4,4'-methylene-bis-(2-chloro-aniline)/2,2’-dichloro-4,4’methylenedianiline (CAS no. 101-14-4)
4,4'-oxydianiline (CAS no. 101-80-4)
4,4'-thiodianiline (CAS no. 139-65-1)
o-toluidine/2-aminotoluene (CAS no. 95-53-4)
2,4-toluylenediamine/4-methyl-m-phenylenediamine (CAS no. 95-80-7)
2,4,5-trimethylaniline (CAS no. 137-17-7)
4-aminoazobenzene (CAS no. 60-09-3)
o-anisidine/ 2-methoxyaniline (CAS no. 90-04-0)

For Oeko-tex standard 100, the list is upgraded to 24 banned list. Which the below 2 arylamines substances are addiationally put into the list.

2,4-Xylidine (CAS no. 95-68-1)
2,6-Xylidine (CAS no. 87-62-7)

For more information about Okeo-tex, please kindly visit www.oeko-tex.com.

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".