OEKO-TEX, REACH and ZDHC: chemical compliance for a clothing order

Chemical compliance in clothing rests on three different things that buyers often run together. OEKO-TEX STANDARD 100 is a voluntary certificate for a textile article tested for harmful substances. EU REACH is law: its Annex XVII restricts named substances in articles sold in the EU, whether or not they hold any certificate. ZDHC MRSL is a list of chemicals that factories and chemical suppliers must not use on purpose; it governs the dye house, not the product. A first order needs each of the three in its proper place.

Factories on the Garments Hub BD bench are matched to the certificates a buyer needs, OEKO-TEX among them. The sourcing report checks each factory's certificates against the issuer, and market specific test reports are built into the timeline when you ask for them on the quote form, so the chemical requirement belongs on that form from the start.

What OEKO-TEX STANDARD 100 certifies, and what it does not

OEKO-TEX STANDARD 100, from the OEKO-TEX Association, tests textiles at every stage of processing for harmful substances: yarn, fabric, sewing thread, labels, buttons and the finished article. A certificate covers the articles listed on it, tested against the limits of one product class. It certifies the product, not the factory. It says nothing about working conditions, wastewater or how the dye house manages its chemicals.

A fabric certificate does not let you put the label on a finished garment. For that, the garment maker's own certificate must cover the article, and every component, from thread to snaps, must meet the class. Certificates usually run for a year. Before the order is confirmed, check the certificate number against the issuer's records, and read the scope: the articles, the class and the expiry date.

Which OEKO-TEX product class a garment needs

STANDARD 100 has four product classes, and class I, for baby articles, is the strictest. Choose the class by the most sensitive use of the article. Materials certified to a stricter class may be used in articles of a less strict one, so a class I fabric can go into an adult tee, but not the other way round.

• Class I: articles for babies and toddlers up to three years, such as bodysuits, sleepsuits and cot sheets.
• Class II: articles worn with a large part of their surface against the skin, such as T-shirts, shirts, underwear and trousers.
• Class III: articles with little or no skin contact, such as jackets, coats and fillings.
• Class IV: decoration materials, such as curtains and table linen.

The REACH Annex XVII entries that reach clothing and leather

REACH (Regulation (EC) No 1907/2006) applies to every article placed on the EU market. Annex XVII restricts named substances, and four entries reach clothing and leather goods most often. Each has its own laboratory method; name the entry numbers when you ask for testing, and the laboratory applies the method each entry calls for.

• Entry 27, nickel: release from metal parts in direct and prolonged contact with skin above 0.5 micrograms per square centimetre per week, which covers snaps, rivets, buckles and jeans buttons.
• Entry 43, azo dyes: dyes that release listed amines above 30 mg/kg, a risk to test on dark and bright shades.
• Entry 47, chromium VI: leather articles in contact with skin above 3 mg/kg, which covers leather patches, trims, belts and footwear.
• Entry 72, CMR substances: a list of substances restricted in clothing, textiles that touch the skin and footwear, formaldehyde at 75 mg/kg among them, in force since 1 November 2020.

Using OEKO-TEX and REACH together

The STANDARD 100 criteria cover many of the substances REACH restricts, often at stricter limits, so many buyers accept a current certificate as part of their evidence. It does not replace the legal duty, which rests with the business placing the goods on the EU market. Where a certificate does not cover a part, test that part against the entries that apply: metal trims for nickel, dark dyes for azo amines, leather for chromium VI, and resin finishes and easy care fabrics for formaldehyde.

ZDHC MRSL: a list for the dye house, not a product test

The ZDHC MRSL, from the ZDHC Foundation, is a Manufacturing Restricted Substances List: chemicals banned from intentional use in facilities processing textiles, leather and trims. It is written for factories and chemical suppliers, and no product test can prove that a garment was made in conformance with it. Evidence comes from the facility: its chemical inventory and the conformance of the chemicals it buys. bluesign, from bluesign technologies, is another system for chemical management across the supply chain.

Do not confuse it with a restricted substances list (RSL), which sets limits in the finished product and is checked by testing. Many brands keep their own RSL for products and ask for MRSL conformance at the mill, using one to control the product and the other to control the process.

Writing the chemical requirement into the quote form

A chemical requirement that arrives after the quote changes both price and timeline, because each test is charged by the laboratory and adds days. Put it on the quote form with the tech pack, in terms a factory can price:

• The selling market, and REACH Annex XVII for the EU.
• OEKO-TEX STANDARD 100 with the product class, and whether it must cover the finished article or the fabric only.
• The test reports required by entry, the parts to be tested, and whether on pre-production or bulk materials.
• Your own RSL, if you have one, with its limits and how often it is tested.
• ZDHC MRSL conformance or bluesign at the dye house, where you need a facility requirement.

What to put in your chemical specification

• Market and lawThe selling market, REACH Annex XVII for the EU, and any restricted substances list of your own.
• Certificate and classOEKO-TEX STANDARD 100, the product class from I to IV, covering the finished article.
• Metal partsNickel release under entry 27 for every metal part that touches the skin for long periods.
• DyesAzo amine testing under entry 43, especially on dark and bright shades.
• Leather partsChromium VI under entry 47 for any leather patch, trim, label or belt.
• FinishesFormaldehyde and the other CMR substances under entry 72, on finished fabric with resin or easy care finishes.
• Factory chemicalsZDHC MRSL conformance or bluesign at the dye house, if your brand requires a facility standard.
• VerificationCertificate numbers, scopes and expiry dates checked against the issuer before the order is confirmed.

Questions buyers ask