REACH and restrictions related to harmful substances

Transcription

1 REACH and restrictions related to harmful substances REACH stands for the Regulation for Registration, Evaluation, Authorization and Restriction of Chemicals. The REACH Regulation entered into force on 1st June 2007 to streamline and improve the former legislative framework for chemicals of the European Union (EU). In practice this means all manufacturers and importers of chemicals have the responsibility to identify and manage the risks that substances manufactured, marketed and imported to the EU may pose to human health and the environment. Due to REACH legislation, for Kwintet being Kwintet AB, any parent company, sister company, subsidiaries and affiliates of any such company and subsidiary it is of critical importance to make sure that none of the materials used in our products violates REACH legislation or contains residues of substances that might be harmful to the customer under any circumstances. Kwintet is also openly committed to ensuring that we as far as technically possible avoid materials that contain substances with known negative consequences for the natural environment. The specifications on the chemical content in textiles, e.g. fabrics, garments, leather products e.g. gloves, and shoes comprise a part of our company s buying terms. The same applies for the specific requirements regarding content of hazardous chemicals in packaging materials. It is the responsibility of the supplier to inform subcontractors, dyeing and finishing mills and other parties involved in the production process, of these terms. The values specified in the Kwintet Restricted Substances List (RSL) should be considered as a maximum and may never be exceeded. Goods containing harmful substances exceeding the maximum values specified in this document are deemed to be defective. They thereby fail to fulfill the requirements in our buying terms, and we therefore reserve the right to cancel the orders in question, demand damages, or take other action in accordance with the Kwintet general terms of purchase. Kwintet, as the buyer, reserve the right to conduct inspections and tests on ordered lots at any time and at any stage of production. Kwintet also retains the right to require the supplier to perform specific tests for specific orders, on the suppliers own expense, to ensure that the requirements are being complied with. Kwintet requires that the supplier shall sign the certificate of compliance with Kwintet s Restricted substances list (RSL). By signing the certificate of compliance, the supplier agrees that they will be held liable for all losses and damages suffered by any entity in the Kwintet group in case harmful substances, as stipulated in the RSL are being found in any of the materials, components or products with actual values above the mentioned maximum value which are set forth in this document effective from the date of the signature. Further, the supplier acknowledge that it is a material breach of contract in case a harmful substances, as stipulated in the RSL are being found in any of the materials, components or products with actual values above the mentioned maximum value which are set forth in this document effective from the date of the signature. This material breach of contract gives Kwintet the right to terminate all contracts with the supplier immediately and without any notice. Furthermore, Kwintet requires that all textile and leather products delivered by the supplier, at least shall meet the criteria listed in the Öko-Tex 100 standard. However we do not always require that the product shall be certified according to the Öko-Tex 100 standard. In such cases where Kwintet require that the whole product or components of the product shall be certified according to Öko-Tex Standard 100, Kwintet will communicate this specifically to the supplier and this requirement will be included in the order contract. Page 1/17

2 The Kwintet Restricted Substances List (RSL) All textile & leather products, including accessories, shall at least meet the criteria specified in the Oeko-Tex Standard 100. In addition to the restrictions listed in the Oeko-Tex Standard 100, all products must be in compliance with the restrictions listed in the table below. Limit values for the product related chemicals in this table overrule the limit values of the Oeko-Tex Standard 100. SUBSTANCE NAME STANDARD TEST METHOD INSTRUMENTAL METHOLOGY REQUIREMENTS COMMENTS PROCESS CHEMICALS 1 Chromium VI (Cr + 6) 2 Chromium VI (Cr+6): ISO for leather. 3 mg/kg. available for textiles. Test equipment: UV- VIS Spectrometer used in processes or be products Legal background: Legal limit is 0.1% by weight, Annex XVII of Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH). Chromium (VI) compounds listed on the Candidate list of Substances of Very High Concern (SVHC) for the authorization of the Regulation (EC) 1907/2006 of the European Parliament of the Council (REACH) are listed in Appendix 5. Use: Tanning with basic chromium salts is the most widely used method where chromium VI (6 +) may occur as an impurity. Etching of artificial leather and rubber. Alternatives: Use direct dyes or acid dyes with high colour fastness to avoid use of chromium salts for dyeing of polyamide, silk, wool and leather. Use hydrogen peroxide and other persalts to avoid the use of chromium VI (6 +) based salts. Vegetable tanning agents are alternatives for leather. Alkylphenol ethoxylates (APEO and derivatives) The most common APEOs are nylphenol ethoxylates (NPEO) and Octylphenol ethoxylates (OPEO). LC-MS LC-DAD used in processes. Occurence in products below 100 mg/kg (0,01 %) textile for total APEO is regarded as unintended residues which cannot be controlled. Legal background: Annex XVII of Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH) states less than 0.1% by weight for nonylphenol ethoxylate as a substance or constituent of preparations (closed systems exempted) 4-nylphenol, branched and linear is listed on the Candidate List of Substances of Very High Concern for authorization of the Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH). Characteristics: Irritating to skin. The metabolites affect the respiratory system, have endocrine disruptive effect (hormones) and are dangerous 1 Used in the manufacturing process of textile and leather goods but have no function in finished Remains of process chemicals may, however, be found in the finished product and cause health and/or environmental problems. 2 Sodium dichromate, sodium chromate, potassium chromate, ammonium dichromate and potassium dichromate are listed on the Candidate list of Substances of Very High Concern (SVHC) for the authorization of the Regulation (EC) 1907/2006 of the European Parliament of the Council (REACH). Please see p in this document. Page 2/17

3 for the environment. nylphenol ethoxylates are rapidly degraded to 4-nonylphenol, which is even more dangerous for the environment. A similar environmental danger is the degradation of octylphenol ethoxylate into 4-octylphenol. Use: Dispersing and emulsifying agents in textile chemicals as well as impregnation agents in printing pastes. Occurs in leather lubricants. Manufacturing of coatings. Aromatic organic solvents standardised 0.1 mg/kg GC-MS products Alternatives: The main alternatives for NPEs also include alcohol ethoxylates, both linear and branched, and glucose-based carbohydrate derivatives such as alkylpolyglucoside, glucamides, and glucamine oxides. Legal background: Manufacturers are required to follow the VOC Directive, 1999/13/EC. Characteristics: Liquids or gases. Inhalation can affect the nervous system and cause headache, fatigue and nausea. Cause irritation on skin, eyes and mucous membranes. Kerosene and diesel odour in finished Some aromatic organic compounds are carcinogenic. Use: Solvents for dyeing and printing textile and leather; stain removal, coatings and binders. Comments: Aromatic organic solvents are volatile organic compounds (VOC). Use solvents of higher quality with lower levels of aromatic hydrocarbons or synthetic thickeners based on polycarboxylic acids. Alternatives: Replace simple aromatic hydrocarbons (petrol) with low molecular-weight aliphatic hydrocarbons. To avoid problems with organic solvents, switching to water-based dyeing and printing processes is recommended. There are statutory hygienic limit values for employees in many countries. Aliphatic organic solvents SNV , screening method. Panel odour test. Limit value: odour Legal background: Manufacturers are required to follow the VOC Directive, 1999/13/EC. Properties: Liquids or gases. Inhalation can affect the nervous system and cause headache, fatigue and nausea. Cause irritation on skin, eyes and mucous membranes. Use: Solvents for dyeing and printing. Solvents that have been used for cleaning of spinning oils from textiles are often found in amounts of mg/kg. The limit for humans to sense a smell lies around 100 mg/kg for most substances. Comments: Aliphatic organic solvents are volatile organic compounds (VOC). There are statutory hygienic limit values for employees in many countries. Page 3/17

4 Chlorinated organic solvents available There is no standard detection limit as yet. For GC- MS 0.1 mg/kg. GC-MS; GC-ECD May not be used in processes or be Legal background: Legal limit: 0.1% by weight for 8 specified chlorinated solvents: - Chloroform CAS Carbon tetrachloridetetrachloromethane CAS ,1,2 Trichloroethane CAS ,1,2,2 Tetrachloroethane CAS ,1,1,2 Tetrachloroethane CAS Pentachloroethane CAS ,1 Dichloroethylene CAS ,1,1 Trichloroethane, methyl chloroform CAS These are listed in Annex XVII of Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH). Trichloroethylene, CAS and and 1,2,3-trichloropropane, CAS are listed on the Candidate List of Substances of Very High Concern for authorization of the Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH). See p.12 in this document. Characteristics: Liquid or gas. Affect the nervous system. Irritating to skin and mucous membranes. Many chlorinated organic solvents are dangerous for the environment. Use: Solvent used in the manufacture of rubber, metal paint and fur industry used for grease and oil, e.g. in stain removers. Also used in cleaning agents and detergents. Solvents in lubricating oils. Solvents in dyeing of synthetic fibres (carriers). Solvents in printing for textile and leather. Finishing agents. Fabric softeners. Also used as moth-proofing agent in textiles and for the manufacture of silk and pearls. See also under heading Flame retardants. Comments: Alternatives: water-based emulsions. Alternative products are available or under development for all uses. Carriers do not need to be used for dyeing in high-pressure machinery. Categories of carriers not recommended to be used: Chloronaphthalenes, which are toxic and cause liver damage, chlorobenzenes and chlorotoluenes, which are toxic and can cause liver and kidney damage and irritate eyes and airways. Other organic solvents DMFa (N,Ndimethylformamide) CAS RN: available for textiles. GC-MS There is no standard detection limit as yet. For GC-MS 1 mg/kg can be expected. used in processes or Alternatives: Water-based emulsions. Alternative products are available or under development for all uses. Carriers do not need to be used for dyeing in high pressure machinery. Legal background: Candidate list of Substances of Very High Concern (SVHC) for the authorization of the Regulation (EC) 1907/2006 of the European Parliament of the Council (REACH). Characteristics: Toxic to reproduction. Use: Used as solvent and in production of leather imitation. An intermediate for paper finishing. Page 4/17

5 DMAC CAS RN: N, N- dimethylacetamide (DMAC): Hydrazine CAS RN standardised available for textiles. available for textiles. There is no standard detection limit as yet. GC-MS, LC-MS There is no standard detection limit as yet. For LC-MS 1 mg/kg can be expected. UV-VIS Spectrometer May not be used in processes or May not be used in processes or Legal background: Candidate list of Substances of Very High Concern (SVHC) for the authorization of the Regulation (EC) 1907/2006 of the European Parliament of the Council (REACH). Characteristics: Toxic to reproduction, irritating. Use: Used as solvent and in industrial coatings, polyimide films, paint strippers and ink removers Legal Bsckground: Candidate list of Substances of Very High Concern (SVHC) for the authorization of the Regulation (EC) 1907/2006 of the European Parliament of the Council (REACH). Characteristics: Carcinogenic, allergenic, toxic. Use: Mainly used as a foaming agent in preparing polymer foams NMP CAS RN: N-methyl- 2-pyrrolidone (NMP): Tin organic compounds See list of DBT s in Appendix 4 available for textiles. There is no standard detection limit as yet. For LC-MS 1 mg/kg can be expected. for textile available mg/kg. DIN EN ISO17353 (water and sediment). GC-MS, LC-MS GC-MS. May not be used in processes or May not be present in Legal background: Candidate list of Substances of Very High Concern (SVHC) forthe authorization of the Regulation (EC) 1907/2006 of the European Parliament of the Council (REACH). Characteristics: Toxic to reproduction, irritating. Use: Good solvency properties for polymers. Surface treatment of textiles, resins and metal coated plastics or as a paint stripper. Intermediates for textile auxiliaries, plasticizers, stabilizers and specialty inks. Polyamide precursor. SBR (styrene-butadiene) latex production. Legal background: Legal Limit: 0.1% by weight Dioctyltin (DOT), dibutyltin (DBT) compounds and trisubstituted organostannic compounds such as tributyltin (TBT) are listed in annex XVII of the Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH). Tributyltin oxide (TBTO), , and dibutyltin dichloride (DBTC), are listed on the Candidate List of Substances of Very High Concern for authorization of the Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH) Characteristics: Tributyltin, dibutyltin and dioctyltin compounds are different chemical substances that are toxic and dangerous for the environment. Bioaccumulative and persistent. Use: Dibutyltin compounds (DBT) and dioctyltin compounds (DOT) are used in consumer products as stabilizers (mainly PVC) or catalysts. (PU and PVC). Organotin catalysts are used in a wide variety of polyurethane applications, aiding formation of the urethane bond and generally functioning as Lewis acid catalysts. Comments: Alternative stabilizers are barium/zinc, Page 5/17

6 potassium/zinc, calcium, or calcium/zinc organic stabilizersor methyltin stabilisers. Alternative catalysts can be organotitanate or zirconate compounds (e.g. titanium 2- ethylhexanoate) or amines such as bis- (dimethylaminoethyl) ether (BDMAEE) and triethylenediamine (TEDA) along with organometallic compounds such as potassium acetate. Dialkyl tin compounds represents a large family of substances that consist of the common constituents listed in appendix 4. PRODUCT RELATED (PROPERTY-LENDING) CHEMICALS Allergenic disperse dyes - 19 dyes listed in Appendix 1 Banned arylamines derived from azo dyes - 24 substances listed in Appendix 2 DIN NMP-512 (disperse dyes) DIN (qualitative) EN , - 3 for textile; ISO/TS for leather textiles or leather imitation. Kwintet policy limit: products Characteristics: Highly allergenic (strong sensitizers) Use: Dyeing of textile and leather imitation goods Alternatives: use other dyes that do not cause allergies Legal background: Legal limit is 30 mg/kg (per each of the arylamine breakdown products). Annex XVII of Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH). Several arylamines are listed on the Candidate List of Substances of Very High Concern for authorization of the Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH). Characteristics: Carcinogenic. Some are allergenic. Arylamines can form part of the molecular structure of a dye. Certain azo dyes can form the 24 listed banned arylamines. Use: Dyeing, printing; consistuent of dyes, mainly disperse dyes. Dyes that can release any of the 24 aromatic amines (see Appendix 2) may not be used. This regulation applies to azo colorants which both apply to azo dye stuffs and azo pigments. CMR, Carcinogenic, Mutagenic, Reproductive toxic dyestuffs - 15 substances listed in Appendix 3 standard EN ISO for azo colorants in leather. 20 mg/kg Extractable dyestuffs will be tested by the coming EN ISO products Legal background: C.I. Solvent Blue 4, C.I. Basic Blue 26, C.I. Basic Violet 3, Michler s base (CAS ) and 4,4'-bis(dimethylamino)- 4''-(methylamino)trityl alcohol (CAS ) are listed on the Candidate List of Substances of Very High Concern for authorization of the Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH) Restrictions for use of substances, harmonized classified as CMR according to CLP, as substances, as constituents of other substances or in mixtures. These are found in REACH annex XVII, entry Restrictions for use of substances in articles are expected within the EU for all CMR substances. Characteristics: Carcinogenic, mutagenic, reproductive toxic. Dyestuffs that are classified as carcinogens, mutagenic, reproductive toxic according to CLP including class 2 (only 1A and 1B are CMR). Page 6/17

7 Use: Dyeing of textile and leather goods Alternatives: Use other dyestuffs than the substances listed in Appendix 3. Cadmium (Cd) and cadmium salts CAS RN: Cadmium (metal): standardised 1) XRF 2) AAS 3) ICP-MS and ICP-OES 1) 50 mg/kg. 2) 100 μg/kg. 3) 1 μg/kg Occurrence in materials below 0.5 mg/kg is regarded as contaminations which cannot be controlled. Legal background: Legal limit: 0.01 % by weight (100 mg/kg). Annex XVII of Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH). The sum of concentration levels of lead, cadmium, mercury and hexavalent chromium packaging or packaging components shall not exceed 100 ppm by weight Directive (EC) 94/62/EC of 20 December 1994 on packaging and packaging waste. Characteristics: Heavy metal that occurs naturally in small quantities in nature. Toxic to aquatic organisms. n-biodegradable. Dangerous for the environment. Can cause kidney damage. Use in textile and leather: Can occur in pigmented plastisol prints. Use in accessories and packaging: Surface treatment. Pigment in colouring agent. Also in plastics as stabilizers and pigment. Cadmium based stabilizers are used to increase the endurance of the material. For recycled packaging cadmium may have had a different original use. Alternatives: Alternatives are available, such as calcium-zinc based stabilizers. Order cadmiumfree processes and materials. Boric acid, borate compounds CAS RN: Boric acid; and Disodium tetraborate anhydrous; and Tetraboron disodium heptaoxid, hydrate; Lead (Pb) and lead salts CAS RN: Lead (metal): SVHC lead compounds are listed in Appendix 6. Detection limit: 1) 1000 μg/kg as Boron. 2) 100 μg/kg as Boron standard 1) AAS. 2) ICP- MS and ICP-OES 1) XRF 2) AAS 3) ICP-MS and ICP-OES 1) 50 mg/kg. 2) 100 μg/kg. 3) 1 μg/kg products < 100 mg/kg for lead as a metal in plastic and metallic accessories Legal background: 0.1 % by weight. Boric acid, disodium tetraborate anhydrous and tetraboron disodium heptaoxid, hydrate are listed on the Candidate List of Substances of Very High Concern for authorization of the Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH) Characteristics: Toxic. May impair fertility and cause harm to unborn child. Use: Wood veneers/pressed wooden panels and boards. Boric acid may be used as flame retardant in wood and biocidal agent in boards. Legal background: Annex XVII of Regulation (EC) no. 1907/2006 of European Parliament and of the Council (REACH) Lead salts are listed on the Candidate List of Substances of Very High Concern for authorization of the Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH). The sum of concentration levels of lead, cadmium, mercury and hexavalent chromium packaging or packaging components shall not exceed 100 ppm by weight Directive (EC) 94/62/EC of 20 December 1994 on packaging and packaging waste. Lead salts are restricted in paint products (no Page 7/17

8 restriction on painted articles) within the EU. Lead as metal is under considerations for regulation within EU, and is already restricted in Denmark. Danish legal limits: 100 mg/kg. (Bekendgørelse nr. 856 af 5. September 2009 om forbud mod import og salg af produkter, der indeholder bly). The Danish Statutory Order no prohibits import and marketing of products in which lead represents more than 100 ppm (mg/kg) of their homogeneous components. However, this limit value does not apply to lead carbonates and lead sulphates in paint, or when lead content in products is regulated by other legislation, e.g. RoHS. Characteristics: Lead exposure can give rise to a number of negative health effects, including damage to liver, nervous system and fetuses. Lead is mainly accumulated in bone tissue. It has a very long half-life. Use of lead in plastics has not been deemed to cause any significant environmental or health effects in the short term, but in the long term such use increases lead concentrations in the environment. Use: Lead salts are additives in plastics. Lead based stabilizers to increase the service of life of the material. Alternatives: Alternative stabilizers are barium/zinc, potassium/zinc, calcium, calcium/zinc organic or methyltin stabilisers. Alternative catalysts can be organotitanate or zirconate compounds (e.g. titanium 2-ethylhexanoate) or amines such as bis- (dimethylaminoethyl) ether (BDMAEE) and triethylenediamine (TEDA) along with organometallic compounds such as potassium acetate. Nickel (Ni), in accessories CAS RN: Nickel (metal): EN and EN ,5 μg per cm² and week for products intended to come into direct and prolonged contact with the skin. Legal background: Annex XVII of Regulation (EC) no. 1907/2006 of European Parliament and of the Council (REACH) Characteristics: Nickel is one of the most common substances that cause contact dermatitis. Highly allergenic (strong sensitizer). Use: Nickel is often used to improve alloys used in clothing accessories such as zippers, buttons and rivets. Mercury CAS RN: Mercury (metal): Detection limit: 1) 50 mg/kg. 2) 100 μg/kg. 3) 10 μg/kg 1) XRF. 2) AAS. 3) ICP-MS and ICP-OES Comments: Refrain from using nickel-treated metals or nickel-containing metal coatings. Legal background: The sum of concentration levels of lead, cadmium, mercury and hexavalent chromium packaging or packaging components shall not exceed 100 ppm by weight Directive (EC) 94/62/EC of 20 December 1994 on packaging and packaging waste. Mercury and its compounds are listed in the Rotterdam convention Characteristics: Heavy metal that occurs naturally in small quantities in nature. Toxic to aquatic organisms and non-biodegradable. Dangerous for Page 8/17

9 the environment. Can cause kidney damage. Polybrominated biphenyls (PBB) and Polybrominated diphenyl ethers (PBDE) CAS RN: Polybrominated biphenyls (mix) Penta bromo diphenyl ether: Octa bromo diphenyl ether: Deca bromo diphenyl ether: Detection limit: There is no standard detection limit as yet. For LC-MS 1 mg/kg can be expected. GC-MS, LC-MS, GC-ECD Use: For recycled packaging mercury may have had a different original use as e.g. pesticide in wood. Legal background: 0.1% by weight for Polybrominated diphenylethers (PBDEs) (penta-, octa- and deca brominated diphenylethers) and Polybrominated biphenyls (PBBs). Commercial Pentabromo diphenylether is listed in Stockholm Convention on Persistent Organic Pollutants (POPs) and banned by Regulation (EC) 850/2004 (EU regulation implementing Stockholm Convention). Commercial Octabromo diphenylether is banned in Annex XVII of Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH). Octabromodiphenylether is suggested as a POP according to the Stockholm Convention. Deca bromo diphenyl ether, , is listed on the Candidate List of Substances of Very High Concern for authorization of the Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH). Decabromo diphenylether is banned in all products in rway since 2008, legal limit 0,1 % by weight. PBBs are listed in the Rotterdam Convention. Chlorinated phosphate esters are, together with several other halogenated flame retardants, under scientific review in several countries and regions worldwide. Characteristics: Persistant, bioaccumulative and toxic. Halogenated organic additives in polymers may leach out and have a negative impact on health and environment. Halogen containing polymers may form highly corrosive substances and undefined range of halogenated substances that may be PBT or CMR when incinerated. Use: Flame-retardant treatment of products where fire protection is required. Comments: Replace bromoorganic chemical flame retardants with phosphorus- and/or nitrogen-based organic chemical flame retardants or non chemical barrier technologies such as blends of natural and synthetic fibers used in furniture and mattresses and high performance synthetic materials used in firefighter uniforms and other protective clothing. Textile goods for private use are basically never flame retardant-treated. The only case when textile goods are treated with flame retardant is if the end customer orders this property. Usually it is done to satisfy regulatory requirements on fire protection. Page 9/17

10 Halogenated flame retardants 1 CAS RN: Short chain chloro paraffins (C10 C13): Penta bromo diphenyl ether: Octa bromo diphenyl ether: Deca bromo diphenyl ether: Hexabromocyclodode cane: , Tris(2- chlorethyl)phosphate (TCEP): standard GC-MS; LC-MS Kwintet policy limit: Legal background: 0.1% by weight (penta- and octa- brominated diphenyl ether) Polybrominated biphenyls (PBBs) are banned, Annex XVII of Regulation (EC) no. 1907/2006 of European Parliament and of the Council (REACH) Hexabromocyclododecane (HBCD) and all major isomers, short chain chloroparaffins (C10 C13) and Tris(2-chlorethyl)phosphate (TCEP) are listed on the Candidate List of Substances of Very High Concern for authorization of the Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH) see more on page 8-9 in this document. Characteristics: Persistent, bio-accumulative and toxic. Use: Flame-retardant treatment of products where fire protection is required. Textile goods for private use are never flameretardant-treated as practice. Textile goods are only treated with flame retardant if the end customer orders this property. Usually it is done to satisfy regulatory requirements on fire protection. Alternatives: Replace chloro-organic and bromoorganic chemical flame retardants with phosphorus- and/or nitrogen-based organic chemical flame retardants or non chemical barrier technologies such as boric acid-treated cotton materials used in mattresses, blends of natural and synthetic fibers used in furniture and mattresses (VISIL, Basofil, Polybenzimidazole, KEVLAR, NOMEX and fiberglass); and high performance synthetic materials used in firefighter uniforms and other protective clothing. Formaldehyde CAS RN: EN ISO (textiles); ISO (leather) < 75 mg/kg for all textiles and leather goods that comes into direct contact with the skin during normal use. < 300 mg/kg for all other textiles and leather goods. Legal background: Several national legislations, see Appendix 7 Characteristics: Volatile colorless gas. Occurs naturally in small quantities in the atmosphere and in nature. Formaldehyde is a human carcinogen that also can cause skin irritation and allergy. Use: Shrinkage-resistant treatment. Wrinkleresistant treatment. Dirt-repellent treatment. Dye fixing agent. Preservative. Due to its volatility, formaldehyde is contagious. If a garment containing formaldehyde is placed on top of a garment without formaldehyde, the latter garment will be infected. Fabric samples for testing must be packed in air dense plastic bags (polyethylene, PE, or polypropylene, PP). Alternatives: Use products without formaldehyde or with very low concentrations of formaldehyde. 1 Halogenated flame retardant is a collective name for brominated and chlorinated flame retardants. Page 10/17

11 Perfluorooctane sulfonate (PFOS) and related substances 1 CAS RN: EN/TS 15968:2009 LC-MS Limits: <1µg/m 2 applies to fluoro coated textiles and leather products < 0,1% by weight applies to fluoro impregnated textiles and leather products Legal background: Legal limit 1 μg/m2 applies to fluoro coated textiles and leather products 0.1% by weight applies to fluoro impregnated textiles and leather products PFOS is listed in the Stockholm Convention on Persistent Organic Pollutants (POPs) and banned by Regulation (EC) 850/2004 (EU regulation implementing Stockholm Convention). Characteristics: Polyflourocarbons are surfactant, stable, temperature-resistant and water- and grease-repellent substance. PFOS is dangerous for the environment. PFOS degrades very slowly and is bio-accumulative. Use: Additives in cleaning agents and impregnation agents in leather and textiles. Alternatives: Alternatives available are polytetrafluoroethylene PTFE membranes and laminates. Verification method: Written certificate produced on demand stating that the product does not contain precursors that could cause emissions of perfluoro-octane sulfonate. Perfluoro octane carboxylic acid (PFOA) and related substances 2 CAS RN: standard LC-MS Legal background: Pentacosafluorotridecanoic acid(pftrda), , Tricosafluorododecanoic acid (PFDoA), , Henicosafluoroundecanoic acid (PFUnA), and Heptacosafluorotetradecanoic acid (PFTA), are listed in the Candidate List of Substances of Very High Concern for authorization of Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH). On 20 December 2011, rway notified the World Trade Organization (WTO) of intentions to introduce rwegian national legislation from 1 July 2012 with the following restrictions for PFOA: 1 ppm in articles 1 μg/m² in textiles. Considerations of similar PFOS restrictions of PFOA, according to EU. Characteristics: Polyfluorocarbons are surfactant, stable, temperature-resistant and water- and grease-repellent substance. PFOA is a potential carcinogen. Use: Additives in cleaning agents and impregnation agents in leather and textiles. Alternatives: Alternatives available are fluorpolymer membranes, laminates or dispersions. 1 The total amount of PFOS and PFOS related substances counted as PFOS, see EN/TS 15968: The total amount of PFOA and PFOA related substances counted as PFOA, compare with PFOS. Page 11/17

12 Chloroparaffins CAS RN: Short-chain chloroparaffins (C10- C13): Medium-chain chloroparaffins (C14- C17): Long-chain chloroparaffins (C18- ): available for textiles. Detection limit: There is no standard detection limit as yet. GC-MS, LC-MS Legal background: Legal limit: 0.1% by weight Annex XVII of Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH). Short-chain chloroparaffins (C10-C13) are listed on the Candidate list of Substances of Very High Concern (SVHC) for the authorization of the Regulation (EC) 1907/2006 of the European Parliament of the Council (REACH). On 20 December 2011, rway notified the World Trade Organization (WTO) of intentions to introduce rwegian national legislation from 1 July 2012 with restrictions for medium-chain chloroparaffins of 0,1 % by weight in articles. Characteristics: Dangerous for the environment. Allergenic. Toxic. Use in textiles: Plasticizers and flame retardant in plastic material. Use in leather: Plasticizers in coated leather. Use in accessories and packaging: Plasticizers and flame retardant in plastic material and rubber. Hexabromocyclo dodecan (HBCDD) CAS RN: Hexabromocyclodode cane (HBCDD): , , , and Detection limit: There is no standard detection limit as yet. For LC-MS 1 mg/kg can be expected. GC-MS, LC-MS, GC-ECD Comments: Replace chloroorganic chemical flame retardants with phosphorus- and/or nitrogen-based organic chemical flame retardants or non chemical barrier technologies. Alternative plasticizers are available but must be evaluated. Legal background: Legal limit: 0.1% by weight. Hexabromocyclododecane (HBCDD) and all major isomers are listed in both annex XIV and in the Candidate List of Substances of Very High Concern for authorization of Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH). Characteristics: Persistant, bioaccumulative and toxic. Halogenated organic additives in polymers may leach out and have a negative impact on health and environment. Halogen containing polymers may form highly corrosive substances and undefined range of halogenated substances that may be PBT or CMR when incinerated. Use: Flame-retardant treatment of products, (i.e upholstery and interior textiles), where fire protection is required. Also used in packaging flakes made of polystyrene (PS). Comments: Replace bromo organic chemical flame retardants with phosphorus- and/or nitrogenbased organic chemical flame retardants or non chemical barrier technologies such as blends of natural and synthetic fibers used in furniture and mattresses and high performance synthetic materials used in firefighter uniforms and other protective clothing. Textile goods for private use are basically never flameretardant-treated. The only case when textile goods are treated with flame retardant is if the end customer orders this property. Usually it is done to Page 12/17

13 satisfy regulatory requirements on fire protection. Phthalate esters Regulated phthalate esters are DEHP, DBP, BBP, DINP, DIDP, DNOP, DIBP, DIHP DHNUP and DMEP. CAS RN: DEHP: DBP: BBP: DINP: DIDP: DNOP: DIBP: DIHP: DHNUP: DMEP: ,2- Benzenedicarboxylic acid, dipentylester, branched and linear: DIPP: N-pentylisopentylphthalate: EN GC-MS, LC-MS <1000 mg/kg (0.1%) by weight in the material of interest (e.g. a print). Legal background: Annex XVII of Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH). DBP, DEHP,BBP and DIBP are listed in both Annex XIV and in the Candidate List of Substances of Very High Concern for authorization of Regulation (EC) 1907/2006 of the European Parliament and of thecouncil (REACH). DIHP, DHNUP, and DMEP, 1,2- Benzenedicarboxylic acid, dipentylester, branched and linear, DIPP and N-pentyl-isopentylphthalate are listed in the Candidate List of Substances of Very High Concern for authorisation of the Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH). Characteristics: DEHP and DIBP are classified as hazardous to health. DBP is classified as having health and environmental effects. BBP is classified as having health and environmental effects. DIDP shows concerns for hepatic toxicity. Many phthalates are suspected endocrine disrupters. Use: Plasticizers in polymers. Additives in adhesives, paints, lacquers, varnishes and solvents. TCEP CAS RN: Tris(2- chlorethyl)phosphate (TCEP): standardised GC-MS, LC-MS, GC-ECD There is no standard detection limit as yet. For LC-MS 1 mg/kg can be expected. Alternatives: Alternatives are available but must be evaluated. Legal background: Legal limit is 0,1 % by weight. Tris(2-chlorethyl) phosphate (TCEP) is listed in the Candidate List of Substances of Very High Concern for authorization of the Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH). Characteristics: Persistant, bioaccumulative and toxic. Halogenated organic additives in polymers may leach out and have a negative impact on health and environment. Halogen containing polymers may form highly corrosive substances and undefined range of halogenated substances that may be PBT or CMR when incinerated. Use: Flame-retardant treatment of products (i.e. coated textiles) where fire protection is required. Plasticizers. Comments: Replace chloroorganic chemical flame retardants with phosphorus- and/or nitrogen-based organic chemical flame retardants or non-chemical barrier technologies such as blends of natural and synthetic fibers used in furniture and mattresses and high performance synthetic materials used in firefighter uniforms and other protective clothing. Textile goods for private use are basically never flameretardant-treated. The only case when textile goods are treated with flame retardant is if the end customer orders this property. Usually it is done to Page 13/17

14 satisfy regulatory requirements of fire protection. BIOCIDAL AGENTS Pentachlorphenol and all isomers of Tetrachlorphenols (TeCP) PCP CAS RN: ISO (leather) XP G (textiles) products Legal background: Annex XVII of Regulation (EC) no. 1907/2006 of European Parliament and of the Council (REACH) Pentachlorophenol (and its salts and esters) is banned in rway in textiles and leather. Legal limit 5 ppm. Pentachlorophenol is listed in the Rotterdam convention. Characteristics: Organic compounds. Toxic and dangerous for the environment. On combustion, PCP emits dioxins, which are extremely toxic to humans. Use: Fungicide for preservative treatment of goods prior to storage and transport. Preservative in sizing agents and adhesives. Component in sizing mix, printing pastes (thickener). Alternatives: The alternative to biocidal agents during storage and transport is cool and dry environment. Silver complexes in nano size (Ag +) standard ICP-MS, ICP- OES or AAS product. Legal background: Metallic silver is on the list of temporarily permitted existing biocides within PT9 (product type 9) that includes textiles, polymers and leather, according to the Biocidal Products Directive (98/8/EC). Characteristics: Slight skin and eye irritant. Disturb denitrification processes in nature that is vital for provision of nutrition s to plants. Dissolved (free) silver ions are very toxic to aquatic organisms. Use: Silver particle complexes in nano size (< 100nm) are antibiotic additives in plastics and fibres. Alternatives: The alternative to antibacterial agents during use is satisfactory washing. Triclosan CAS RN: standard GC-MS; LC-MS product. Legal background: Triclosan is on the list of existing biocides within PT9 (product type 9) that includes textiles, polymers and leather, according to the Biocidal Products Directive (98/8/EC). Characteristics: Anti bacterial agent. Triclosan is classified as a probable human carcinogen and bio accumulative. Use: Anti bacterial agent in clothes and other commodities Alternatives: The alternative to antibacterial agents during use is satisfactory washing. Page 14/17

15 Permethrin CAS RN: standard GC-MS; LC-MS product. Legal background: Permethrin is on the list of temporarily permitted existing biocides within PT9 (product type 9) that includes textiles, polymers and leather, according to the Biocidal Products Directive (98/8/EC). Characteristics: Insecticide. Permethrin is like all synthetic pyrethroids a neurotoxin. It is considered more acutely toxic to children than to adults. Use: Permethrin is a biocide in textiles. Alternatives: The alternative to biocidal agents during production is satisfactory washing. The alternative to biocidal agents during storage and transport is cool and dry environment. Tributyltin oxide (TBTO) CAS RN: standard mg/kg. DIN EN ISO17353 (water and sediment) GC-MS product. Legal background: Legal Limit is 0.1% by weight Dioctyltin (DOT), dibutyltin (DBT) compounds and trisubstituted organostannic compounds such as tributyltin (TBT) are listed in annex XVII of the Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH). Tributyltin oxide (TBTO) is listed on the Candidate List of Substances of Very High Concern for authorization of the Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH)Characteristics: Anti-bacterial agent. Tributyltin compounds are different chemical substances that are toxic and dangerous for the environment. Bio accumulative and persistent. Use in textile and leather: To counteract noxious odours in clothes and shoes. Preservative, fungicide and antifouling agent. Alternatives: The alternative to antibacterial agents is satisfactory washing. Dimethylfumarate (DMFu) CAS RN: standard GC-MS; LC-MS product nor in desiccant. Legal background: banned according to EU Directive 2001/95/EC (General Product Safety). As of 1 May 2009 Member States shall ensure that products containing DMF in a concentration greater than 0,1 mg/kg of the weight may not be placed on the market. Directive 2001/95/EC also implies that products containing DMFu put on the market before this date shall be withdrawn from the market. Characteristics: Fungicide. DMFu is harmful to skin and a strongly allergenic substance. Use in textile and leather: To counteract fungus growth in clothes, shoes and other leather items. DMFu can e.g. be found in silica gel bags, but is also applied on the product both as a powder and in tablet form. Alternatives: The alternative to biocidal agents during storage and transport is cool and dry environment Page 15/17

16 Specific requirements regarding content of harmful chemicals (Substances of Very High Concern SVHC) in all our products and packaging materials All our products and packaging materials used for Kwintet orders must be in compliance with the restrictions listed on the Candidate List of Substances of Very High Concern for authorization of the Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH). The latest list is always available for access through the following link: Substances of Very High Concern listed on Annex XIV The following six substances are not only listed as SVHC but also included in Annex XIV of Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH), i.e. if the substances are used in amounts >1000 mg/kg (0.1%) by weight in the material of interest, authorization is required. CHEMICAL SUBSTANCES CAS NUMBER EC NUMBER Benzyl butyl phthalate (BBP) Bis (2-ethyl(hexyl)phthalate) (DEHP) Dibutyl phthalate (DBP) ,4 -Diaminodiphenylmethane (MDA) 5-tert-butyl-2,4,6-trinitro-mxylene (musk xylene) Hexabromocyclododecane (HBCDD) and all major diastereoisomers identified (α HBCDD, β-hbcdd, γ- HBCDD) and ( , , and Page 16/17

17 Certificate of compliance with the Kwintet Restricted Substances List By signing this document the supplier certifies that all articles delivered by the supplier to Kwintet are produced in compliance with the Öko-Tex 100 Standard and all additional restrictions related to residues of harmful substances listed in the Kwintet Restricted Substances List.. The supplier accepts to be held liable for all losses and damages suffered by Kwintet, in case harmful substances, as stipulated in the Restricted Substances List enclosed to this certificate, are being found in any of the materials, components or products with actual values above the mentioned maximum values which are set forth in the Öko-Tex 100 Standard and the list of additional restrictions included in the Kwintet Restricted Substances List, effective from the date of signature. Kwintet will ensure that its nominated suppliers are in compliance with the RSL Furthermore, by signing this document the supplier commits to: 1) communicating the Kwintet Restricted Substances List to all of its subcontractors as well as accessory and chemicals suppliers, and ensure that they are in compliance with the Kwintet Restricted Substances List, 2) at own cost conduct relevant lab tests to verify compliance with the Kwintet Restricted Substances List and upon request send Kwintet a copy of the test report, 3) staying continuously updated with latest version of the Kwintet Restricted Substances List, available for download at Kwintet s web site By effect, this means that the supplier also must comply with restrictions on substances added to the Kwintet Restricted Substances List after the date of supplier signing the document. Kwintet will notify its suppliers whenever the RSL is updated. 4) Stay continuously updated with REACH Candidate List of Substances of Very High Concern for authorization of the Regulation (EC) 1907/2006 of the European Parliament and of the Council (REACH): Kwintet reserves the right to, at any time, conduct its own random tests to ensure that articles produced for Kwintet are in compliance with the Restricted Substances List. Liquidated damages clause regarding violations of the Kwintet Restricted Substances List If articles produced for Kwintet are found to contain prohibited amounts of substances specified in the Kwintet Restricted Substances List after shipment and payment to supplier has taken place already, supplier shall pay a fine of minimum the amount Kwintet was invoiced by the supplier for the damaged goods. If Kwintet can document that losses are larger than the amount invoiced by the supplier, the fine shall be adjusted accordingly. Supplier will also have to ensure that a) articles remaining to be produced for Kwintet no longer exceed the restricted substance s limit values, and b) the goods are approved by Kwintet prior to next shipping/transportation. Supplier (name and all associated companies, subcontractors). Address1:. Address2:. Country: Direct phone: Fax: Date: On behalf of the supplier: Name in print: Position: Page 17/17