Similarly, dyeing, printing, finishing and tanning processes can be hazardous, and have a well-deserved historical reputation for damaging human health and the environment. While many chemicals are safe when used appropriately, it is essential to identify and eliminate those that pose a risk to human health and the environment.

It was long assumed that toxic waste could be managed by dilution into the environment. This has reached a point, where bioaccumulation is a threat to society. We need to understand and manage the impact of every chemical used in textile manufacturing. This has been recognised by governments in textile-producing countries who are dealing with the issues through national and local legislation, particularly for waste water and air emissions. Responsible dye and chemical manufacturers, dyers, printers and retailers have also addressed the problem.

Chemical Legislation

Countries within the textile supply chain have environmental legislation, some targeting textile processors in particular. These nations have minimum standards for effluent, solid waste disposal and air emissions, violations of which can lead to warnings, fines and possible closure. For example, some states in India are insisting onfrom processors, and closing non-compliant facilities.

Environmental legislation in Europe is well-established. REACH legislation is an excellent example of chemical management, aimed at manufacturers and importers of chemicals. REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemical substances. REACH is chemical legislation covering the European Economic Area (EEA) that was introduced in 2007, its purpose being the protection of human health and the environment, with focus on chemicals of high concern. It is administered by the European Chemical Agency (ECHA) and applies to chemicals that are manufactured in or imported into the EEA at over 1 tonne per annum.

Industrial and household chemicals are included, plus articles that contain chemicals, e.g. textiles and electrical items.

The REACH process

Registration

Manufacturers and Importers of chemicals over 1 tonne per annum must register the chemical with the ECHA. Registration also applies to articles that release substances intentionally in excess of 1 tonne per annum. Examples are fragranced candles, printer cartridges, aerosols etc.

Evaluation

The ECHA evaluates the registration information and decides if the substance should be added to the Candidate List of Substances of Very High Concern (SVHC). The classification is based the chemical’s carcinogenic, mutagenic, environmental persistence and bioaccumulative properties.

SVHC Obligations – Notification

If a chemical contains more than 0.1 per cent by weight of an SVHC, and the total amount of SVHC per annum per manufacturer or importer exceeds 1 tonne, then the ECHA must be notified.

SVHC Obligations – Communication

If the SVHC content of an article exceeds 0.1 per cent, this must be communicated to the recipient. Information must be provided about the chemical, including advice on its safe storage, handling and disposal. The “recipient” is someone who will use the chemical or article as part of their work – this does not include consumers. However, if a consumer requests information on SVHC presence, information must be made available, free of charge, within 45 days. This is a legal obligation.

Authorisation

The ECHA carries out regular reviews of the Candidate List to decide if a substance should be authorised for use. After a “sunset date”, the use of the substance must stop unless authorised.

The Authorisation List is Annex XIV.

Restriction

Annex XVII of REACH lists substances whose use is restricted, and gives details of those restrictions, and limits on residual content allowed in articles.

Definition and Interpretation of “Article” under REACH

Definition

The 2007 REACH definition of an article is something that: “During production is given a special shape, surface or design which determines its function to a greater degree than its chemical composition.” For example, an unshaped lump of iron is not an article. If it is moulded into a doorstop, it has the same weight and molecular structure, but its design now makes it an article. The shape is more important than the chemical composition.

Interpretation

Some member states considered a complex article made up of separate components to be a complete article. This was challenged in the European Court of Justice, who decided, in 2015, that each component of a complex product is now an article in its own right. For example, a button on a jacket used to be considered as part of an article, and would be part of the overall jacket weight. Any SVHC content in the button would be based on the weight of the whole jacket. Under the new interpretation, any SVHC content of the button will no longer be “diluted” by the weight of the rest of the product – it stands alone as an article.

Componentry

The same SVHC requirements apply to zips, sequins, bows, beads and other embellishments, which must comply as individual articles.

Non-Governmental Initiatives

Retailers

Some retailers have introduced regularly-updated Restricted Substance Lists (RSL), which identify and restrict hazardous substances that may appear on the final product. RSL requirements often go beyond legal obligations. The influence of restricted substances lists on the wet processing industry’s chemical management policies, and the consequent impact on workers, the environment and consumers is considerable.

Some retailers have also introduced Manufacturing Restricted Substances Lists (MRSL) which place restrictions on input chemicals used by wet processors. This helps to protect workers and the environment, and reduces harmful residues on the final product.

Dye and Chemical Manufacturers

Responsible dye and auxiliary chemical manufacturers have worked on eliminating SVHCs from their products, and provide confirmation of compliance to their customers.

Wet Processors

Dyers, printers, finishers, laundries and tanneries who use products from companies who can demonstrate chemical compliance will minimise the effect of hazardous chemicals to workers, the environment and the consumer.

Pressure Groups

Greenpeace, in particular, have exerted influence, through their “Detox” campaign, on brands and retailers to reduce the discharge of hazardous chemicals into the environment. This has led to the formation of the Zero Discharge of Hazardous Chemicals group, whose membership includes several leading brands and retailers.

Key points

• Many chemicals used in the textile industry are hazardous, and need to be identified, managed and eliminated where possible.
• Legislation is in place to protect workers, the environment and the consumer.
• EU REACH legislation is a good example of responsible chemical management by governments.
• Current REACH legislation means that components that make up complex articles are all articles in their own right, and SVHC obligations apply to them.
• Responsibility lies with chemical manufacturers, textile processers including dyers, printers, laundries and tanneries, and with retailers.
• Responsible chemical manufacturers minimise or eliminate particularly hazardous chemicals from their formulations.
• Responsible processors operate an enforceable chemical management policy to minimise or eliminate risks to their workers, the environment and the consumer of the final product.
• Responsible retailers contribute by issuing restricted substances lists for residues on the final product, and liaising with suppliers to ensure compliance.

Conclusion

Textile processes such as dyeing, finishing and printing use hazardous chemicals, and historically this has been accepted and, to some degree, overlooked by authorities responsible for the environment. However, nowadays this situation has been recognised as unacceptable, and national and local governments are introducing increasingly stringent legislation on worker protection, environmental pollution and consumer safety.

The EU’s REACH legislation is an advanced model of chemical management at national level, and similar measures are being introduced or considered by non-European countries in the current textile supply base. Responsibility for chemical management within textiles lies in three key areas – chemical manufacturers, wet processors and retailers. Their roles are closely linked.

The dye and chemical auxiliary manufacturers are solely responsible for the ingredients used in their formulations, and are therefore best placed to identify, reduce and eliminate hazardous chemicals. Retailers and brands can issue RSLs and MRSLs to their suppliers’ wet processors, who in turn can put pressure on their chemical manufacturers to supply them with compliant formulations. Wet processors have the responsibility to source the least hazardous chemicals available and ensure that optimum process conditions are employed in their application.

No single entity can exert enough influence to reduce or eliminate hazardous chemicals from the industry. Constant dialogue and trust between national and local governments, chemical manufacturers, wet processors, retailers and pressure groups are essential to achieve progress.