{"about":"An illustrative pathway, not a traced shipment. Each cell keeps four kinds of evidence apart: legal basis, case evidence, recipient access and decision usefulness. A claim is published only with a source, a verbatim passage and a verification date.","changeLog":[{"date":"2026-10-26","change":"First published, with evidence checked on 23 October 2026."}],"claims":[{"claim":"Under the EU Textile Labelling Regulation (TLR, Regulation (EU) No 1007/2011), a textile product may only be made available on the EU market if it is labelled or marked with its fibre composition, and a label must be durable, easily legible and securely attached. The manufacturer, or the EU importer where the manufacturer is outside the EU, answers for supplying the label and for its accuracy; between businesses in the supply chain, commercial documents may replace or supplement the label.","claimType":"legal","conditions":"Applies to textile products and to products containing at least 80% textile fibres by weight (Article 2(2)(a)) whenever they are made available on the market","confidence":"high","contrary":null,"decisionSupported":"Knowing what the jacket is made of, by fibre, at and after purchase","documentRef":"Regulation (EU) No 1007/2011, Articles 4, 14(1) and 15(1)","exemptions":"In supply to economic operators within the supply chain, labels may be replaced or supplemented by accompanying commercial documents (Article 14(2))","fields":["component"],"handovers":["h3","h4"],"id":"LAW-01","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"A duty to label does not show that any given label is accurate or that it survives wear and washing. 'Durable' is not defined in terms of legibility at a sorting line. The Vietnamese factory has no duty under the TLR; the duty sits with whoever places the jacket on the EU market.","materialStatus":"article","note":null,"passage":"Textile products shall only be made available on the market provided that such products are labelled, marked or accompanied with commercial documents in compliance with this Regulation. [...] The labelling and marking of textile products shall be durable, easily legible, visible and accessible and, in the case of a label, securely attached. [...] When placing a textile product on the market, the manufacturer shall ensure the supply of the label or marking and the accuracy of the information contained therein. If the manufacturer is not established in the Union, the importer shall ensure the supply of the label or marking and the accuracy of the information contained therein.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 4; Article 14(1), second subparagraph; Article 15(1)","recipient":"Distributors and the consumer","sender":"The manufacturer placing the jacket on the EU market or, where the manufacturer is not established in the EU, the EU importer (a distributor selling under its own name or trade mark counts as manufacturer, Article 15(2))","sourceDate":"2018-02-15","sourceId":"src-6c6fc89e","threshold":null,"timing":"Applies from 8 May 2012 (Article 28)","verificationMethod":"Fetched official consolidated text from the EU Publications Office (Cellar content negotiation); the EUR-Lex web front end blocked automated requests (CELEX 02011R1007-20180215, the latest consolidation found)."},{"claim":"The TLR label must give the name and percentage by weight of every constituent fibre in descending order, and where a product has textile components with different fibre contents, the content of each component. Components that are not main linings and weigh under 30% of the product need not be listed, so a jacket's label covers its outer fabric and main lining but may leave smaller textile parts unstated.","claimType":"legal","conditions":"Product with two or more textile components of different fibre content","confidence":"high","contrary":null,"decisionSupported":"Identifying fibre type per component, for care, purchase and later for sorting by material","documentRef":"Regulation (EU) No 1007/2011, Articles 9(1) and 11(1)-(2)","exemptions":null,"fields":["component"],"handovers":["h3","h4"],"id":"LAW-02","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"Fibre composition is not chemical composition. These articles do not settle whether a laminated film membrane is a 'textile component' or a 'non-textile part' (see LAW-03); that is an application question for the scenario.","materialStatus":"article","note":null,"passage":"A textile product shall be labelled or marked with the name and percentage by weight of all constituent fibres in descending order. [...] Any textile product containing two or more textile components which have different textile fibre contents shall bear a label or marking stating the textile fibre content of each component. [...] The labelling or marking referred to in paragraph 1 shall not be compulsory for textile components when the following two conditions are fulfilled: (a) those components are not main linings; and (b) those components represent less than 30 % of the total weight of the textile product.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 9(1); Article 11(1) and (2)","recipient":"Consumer and distributors","sender":"Manufacturer or EU importer","sourceDate":"2018-02-15","sourceId":"src-6c6fc89e","threshold":"Component labelling not compulsory where the component is not a main lining and represents less than 30 % of the total weight of the textile product (Article 11(2))","timing":null,"verificationMethod":"Fetched official consolidated text from the EU Publications Office (Cellar content negotiation); the EUR-Lex web front end blocked automated requests."},{"claim":"When fibre composition is worked out for the TLR label, finishing chemistry is expressly left out: 'impregnating products' and 'other textile processing products' are not taken into account, nor are non-textile parts. The label is designed to say 'polyester', not what the polyester was finished with, so a durable water-repellent (DWR) finish has no place on it by law.","claimType":"legal","conditions":null,"confidence":"high","contrary":null,"decisionSupported":"None for chemistry: the mandatory label cannot support a decision about the water-repellent finish","documentRef":"Regulation (EU) No 1007/2011, Article 19(2) and Annex VII, row (a)","exemptions":null,"fields":["component","chemical"],"handovers":["h3","h4","h5"],"id":"LAW-03","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"The rule governs how fibre content is calculated; it does not stop a brand adding voluntary information elsewhere. Reading a DWR finish as an 'impregnating product' or 'other textile processing product' is an application of the text to the scenario, though a plain one.","materialStatus":"article","note":null,"passage":"In the determination of fibre compositions set out in Articles 7, 8 and 9, the items listed in Annex VII shall not be taken into account. [...] (a) All textile products (i) Non-textile parts, selvedges, labels and badges, edgings and trimmings not forming an integral part of the product, buttons and buckles covered with textile materials, accessories, decorations, [...] (ii) Fatty substances, binders, weightings, sizings and dressings, impregnating products, additional dyeing and printing products and other textile processing products","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 19(2); Annex VII, row (a)(i) and (ii)","recipient":"Consumer, distributors, and anyone who later reads the sewn-in label","sender":"Manufacturer or EU importer (label author)","sourceDate":"2018-02-15","sourceId":"src-6c6fc89e","threshold":null,"timing":null,"verificationMethod":"Fetched official consolidated text from the EU Publications Office (Cellar content negotiation); the EUR-Lex web front end blocked automated requests."},{"claim":"Fibre composition must be clearly visible to the consumer before purchase, including when buying online, and the label must be in the official language or languages of the Member State where the jacket is sold to the consumer, unless that state provides otherwise. For a jacket sold in France the label must therefore be readable in French.","claimType":"legal","conditions":null,"confidence":"high","contrary":null,"decisionSupported":"Choosing a garment by fibre composition before buying","documentRef":"Regulation (EU) No 1007/2011, Article 16(1) and (3)","exemptions":null,"fields":["component"],"handovers":["h4"],"id":"LAW-04","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"French national language rules (for example the Loi Toubon) were not checked in this package. The language duty serves the French buyer; a label in French may not serve a reuse buyer elsewhere at H6.","materialStatus":"article","note":null,"passage":"This information shall be clearly visible to the consumer before the purchase, including in cases where the purchase is made by electronic means. [...] The labelling or marking shall be provided in the official language or languages of the Member State on the territory of which the textile products are made available to the consumer, unless the Member State concerned provides otherwise.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 16(1), second sentence; Article 16(3)","recipient":"Consumer in France, in shop or online","sender":"Manufacturer, importer or distributor making the jacket available","sourceDate":"2018-02-15","sourceId":"src-6c6fc89e","threshold":null,"timing":null,"verificationMethod":"Fetched official consolidated text from the EU Publications Office (Cellar content negotiation); the EUR-Lex web front end blocked automated requests."},{"claim":"EU law does not require a textile label to carry care instructions, country of origin, allergenic substances or any electronic labelling. In the TLR these appear only as topics the Commission was asked to examine in a review report due by 30 September 2013.","claimType":"legal","conditions":"Statement of what the regulation does not currently require; the listed topics are review items, not duties","confidence":"high","contrary":null,"decisionSupported":null,"documentRef":"Regulation (EU) No 1007/2011, Article 24(1) and (3)","exemptions":null,"fields":["chemical","handling"],"handovers":["h3","h4"],"id":"LAW-05","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Covers EU law only. National rules on care labelling exist in some Member States (see LAW-06). Other EU laws (REACH Article 33, GPSR) can require information that a brand may choose to place on the label.","materialStatus":"article","note":null,"passage":"By 30 September 2013, the Commission shall submit a report to the European Parliament and to the Council regarding possible new labelling requirements to be introduced at Union level [...] The report shall be accompanied, where appropriate, by legislative proposals, and shall examine, inter alia, the following issues: (a) an origin labelling scheme aimed at providing consumers with accurate information on the country of origin [...] (b) a harmonised care labelling system; [...] (d) an indication of allergenic substances; (e) electronic labelling and other new technologies, and the use of language-independent symbols or codes for the identification of fibres.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 24(1) and (3)(a), (b), (d), (e)","recipient":null,"sender":null,"sourceDate":"2018-02-15","sourceId":"src-6c6fc89e","threshold":null,"timing":null,"verificationMethod":"Fetched official consolidated text from the EU Publications Office (Cellar content negotiation); the EUR-Lex web front end blocked automated requests."},{"claim":"A study for the Commission's Joint Research Centre (JRC) reports, citing the care-labelling association GINETEX (2017), that care instructions are mandatory in 12 EU Member States. France is not among those listed, so the care symbols on a jacket sold in France appear to be voluntary practice rather than a legal requirement.","claimType":"interpretation","conditions":null,"confidence":"medium","contrary":null,"decisionSupported":null,"documentRef":"JRC study Textiles_DPP_20260513, section on disclosures in other legislation, footnote 35","exemptions":null,"fields":["handling"],"handovers":["h4"],"id":"LAW-06","jurisdiction":"EU / France","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Secondary statement of national law dated to 2017. Absence from the list is evidence, not proof, that France has no care-labelling duty. Care symbols address washing and drying, not chemical content.","materialStatus":"article","note":null,"passage":"— Countries like China, Japan, Canada, Australia and the USA mandate care instructions via national symbols/standards, which are also mandatory in 12 Member States35 (GINETEX, 2017). [footnote 35:] Austria, Bulgaria, Estonia, Finland, Hungary, Lithuania, Romania, Slovakia, Czech Republic, Poland, Denmark, Letonia and, as well as, in the EEA, Norway.","passageLanguage":"en","passageTranslation":null,"pinpoint":"p. 28 and footnote 35","recipient":null,"sender":null,"sourceDate":"2026-05-13","sourceId":"src-b9cc3aff","threshold":null,"timing":null,"verificationMethod":"Fetched the official JRC PDF (saved by WebFetch, text extracted locally). The study's disclaimer states it does not necessarily reflect the Commission's position. French law and the GINETEX source were not checked directly."},{"claim":"No proposal to revise the TLR had been published by 20 September 2026. The European Parliament's Legislative Train marks the file 'Blocked', citing a revision planned for the second quarter of 2026 that would introduce specifications for physical and digital labelling of textiles.","claimType":"proposal","conditions":"Planned legislation only; no Commission proposal identified","confidence":"medium","contrary":null,"decisionSupported":null,"documentRef":"Legislative Train file 'textile-labeling-regulation'","exemptions":null,"fields":["component"],"handovers":["h3","h4"],"id":"LAW-07","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":null,"limitations":"The Legislative Train is a Parliament tracking service, not a legal record. A proposal could appear before 20 November 2026; its contents (care, origin, digital label, chemicals) are unknown.","materialStatus":"article","note":null,"passage":"Blocked [...] the planned proposed revision of this regulation by the second quarter of 2026 [...] introduce specifications for physical and digital labelling of textiles [...] Information updated as of 20/09/2026.","passageLanguage":"en","passageTranslation":null,"pinpoint":"File status and body text","recipient":null,"sender":null,"sourceDate":"2026-09-20","sourceId":"src-490ab543","threshold":null,"timing":"Revision planned 'by the second quarter of 2026'; not published at the last update (20 September 2026)","verificationMethod":"Fetched with WebFetch, which returned the quoted fragments verbatim; direct download was blocked ('Request blocked'). The Commission's TLR review page (single-market-economy.ec.europa.eu, review-regulation-eu-10072011) was also consulted and states that only physical labels are currently foreseen."},{"claim":"Under REACH Article 33(1), any supplier of an article containing a substance of very high concern (SVHC) on the Candidate List above 0.1% weight by weight must give the recipient enough information for safe use, at least the substance name. The duty runs between EU supply chain actors: 'recipient' means a professional user or distributor and excludes consumers, and the information is only what is 'available to the supplier'.","claimType":"legal","conditions":"Substance on the Candidate List (identified under Article 59(1)) present in the article","confidence":"high","contrary":null,"decisionSupported":"Safe handling and onward communication by the retailer; whether to stock the item","documentRef":"Regulation (EC) No 1907/2006, Article 33(1) and Article 3(35)","exemptions":null,"fields":["chemical","handling"],"handovers":["h3"],"id":"LAW-08","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"REACH binds actors in the EU. The Vietnamese mill and factory have no Article 33 duty to the importer, which must rely on contracts, declarations or tests (an interpretation of REACH's territorial scope, not a quoted provision). There is no duty to test: the information is what is 'available to the supplier'. Covers Candidate List substances only.","materialStatus":"article","note":null,"passage":"Any supplier of an article containing a substance meeting the criteria in Article 57 and identified in accordance with Article 59(1) in a concentration above 0,1 % weight by weight (w/w) shall provide the recipient of the article with sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance. [...] recipient of an article: means an industrial or professional user, or a distributor, being supplied with an article but does not include consumers;","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 33(1); Article 3(35)","recipient":"Distributors and professional users, such as the retailer (REACH Article 3(35)); not consumers","sender":"EU supplier of the article: producer, importer or distributor (REACH Article 3(33)); for this jacket, the EU importer or brand onwards","sourceDate":"2026-06-22","sourceId":"src-5cf370c6","threshold":"in a concentration above 0,1 % weight by weight (w/w)","timing":null,"verificationMethod":"Fetched official consolidated text from the EU Publications Office (Cellar content negotiation); the EUR-Lex web front end blocked automated requests (CELEX 02006R1907-20260622, consolidated 22 June 2026)."},{"claim":"A consumer gets SVHC information only by asking. Under REACH Article 33(2), any supplier of the article must, on a consumer's request, give at least the substance name, free of charge, within 45 days.","claimType":"legal","conditions":"Consumer request; Candidate List substance present in the article","confidence":"high","contrary":null,"decisionSupported":"Whether to buy, use, wash or discard the jacket knowing which SVHC it contains","documentRef":"Regulation (EC) No 1907/2006, Article 33(2)","exemptions":null,"fields":["chemical","handling"],"handovers":["h4"],"id":"LAW-09","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"Nothing reaches the consumer by default; the consumer has to know the right exists and whom to ask. A 45-day answer cannot inform a decision at the till. A 'no SVHC above 0.1%' answer says nothing about PFAS that are not on the Candidate List.","materialStatus":"article","note":null,"passage":"On request by a consumer any supplier of an article containing a substance meeting the criteria in Article 57 and identified in accordance with Article 59(1) in a concentration above 0,1 % weight by weight (w/w) shall provide the consumer with sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance. The relevant information shall be provided, free of charge, within 45 days of receipt of the request.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 33(2)","recipient":"The consumer, on request only","sender":"Any supplier of the article, including the retailer or brand","sourceDate":"2026-06-22","sourceId":"src-5cf370c6","threshold":"in a concentration above 0,1 % weight by weight (w/w)","timing":"Within 45 days of receipt of the request","verificationMethod":"Fetched official consolidated text from the EU Publications Office (Cellar content negotiation); the EUR-Lex web front end blocked automated requests."},{"claim":"The Court of Justice ruled in 2015 (Case C-106/14) that the 0.1% threshold applies to each article that forms part of a complex product, not to the product as a whole. For a jacket, each constituent article (for example the outer fabric, the zip) is assessed separately, so dilution across the whole garment does not remove the duty to inform.","claimType":"legal","conditions":null,"confidence":"high","contrary":null,"decisionSupported":"Whether the SVHC information duty is triggered for a multi-part garment","documentRef":"Case C-106/14, operative part, point 2","exemptions":null,"fields":["chemical","result"],"handovers":["h3","h4"],"id":"LAW-10","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"The judgment does not decide which layers of a laminated fabric are separate 'articles'; that is an application question. It concerns the Candidate List trigger only.","materialStatus":"article","note":null,"passage":"Article 33 of Regulation No 1907/2006, as amended, must be interpreted as meaning that, for the purposes of application of that provision, it is for the supplier of a product one or more constituent articles of which contain(s) a substance of very high concern identified in accordance with Article 59(1) of that regulation in a concentration above 0.1% weight by weight of that article, to inform the recipient and, on request, the consumer, of the presence of that substance by providing them, as a minimum, with the name of the substance in question.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Operative part, point 2","recipient":"Recipient (professional) and, on request, the consumer","sender":"Supplier of the complex product","sourceDate":"2015-09-10","sourceId":"src-ca4f8231","threshold":"above 0.1% weight by weight of that [constituent] article","timing":null,"verificationMethod":"Fetched the official judgment text (CELEX 62014CJ0106) from the Publications Office Cellar."},{"claim":"On 23 October 2026 the REACH Candidate List of substances of very high concern includes several PFAS (per- and polyfluoroalkyl substances): PFOA and its ammonium salt, the C11 to C14 perfluorocarboxylic acids, PFNA, PFDA, PFHxS, PFHpA, PFBS, HFPO-DA, perfluamine and a fluorinated morpholine mixture. PFHxA is not on it, and there is no group entry for PFAS, so the SVHC information duties (Article 33, SCIP, France's AGEC mention) do not reach PFHxA or PFAS in general.","claimType":"legal","conditions":"Inclusion on the Candidate List is the trigger for REACH Article 33, the SCIP notification and the French AGEC hazardous-substance mention","confidence":"high","contrary":null,"decisionSupported":null,"documentRef":"REACH Article 59(1) Candidate List, 253 entries","exemptions":null,"fields":["chemical"],"handovers":["h3","h4","h5"],"id":"LAW-11","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"Bisphenol AF and its salts (added 04-Feb-2026) also carry CF3 groups but were added for reproductive toxicity and are not a DWR chemistry; they are left out of the list above. Side-chain fluorinated polymers, the typical fluorinated DWR chemistry, have no entry. The list is updated several times a year.","materialStatus":"substance","note":null,"passage":"Pentadecafluorooctanoic acid | 206-397-9 | 335-67-1 | 20-Jun-2013; Ammonium pentadecafluorooctanoate | 223-320-4 | 20-Jun-2013; Henicosafluoroundecanoic acid | 19-Dec-2012; Tricosafluorododecanoic acid | 19-Dec-2012; Pentacosafluorotridecanoic acid | 19-Dec-2012; Heptacosafluorotetradecanoic acid | 19-Dec-2012; Perfluorononan-1-oic-acid and its sodium and ammonium salts | 17-Dec-2015; Nonadecafluorodecanoic acid (PFDA) and its sodium and ammonium salts | 12-Jan-2017; Perfluorohexane-1-sulphonic acid and its salts | PFHxS | 07-Jul-2017; 2,3,3,3-tetrafluoro-2-(heptafluoropropoxy)propionic acid, its salts and its acyl halides | 16-Jul-2019; Perfluorobutane sulfonic acid (PFBS) and its salts | 16-Jan-2020; Perfluoroheptanoic acid and its salts | 17-Jan-2023; reaction mass of 2,2,3,3,5,5,6,6-octafluoro-4-(1,1,1,2,3,3,3-heptafluoropropan-2-yl)morpholine and 2,2,3,3,5,5,6,6-octafluoro-4-(heptafluoropropyl)morpholine | 17-Jan-2023; Perfluamine | 206-420-2 | 21-Jan-2025","passageLanguage":"en","passageTranslation":null,"pinpoint":"Candidate List records: substanceName, ecNumber, casNumber, dateOfInclusion fields","recipient":null,"sender":null,"sourceDate":"2026-02-04","sourceId":"src-7a67ee0b","threshold":null,"timing":"Latest inclusion 04-Feb-2026; recent additions 21-Jan-2025, 25-Jun-2025, 05-Nov-2025, 04-Feb-2026","verificationMethod":"Queried ECHA's official ECHA CHEM API (the ECHA website blocked automated requests); passage assembles field values verbatim from the returned records. Searches for 'PFHxA', 'undecafluoro' and 'fluorotelomer' returned no Candidate List entries."},{"claim":"The information duties and the restrictions work on scales 40,000 times apart. REACH Article 33 (and France's AGEC mention) start above 0.1% by weight, which is 1,000,000 parts per billion (ppb), while the PFHxA restriction starts at 25 ppb. A PFAS residue can make a jacket unlawful to sell long before any information duty would require anyone to name it.","claimType":"interpretation","conditions":null,"confidence":"high","contrary":null,"decisionSupported":null,"documentRef":"Regulation (EC) No 1907/2006, Article 33(1) and Annex XVII, entry 79, paragraph 1","exemptions":null,"fields":["result","chemical"],"handovers":["h3","h4"],"id":"LAW-12","jurisdiction":"EU / France","lastVerified":"2026-10-23","legalStatus":null,"limitations":"The two thresholds are measured on different bases (per article by weight; per homogeneous material). The comparison shows scale, not a legal relationship. French AGEC IX uses the same 0.1% basis (LAW-26).","materialStatus":"article","note":null,"passage":"in a concentration above 0,1 % weight by weight (w/w) [...] 1. Shall not, from 10 October 2026 be placed on the market, or used, in a concentration equal to or greater than 25 ppb for the sum of PFHxA and its salts, or 1 000 ppb for the sum of PFHxA-related substances, measured in homogeneous material","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 33(1); Annex XVII, entry 79, paragraph 1","recipient":null,"sender":null,"sourceDate":"2026-06-22","sourceId":"src-5cf370c6","threshold":"0,1 % w/w = 1 g/kg = 1,000,000 µg/kg (ppb); restriction limit 25 ppb (µg/kg). Ratio 1,000,000 / 25 = 40,000","timing":null,"verificationMethod":"Fetched official consolidated text from the EU Publications Office (Cellar content negotiation); the EUR-Lex web front end blocked automated requests. The ratio is arithmetic on the two quoted thresholds."},{"claim":"Older restrictions already cap long-chain PFAS in the jacket: since 25 February 2023, REACH Annex XVII entry 68 bars articles containing 25 ppb or more of C9 to C14 perfluorocarboxylic acids (PFCAs) and their salts, or 260 ppb or more of related substances. Like the PFHxA rule, this is a restriction with no information duty attached.","claimType":"legal","conditions":null,"confidence":"high","contrary":null,"decisionSupported":"Whether the jacket may be placed on the EU market (importer or brand; market surveillance)","documentRef":"Regulation (EC) No 1907/2006, Annex XVII, entry 68, paragraph 2","exemptions":"Paragraph 2(c) does not apply to articles placed on the market before 25 February 2023 (paragraph 6)","fields":["result","chemical"],"handovers":["h3"],"id":"LAW-13","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"The POPs Regulation (EU) 2019/1021 limits on PFOS, PFOA and PFHxS also apply but were not fetched in this package. A restriction creates a compliance need, which brands usually meet with declarations or tests, but no legal duty to pass information on.","materialStatus":"article","note":null,"passage":"2. Shall not, from 25 February 2023, be used in, or placed on the market in: (a) another substance, as a constituent; (b) a mixture; (c) an article, except if the concentration in the substance, the mixture, or the article is below 25 ppb for the sum of C9-C14 PFCAs and their salts or 260 ppb for the sum of C9-C14 PFCA-related substances.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Annex XVII, entry 68, paragraph 2","recipient":null,"sender":null,"sourceDate":"2026-06-22","sourceId":"src-5cf370c6","threshold":"below 25 ppb for the sum of C9-C14 PFCAs and their salts or 260 ppb for the sum of C9-C14 PFCA-related substances","timing":"From 25 February 2023","verificationMethod":"Fetched official consolidated text from the EU Publications Office (Cellar content negotiation); the EUR-Lex web front end blocked automated requests."},{"claim":"Since 5 January 2021, every EU supplier of an article must send the European Chemicals Agency (ECHA) the information it owes under REACH Article 33(1). ECHA holds it in the SCIP database and must give access to waste treatment operators and, on request, to consumers. This is the one route by which SVHC information from the point of sale is meant to reach sorters and recyclers; France transposed it in Code de l'environnement Article L. 521-5 III.","claimType":"legal","conditions":"Article contains a Candidate List SVHC above 0.1% w/w (the Article 33(1) trigger)","confidence":"high","contrary":null,"decisionSupported":"Waste operators' sorting and treatment decisions for articles containing Candidate List SVHCs","documentRef":"Directive 2008/98/EC, Article 9(1)(i) and 9(2)","exemptions":null,"fields":["chemical","handling"],"handovers":["h3","h5","h6"],"id":"LAW-14","jurisdiction":"EU / France","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"Notification to ECHA is not disclosure on the product: a sorter must look the product up, and the jacket carries no SCIP identifier. Only Candidate List SVHCs are covered, so PFHxA and most PFAS are outside it (LAW-11).","materialStatus":"article","note":null,"passage":"ensure that any supplier of an article as defined in point 33 of Article 3 of Regulation (EC) No 1907/2006 [...] provides the information pursuant to Article 33(1) of that Regulation to the European Chemicals Agency as from 5 January 2021; [...] The European Chemicals Agency shall establish a database for the data to be submitted to it pursuant to point (i) of paragraph 1 by 5 January 2020 and maintain it. The European Chemicals Agency shall provide access to that database to waste treatment operators. It shall also provide access to that database to consumers upon request.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 9(1)(i); Article 9(2)","recipient":"ECHA, then waste treatment operators; consumers on request","sender":"EU supplier of the article (importer, producer, distributor)","sourceDate":"2025-10-16","sourceId":"src-840b1ee8","threshold":"Same as REACH Article 33(1): above 0,1 % w/w","timing":"As from 5 January 2021. Proposed for repeal (LAW-15)","verificationMethod":"Fetched official consolidated text from the EU Publications Office (Cellar content negotiation); the EUR-Lex web front end blocked automated requests (CELEX 02008L0098-20251016). French transposition read in the AIDA consolidated Code de l'environnement, Article L. 521-5 III (https://aida.ineris.fr/reglementation/livre-v-prevention-pollutions-risques-nuisances-partie-legislative)."},{"claim":"The Commission proposed on 10 December 2025 (COM(2025) 986) to end the duty to submit data to SCIP, saying the database 'is not fulfilling its intended objectives'; data already reported would be kept. At 23 October 2026 the European Parliament's procedure file shows the proposal awaiting a committee decision, with an indicative plenary date of 14 December 2026. Until it is adopted, the SCIP duty still applies.","claimType":"proposal","conditions":null,"confidence":"high","contrary":"The Commission's own text records that SCIP was meant to help waste operators manage hazardous substances at end of life; repeal removes the only EU-wide channel from seller to sorter for SVHC data until a textile DPP exists.","decisionSupported":null,"documentRef":"COM(2025) 986 final, 2025/0394(COD), recital 5 and Article 1 (amending Article 9 of Directive 2008/98/EC)","exemptions":null,"fields":["chemical","record"],"handovers":["h3","h5","h6"],"id":"LAW-15","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"proposal","limitations":"The proposal can still change in Parliament and Council; no Council general approach was found. The explanatory text says SCIP information 'is made publicly available, in particular to waste operators and consumers' and that stakeholders report low use; low use is not evidence that the information is useless to sorters.","materialStatus":"article","note":null,"passage":"(5) The database established pursuant to Article 9(2) of Directive 2008/98/EC [...] was devised to enhance transparency and provide comprehensive access to information on hazardous substances in products. [...] it is estimated that the database in its current form is not fulfilling its intended objectives. [...] ensure that any supplier of an article as defined in Article 3, point 33 of Regulation (EC) No 1907/2006 of the European Parliament and of the Council* provides the information pursuant to Article 33(1) of that Regulation to the European Chemicals Agency from 5 January 2021 until [date of entry into force of this Directive];’ [...] ‘2. The European Chemicals Agency shall maintain the data submitted to it pursuant to paragraph 1, point (ia).’","passageLanguage":"en","passageTranslation":null,"pinpoint":"Recital 5; Article 1, new Article 9(1)(ia) and 9(2) of Directive 2008/98/EC","recipient":"ECHA (and through it waste operators and consumers)","sender":"EU supplier of the article","sourceDate":"2025-12-10","sourceId":"src-65da5292","threshold":null,"timing":"Proposal 10/12/2025; referred to ENVI 09/02/2026; status 'Awaiting committee decision'; indicative plenary sitting date, 1st reading, 14/12/2026","verificationMethod":"Fetched the official proposal text from the Publications Office Cellar. Procedure status fetched from the European Parliament Legislative Observatory: https://oeil.europarl.europa.eu/oeil/en/procedure-file?reference=2025/0394(COD)."},{"claim":"Since 10 October 2026, REACH Annex XVII entry 79 (Commission Regulation (EU) 2024/2462) bars placing on the market textiles in clothing for the general public with 25 ppb or more of PFHxA (perfluorohexanoic acid) and its salts, or 1,000 ppb or more of PFHxA-related substances, measured in homogeneous material; the recitals name rain jackets. Jackets already placed on the market before that date are exempt, so the placing-on-the-market date becomes evidence the brand may need. The entry imposes no labelling or information duty.","claimType":"legal","conditions":"Textiles in clothing for the general public placed on the market or used","confidence":"high","contrary":null,"decisionSupported":"Whether the jacket may be placed on the EU market (importer or brand; market surveillance authorities)","documentRef":"Regulation (EU) 2024/2462, Annex (entry 79), paragraphs 1 and 7; recitals 15 and 25","exemptions":"Personal protective equipment within risk category III points (a), (c) to (f), (h) and (l) of Annex I to Regulation (EU) 2016/425; medical devices; construction textiles (paragraph 3). Articles placed on the market before 10 October 2026 (paragraph 7), where the supplier can demonstrate this (recital 25)","fields":["result","chemical","record"],"handovers":["h3","h4"],"id":"LAW-16","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"A restriction, not an information duty: nothing requires a declaration, test report or label to pass to any downstream actor. Recital 7 records RAC's note that standard analytical methods 'are required to be developed'. PFHxA-related substances are defined by their potential to degrade to PFHxA (paragraph 9), which is why C6 fluorotelomer chemistry is in scope; that chemistry link is for R3 to evidence.","materialStatus":"article","note":null,"passage":"Shall not, from 10 October 2026 be placed on the market, or used, in a concentration equal to or greater than 25 ppb for the sum of PFHxA and its salts, or 1 000 ppb for the sum of PFHxA-related substances, measured in homogeneous material, in the following: (a) textiles, leather, furs and hides in clothing and related accessories for the general public; [...] By way of derogation from paragraph 1, that paragraph shall not apply to articles and mixtures which were placed on the market before 10 October 2026. [Recital 15:] textiles, leather, furs and hides in clothing (such as outdoor clothing like rain jackets) [Recital 25:] The restriction should not apply to articles and mixtures for which the supplier can demonstrate that such articles and mixtures were placed on the market prior to the respective date of application of the restriction, for practicality and enforceability reasons.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Annex, entry 79, paragraphs 1(a) and 7; recitals 15 and 25","recipient":null,"sender":null,"sourceDate":"2024-09-19","sourceId":"src-3abba0ad","threshold":"25 ppb for the sum of PFHxA and its salts, or 1 000 ppb for the sum of PFHxA-related substances, measured in homogeneous material","timing":"Clothing textiles from 10 October 2026; other textiles for the general public from 10 October 2027","verificationMethod":"Fetched the official text (CELEX 32024R2462) from the Publications Office Cellar; confirmed unchanged in consolidated REACH of 22 June 2026."},{"claim":"The EU-wide 'universal' PFAS restriction is still a proposal. ECHA's Risk Assessment Committee (RAC) adopted its final opinion on 2 March 2026 and the consultation on the Socio-Economic Analysis Committee (SEAC) draft opinion ran from 26 March to 25 May 2026. SEAC is expected to adopt its final opinion by the end of 2026, after which the Commission will propose a restriction for a vote by Member States in the REACH Committee.","claimType":"proposal","conditions":null,"confidence":"high","contrary":null,"decisionSupported":null,"documentRef":"ECHA restriction process 100.308.021 (PFAS), SEAC draft opinion consultation information note","exemptions":null,"fields":["chemical","result"],"handovers":["h3","h4"],"id":"LAW-17","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"proposal","limitations":"No adoption date exists. Any final text could differ from the RAC and SEAC opinions. Submitted by Germany, Denmark, the Netherlands, Norway and Sweden.","materialStatus":"substance","note":null,"passage":"The consultation on this proposed restriction will start on 26 March 2026 and end on 25 May 2026 at 23h59 (local time in Helsinki). [...] The Committee is expected to adopt its final opinion by the end of 2026. This adoption will conclude the scientific evaluation of the proposed restriction by ECHA's Committees and the opinions will be formally submitted to the European Commission. Based on the two final opinions, the Commission will propose a restriction for discussion and vote in the REACH Committee, composed of EU Member States.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Information note, first paragraph and 'Next steps'","recipient":null,"sender":null,"sourceDate":"2026-03-26","sourceId":"src-984dc954","threshold":null,"timing":"Intention 15-Jul-2021; submission 13-Jan-2023; RAC final opinion 02-Mar-2026; SEAC draft agreed 10 March 2026; consultation 26-Mar-2026 to 25-May-2026 (current stage on ECHA CHEM at 23 October 2026); SEAC final opinion expected by end of 2026; then Commission proposal and REACH Committee vote","verificationMethod":"Fetched the official ECHA PDF via the ECHA CHEM document API; milestones re-checked on 23 October 2026 via https://chem.echa.europa.eu/api-activity-list/v1/restrictionProcess/100.308.021/details?caseCode=90261f0ec4fde13102704a507698a6e6 (caseStatus 'Ongoing', currentStage 'Restriction start consultation on SEAC draft opinion')."},{"claim":"Under RAC's recommended conditions, the universal restriction would set limits of 25 ppb for any single PFAS by targeted analysis, 250 ppb for the sum of targeted PFAS, and 50 ppm for total PFAS including polymers, applying 18 months after entry into force. Where total fluorine exceeds 50 mg F/kg, the manufacturer, importer or downstream user would owe proof of the fluorine's origin to enforcement authorities on request. The only consumer statement, 'This product contains PFAS', is reserved for products that keep using PFAS under a derogation, and consumer apparel has none, so for this jacket the proposal would work as a ban without a label.","claimType":"proposal","conditions":null,"confidence":"high","contrary":null,"decisionSupported":"An authority's decision whether high total fluorine in a product comes from PFAS","documentRef":"RAC opinion, Table 2 (Restriction proposed by RAC), paragraphs 2, 3 and 8(a)","exemptions":"Derogations listed in RAC Table 2, paragraphs 5 and 6, include PPE and some technical textiles and, for a period, textile articles containing recovered material; no derogation for consumer apparel","fields":["result","chemical","record"],"handovers":["h3","h4"],"id":"LAW-18","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"proposal","limitations":"RAC's view, not adopted law; SEAC and the Commission may change the conditions. That consumer apparel has no derogation is read from the derogation list (searched for 'apparel', 'clothing' and 'textile') and from SEAC's apparel assessment (LAW-19).","materialStatus":"article","note":null,"passage":"iii. 50 ppm for total PFASs (polymeric PFASs included). If total fluorine exceeds 50 mg F/kg the manufacturer, importer or downstream user shall upon request to the enforcement authorities provide a proof for the fluorine measured (as content of either PFASs or non-PFASs). 3. Paragraphs 1 and 2 shall apply 18 months from entry into force of the restriction. [...] 8. a) Suppliers of PFAS or PFAS-containing mixtures or articles for an application with continued use of PFAS by way of a derogation from paragraph 1 and 2 shall provide from (EiF + 18 months): i. the statement “This product contains PFAS”","passageLanguage":"en","passageTranslation":null,"pinpoint":"Table 2, Column 2, paragraphs 2(iii), 3 and 8(a)(i), pp. 9-10","recipient":"Enforcement authorities, on request only","sender":"Manufacturer, importer or downstream user","sourceDate":"2026-03-02","sourceId":"src-69e1b93b","threshold":"i. 25 ppb for any PFAS as measured with targeted PFAS analysis (polymeric PFASs excluded from quantification) ii. 250 ppb for the sum of PFASs [...] iii. 50 ppm for total PFASs (polymeric PFASs included); total fluorine trigger 50 mg F/kg","timing":"18 months after entry into force (not yet adopted)","verificationMethod":"Fetched the official ECHA PDF via the ECHA CHEM document API and extracted the text locally. Table 2 is set in two columns; the passage joins the Column 2 lines in reading order."},{"claim":"SEAC's draft assessment names jackets as consumer apparel, lists fluorine-free alternatives in general practical use (dendrimers, hybrid silicone/hydrocarbons, hydrocarbons, polyurethane, silicones), and concludes there is 'overwhelming evidence' against claims that PFAS cannot be replaced in consumer apparel, with high substitution potential at entry into force.","claimType":"proposal","conditions":null,"confidence":"high","contrary":null,"decisionSupported":null,"documentRef":"SEAC draft TULAC evaluation, section B 'Consumer apparel'","exemptions":null,"fields":["chemical"],"handovers":["h1","h3"],"id":"LAW-19","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"proposal","limitations":"A draft committee assessment, open to change after consultation. 'Substitution potential' is about technical feasibility, not about whether a given jacket is fluorine-free. RAC's TULAC evaluation separately finds consumer apparel is 'the sub-use resulting with the highest emissions of PFAA/PFAA precursors' (rest_pfas_02_tulac_rac_en.pdf, p. 37).","materialStatus":"mixture","note":null,"passage":"The category consumer apparel includes outdoor wear, indoor wear, sportswear, footwear and accessories. Example products are (down) jackets, coats, ski wear, hats and shoes. [...] While some stakeholders maintain that alternatives cannot replace PFAS in consumer apparel, there is overwhelming evidence to the contrary. [...] SEAC agrees with the assessment carried out by the Dossier Submitter and consequently also the conclusion that there is sufficiently strong evidence for high substitution potential at entry into force for this use.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Section B 'Consumer apparel', pp. 11-12","recipient":null,"sender":null,"sourceDate":"2026-03-10","sourceId":"src-a399f85c","threshold":null,"timing":null,"verificationMethod":"Fetched the official ECHA PDF via the ECHA CHEM document API and extracted the text locally."},{"claim":"RAC agrees that mechanical recycling does not destroy PFAS and that only mixing with virgin, PFAS-free fibre lowers their concentration in recycled products. It notes that many PFAS-treated consumer textiles may enter normal textile recycling, and that no data exist on PFAS exposure of workers in textile recycling.","claimType":"technical","conditions":null,"confidence":"high","contrary":null,"decisionSupported":null,"documentRef":"RAC opinion, section on waste streams, 'Textiles'","exemptions":null,"fields":["chemical","result","handling"],"handovers":["h5","h6"],"id":"LAW-20","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":null,"limitations":"A committee's assessment of the literature, not a measurement of any garment. It explains why recycled-content derogations exist in the RAC proposal and in the French decree (LAW-23). Second-life detail is for R4.","materialStatus":"waste","note":null,"passage":"many PFAS-treated textiles e.g. from consumer uses may enter the normal textile recycling processes. [...] RAC agrees with the Dossier Submitter that mechanical recycling does not destroy PFAS and only mixing with virgin (non-PFAS containing) fibres can decrease their concentration in products made of recycled material. [...] RAC notes that there is, however, no actual data available on occupational exposure in textile recycling.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Waste streams, 'Textiles', pp. 73-74","recipient":null,"sender":null,"sourceDate":"2026-03-02","sourceId":"src-69e1b93b","threshold":null,"timing":null,"verificationMethod":"Fetched the official ECHA PDF via the ECHA CHEM document API and extracted the text locally."},{"claim":"Since 1 January 2026, French law bans the manufacture, import, export and placing on the market of clothing textiles for consumers that contain PFAS (Loi n° 2025-188, Code de l'environnement Article L. 524-1). All textiles follow from 1 January 2030, with listed exceptions. Products below a residual value set by decree are outside the ban.","claimType":"legal","conditions":null,"confidence":"medium","contrary":null,"decisionSupported":"Whether the jacket may be made, imported, exported or sold in France","documentRef":"Code de l'environnement, Article L. 524-1 I 3°, II and III (created by Loi n° 2025-188)","exemptions":"Clothing and footwear designed for the protection and safety of persons, listed by decree (D. 525-2; see LAW-23)","fields":["chemical","result"],"handovers":["h1","h3","h4"],"id":"LAW-21","jurisdiction":"France","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"A ban, not an information duty: the law requires no label, declaration or data transfer. The ban also covers export, so it reaches French exporters but not a Vietnamese factory. Waterproofing agents sold to consumers are banned, but agents sold to industrial finishers abroad are outside French jurisdiction. No amendment or court challenge was found, but Legifrance could not be checked directly.","materialStatus":"article","note":null,"passage":"« Art. L. 524-1. I. Sont interdites, à compter du 1er janvier 2026, la fabrication, l'importation, l'exportation et la mise sur le marché à titre onéreux ou gratuit de : [...] « 3° Tout produit textile d'habillement, toute chaussure et tous agents imperméabilisants de produits textiles d'habillement et de chaussures destinés aux consommateurs contenant des substances perfluoroalkylées et polyfluoroalkylées, à l'exception des textiles d'habillement et des chaussures qui sont conçus pour la protection et la sécurité des personnes, notamment dans l'accomplissement des missions de défense nationale ou de sécurité civile, et dont la liste est précisée par décret. [...] « III. Les interdictions prévues aux I et II ne s'appliquent pas aux produits contenant des substances perfluoroalkylées et polyfluoroalkylées présentes en concentration inférieure ou égale à une valeur résiduelle définie par décret.","passageLanguage":"fr","passageTranslation":"Art. L. 524-1. I. From 1 January 2026, the manufacture, import, export and placing on the market, for payment or free of charge, of the following are prohibited: [...] 3° Any clothing textile product, any footwear and any waterproofing agents for clothing textile products and footwear intended for consumers that contain per- and polyfluoroalkyl substances, except clothing textiles and footwear designed for the protection and safety of persons, in particular in carrying out national defence or civil security missions, the list of which is specified by decree. [...] III. The prohibitions in I and II do not apply to products containing per- and polyfluoroalkyl substances present at a concentration less than or equal to a residual value defined by decree.","pinpoint":"Code de l'environnement, Article L. 524-1 I 3° and III","recipient":null,"sender":null,"sourceDate":"2025-02-27","sourceId":"src-b75df2ff","threshold":"Residual value set by decree (D. 525-4; see R1-022)","timing":"Clothing textiles, footwear and their waterproofing agents for consumers: from 1 January 2026. All textile products: from 1 January 2030","verificationMethod":"Fetched the AIDA (INERIS, French Ministry of Ecological Transition) reproduction of the official text; Legifrance returned HTTP 403 to automated requests, so the Legifrance version was not fetched directly. Wording matches the AIDA consolidated Code de l'environnement (Livre V, partie législative)."},{"claim":"France's implementing decree defines PFAS as a group, any substance with at least one fully fluorinated CF3 or CF2 carbon, the same structural definition RAC uses. It sets the residual values at 25 ppb for any single PFAS and 250 ppb for the sum of targeted PFAS (both excluding polymers), and 50 ppm for PFAS including polymers. Where total fluorine exceeds 50 mg F/kg, the person placing the product on the market must prove to the authorities, on request, whether that fluorine comes from PFAS.","claimType":"legal","conditions":null,"confidence":"medium","contrary":null,"decisionSupported":"An authority's decision whether a product with high total fluorine breaches the French ban","documentRef":"Décret n° 2025-1376, Article 1, creating Code de l'environnement Articles D. 525-1 and D. 525-4","exemptions":null,"fields":["chemical","result","record"],"handovers":["h3","h4"],"id":"LAW-22","jurisdiction":"France","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"The decree specifies limits but no test method or reporting limit. A group definition is not a substance identity: a compliant result says the jacket is below limits, not what chemistry the finish uses. Proof flows to authorities only, not to retailers, consumers or sorters.","materialStatus":"article","note":null,"passage":"« “Substances perfluoroalkylées et polyfluoroalkylées” : toute substance contenant au moins un atome de carbone méthyle (CF3-) ou méthylène (-CF2-) entièrement fluoré, sans atomes d'hydrogène, de chlore, de brome ou d'iode rattaché. [...] « Art. D. 525-4. La valeur résiduelle prévue au III de l'article L. 524-1 est fixée selon les conditions suivantes : « - pour tout PFAS mesuré par une analyse ciblée, à l'exclusion des polymères, le seuil est fixé à 25 ppb ; « - pour la somme des PFAS mesurée comme la somme des analyses ciblées des PFAS, le cas échéant avec une dégradation préalable des précurseurs, à l'exclusion des polymères, le seuil est fixé à 250 ppb ; « - pour les PFAS incluant les polymères le seuil est fixé à 50 ppm. Dans le cas où la mesure de fluor total dépasserait 50 mg F/kg, le fabricant, l'importateur, l'exportateur ou le metteur sur le marché fournit à la demande des autorités compétentes une preuve que la teneur en fluor provient de substances PFAS ou non PFAS.","passageLanguage":"fr","passageTranslation":"'Per- and polyfluoroalkyl substances': any substance containing at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom, without hydrogen, chlorine, bromine or iodine atoms attached. [...] Art. D. 525-4. The residual value provided for in III of Article L. 524-1 is set under the following conditions: - for any PFAS measured by targeted analysis, excluding polymers, the threshold is 25 ppb; - for the sum of PFAS measured as the sum of targeted PFAS analyses, where appropriate with prior degradation of precursors, excluding polymers, the threshold is 250 ppb; - for PFAS including polymers the threshold is 50 ppm. Where the total fluorine measurement exceeds 50 mg F/kg, the manufacturer, importer, exporter or person placing on the market shall provide, at the request of the competent authorities, proof that the fluorine content comes from PFAS or non-PFAS substances.","pinpoint":"Code de l'environnement, Articles D. 525-1 and D. 525-4","recipient":"Competent French authorities, on request only","sender":"Manufacturer, importer, exporter or person placing on the market","sourceDate":"2025-12-28","sourceId":"src-9b70ac55","threshold":"25 ppb (any PFAS, targeted analysis, excluding polymers); 250 ppb (sum of targeted PFAS, with prior precursor degradation where appropriate, excluding polymers); 50 ppm (PFAS including polymers); total fluorine trigger 50 mg F/kg","timing":"In force 1 January 2026; values 'ont vocation à être révisées' if EU technical rules change","verificationMethod":"Fetched the AIDA (INERIS, French Ministry of Ecological Transition) reproduction of the official text; Legifrance returned HTTP 403 to automated requests, so the Legifrance version was not fetched directly."},{"claim":"France exempts clothing and footwear containing at least 20% recycled material from post-consumer waste, provided any PFAS in the finished product is limited to the recycled fraction. The exemption only works if someone can show the recycled share and where the PFAS came from, information that originates at the sorting and recycling stages.","claimType":"legal","conditions":null,"confidence":"medium","contrary":null,"decisionSupported":"Whether a garment with recycled content and residual PFAS may be sold in France","documentRef":"Décret n° 2025-1376, Article 1, creating Code de l'environnement Article D. 525-2 3°","exemptions":null,"fields":["record","chemical"],"handovers":["h6","h3"],"id":"LAW-23","jurisdiction":"France","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"The decree does not say what evidence proves recycled origin or attributes PFAS to the recycled fraction. The interpretation that this needs information from H6 is ours. RAC's proposal has a parallel time-limited derogation for textile articles containing recovered material.","materialStatus":"article","note":null,"passage":"« 3° Les textiles d'habillement et chaussures incorporant au moins vingt pour cent (20 %) de matière recyclée issue de déchets post-consommation. La présence de substances perfluoroalkylées et polyfluoroalkylées dans le produit fini est limitée à la fraction de matière recyclée, de sorte que la quantité de PFAS résiduelle admissible dans le produit fini est proportionnelle à la proportion de matière recyclée incorporée.","passageLanguage":"fr","passageTranslation":"3° Clothing textiles and footwear incorporating at least twenty per cent (20%) recycled material from post-consumer waste. The presence of per- and polyfluoroalkyl substances in the finished product is limited to the recycled material fraction, so that the permissible residual quantity of PFAS in the finished product is proportional to the proportion of recycled material incorporated.","pinpoint":"Code de l'environnement, Article D. 525-2 3° (same wording in D. 525-3 3°)","recipient":"French competent authorities (if challenged)","sender":"Recycler and fibre supplier (evidence of recycled origin), then the person placing on the market","sourceDate":"2025-12-28","sourceId":"src-9b70ac55","threshold":"au moins vingt pour cent (20 %) de matière recyclée issue de déchets post-consommation","timing":"From 1 January 2026 (and for the 2030 stage, Article D. 525-3 3°)","verificationMethod":"Fetched the AIDA (INERIS, French Ministry of Ecological Transition) reproduction of the official text; Legifrance returned HTTP 403 to automated requests, so the Legifrance version was not fetched directly."},{"claim":"Clothing containing PFAS that was manufactured before 1 January 2026 may be placed on the French market or exported for at most twelve months from that date. The sell-off window closes on 31 December 2026, and the manufacturing date becomes the evidence that matters.","claimType":"legal","conditions":null,"confidence":"medium","contrary":null,"decisionSupported":"Whether old stock may still be sold or exported","documentRef":"Décret n° 2025-1376, Article 2","exemptions":null,"fields":["record"],"handovers":["h3","h4"],"id":"LAW-24","jurisdiction":"France","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"The decree uses the date of manufacture; the EU PFHxA rule uses the date of placing on the market (LAW-16). The two date tests differ, so one jacket can need two dated records.","materialStatus":"article","note":null,"passage":"Les produits mentionnés au I de l'article L. 524-1 du code de l'environnement contenant des PFAS et fabriqués avant le 1er janvier 2026 peuvent être mis sur le marché ou exportés pendant une durée maximale de douze mois à compter de cette date. A l'issue de ce délai, toute mise sur le marché ou exportation de ces produits est interdite.","passageLanguage":"fr","passageTranslation":"Products mentioned in I of Article L. 524-1 of the Environmental Code containing PFAS and manufactured before 1 January 2026 may be placed on the market or exported for a maximum period of twelve months from that date. At the end of that period, any placing on the market or export of these products is prohibited.","pinpoint":"Décret n° 2025-1376, Article 2","recipient":"French competent authorities (if checked)","sender":"Person placing on the market","sourceDate":"2025-12-28","sourceId":"src-9b70ac55","threshold":null,"timing":"Sell-off ends twelve months after 1 January 2026 (that is, by 31 December 2026)","verificationMethod":"Fetched the AIDA (INERIS, French Ministry of Ecological Transition) reproduction of the official text; Legifrance returned HTTP 403 to automated requests, so the Legifrance version was not fetched directly."},{"claim":"Under France's anti-waste law (AGEC, Code de l'environnement L. 541-9-1 and R. 541-227 to R. 541-229), producers and importers with over EUR 10 million turnover and at least 10,000 units a year must publish a free, machine-readable 'fiche produit' for each new consumer product, accessible at the time of purchase. Information on hazardous substances may instead be given through an app designated by ministerial order, and the sheet must stay available for two years after the last unit is placed on the market.","claimType":"legal","conditions":"New products sold to consumers; sales between professionals are outside the scope (Ministry FAQ, November 2025)","confidence":"medium","contrary":null,"decisionSupported":"Comparing products' environmental characteristics at purchase","documentRef":"Code de l'environnement, Articles R. 541-227 (third paragraph) and R. 541-229","exemptions":null,"fields":["chemical","component","record"],"handovers":["h4"],"id":"LAW-25","jurisdiction":"France","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"The sheet is online, not on the garment; the sewn-in label need not point to it. The FAQ says the designated app is Scan4Chem, backed by the EU LIFE AskREACH database. Smaller brands below the thresholds are outside the duty. Second-hand products sold by professionals are outside it (FAQ 1.1.3), so the sheet does not follow the jacket into resale.","materialStatus":"article","note":null,"passage":"« Sont soumis à l'obligation d'information ainsi définie les producteurs, importateurs ou tout autre metteur sur le marché déclarant, pour les produits mentionnés à l'article R. 541-228 qu'ils mettent sur le marché national, un chiffre d'affaire supérieur à 10 millions d'euros et sont responsables annuellement de la mise sur le marché national d'au moins 10 000 unités de ces produits. » [...] Cette mise à disposition se fait sous un format dématérialisé, accessible sans frais au moment de l'acte d'achat et réutilisable de façon à permettre une agrégation. [...] « Toutefois, pour les substances visées au IX de l'article R. 541-228, cette mise à disposition de l'information peut être réalisée au moyen d'une application désignée par arrêté du ministre chargé de l'environnement. [...] « L'obligation de mise à disposition des informations mentionnées à l'article R. 541-228 demeure applicable pendant deux ans après la mise sur le marché de la dernière unité du produit concerné.","passageLanguage":"fr","passageTranslation":"Producers, importers or any other person placing on the market who declare, for the products mentioned in Article R. 541-228 that they place on the national market, a turnover above EUR 10 million and who are responsible each year for placing at least 10,000 units of these products on the national market are subject to the information obligation thus defined. [...] This information is made available in a dematerialised format, accessible free of charge at the time of purchase and reusable so as to allow aggregation. [...] However, for the substances referred to in IX of Article R. 541-228, the information may be made available by means of an application designated by order of the minister responsible for the environment. [...] The obligation to make the information mentioned in Article R. 541-228 available remains applicable for two years after the last unit of the product concerned is placed on the market.","pinpoint":"Code de l'environnement, Article R. 541-227, third paragraph; Article R. 541-229, first, second and fourth paragraphs","recipient":"Consumers, and the public, via a dedicated web page or the designated app","sender":"Producer, importer or other person placing on the French market (a retailer with its own brand counts as producer)","sourceDate":"2024-04-05","sourceId":"src-bfa1a9a2","threshold":"un chiffre d'affaire supérieur à 10 millions d'euros [...] au moins 10 000 unités","timing":"Phased in from 1 January 2023; EUR 10 million / 10,000-unit threshold from 1 January 2025 (Décret n° 2022-748, Article 3)","verificationMethod":"Fetched the AIDA (INERIS, French Ministry of Ecological Transition) reproduction of the official text; Legifrance returned HTTP 403 to automated requests, so the Legifrance version was not fetched directly (consolidated Code, including renumbering by Décret n° 2024-316). Scope and Scan4Chem points cross-checked in the Ministry FAQ, November 2025: https://www.ecologie.gouv.fr/sites/default/files/documents/FAQ_article_13-I_AGEC_version-novembre_2025_vF_FR.pdf (sections 1.1.3 and 2.8.2)."},{"claim":"Where a hazardous substance is present above 0.1% by mass, the French product sheet must state 'contient une substance dangereuse' or, for a Candidate List substance, 'contient une substance extrêmement préoccupante', followed by the name of each substance. This turns REACH's on-request consumer right into published information for in-scope products.","claimType":"legal","conditions":null,"confidence":"medium","contrary":null,"decisionSupported":"Whether to buy a product that contains an SVHC or other listed hazardous substance","documentRef":"Code de l'environnement, Article R. 541-228 IX","exemptions":null,"fields":["chemical"],"handovers":["h4"],"id":"LAW-26","jurisdiction":"France","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"Same 0.1% trigger and same substance list as REACH Article 33 (LAW-27), so PFHxA and most PFAS do not trigger it. The Ministry FAQ says the obligation applies to the product as a whole rather than each component (section 1.1.4), while IX refers to 'un article' in the REACH sense; how this sits with C-106/14 is unresolved in the sources read.","materialStatus":"article","note":null,"passage":"« IX. L'information du consommateur relative à la présence d'une substance dangereuse s'applique dès lors que celle-ci est présente en concentration supérieure à 0,1 % en pourcentage massique dans une substance, un mélange ou un article, au sens des points 1, 2 et 3 de l'article 3 du règlement (CE) n° 1907/2006 [...] « Cette information est exprimée sous la forme de la mention “ contient une substance dangereuse ” ou, lorsque la substance dangereuse présente est contenue dans la liste mentionnée au paragraphe 1 de l'article 59 du règlement (CE) n° 1907/2006 du 18 décembre 2006 précité et publiée en vertu du paragraphe 10 de cet article 59, sous la forme de la mention “ contient une substance extrêmement préoccupante ”. L'information est complétée du nom de chacune des substances dangereuses présentes. [...] « La mise à disposition de l'information est réalisée au plus tard six mois après l'identification de la substance en tant que substance dangereuse.","passageLanguage":"fr","passageTranslation":"IX. Consumer information on the presence of a hazardous substance applies where it is present at a concentration above 0.1% by mass in a substance, a mixture or an article, within the meaning of points 1, 2 and 3 of Article 3 of Regulation (EC) No 1907/2006 [...] This information is expressed as the statement 'contains a hazardous substance' or, where the hazardous substance present is on the list referred to in Article 59(1) of Regulation (EC) No 1907/2006 and published under Article 59(10), as the statement 'contains a substance of very high concern'. The information is supplemented by the name of each hazardous substance present. [...] The information shall be made available no later than six months after the substance is identified as a hazardous substance.","pinpoint":"Code de l'environnement, Article R. 541-228 IX","recipient":"Consumer, at purchase, via the product sheet or Scan4Chem","sender":"Producer or importer (in scope per LAW-25)","sourceDate":"2024-04-05","sourceId":"src-bfa1a9a2","threshold":"concentration supérieure à 0,1 % en pourcentage massique dans une substance, un mélange ou un article","timing":"Within six months of a substance being identified as hazardous","verificationMethod":"Fetched the AIDA (INERIS, French Ministry of Ecological Transition) reproduction of the official text; Legifrance returned HTTP 403 to automated requests, so the Legifrance version was not fetched directly."},{"claim":"France's 'hazardous substances' for AGEC are the Candidate List SVHCs plus substances of comparable concern listed by ministerial order. The only order found (30 August 2023) adds two substances, DIOP and resorcinol, so French consumer disclosure adds no PFAS beyond those on the Candidate List.","claimType":"legal","conditions":null,"confidence":"medium","contrary":null,"decisionSupported":null,"documentRef":"Décret n° 2021-1285, Article 1; Arrêté du 30 août 2023 relatif à l'identification des substances dangereuses dans les produits générateurs de déchets, Annex","exemptions":null,"fields":["chemical"],"handovers":["h4"],"id":"LAW-27","jurisdiction":"France","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"A later order adding substances could exist; none was found on AIDA, and Legifrance could not be searched.","materialStatus":"substance","note":null,"passage":"Les substances dangereuses mentionnées à l'article L. 541-9-1 du code de l'environnement sont les substances suivantes : - substances extrêmement préoccupantes inscrites sur la liste mentionnée à l'article 59, paragraphe 1, du règlement (CE) n° 1907/2006 et publiée conformément à l'article 59, paragraphe 10, du règlement (CE) n° 1907/2006 ; - substances présentant un niveau de préoccupation comparable aux substances extrêmement préoccupantes qui ne sont pas sur la liste mentionnée à l'article 59, paragraphe 1, du règlement (CE) n° 1907/2006. La liste de ces substances et sa mise à jour sont fixées par arrêté du ministre chargé de l'environnement après avis de l'Agence nationale de sécurité sanitaire de l'alimentation, de l'environnement et du travail. [Arrêté du 30 août 2023, annex:] Phtalate de diisooctyle (DIOP) 27554-26-3 [...] 1,3-benzènediol (résorcinol) 108-46-3","passageLanguage":"fr","passageTranslation":"The hazardous substances mentioned in Article L. 541-9-1 of the Environmental Code are: - substances of very high concern included in the list referred to in Article 59(1) of Regulation (EC) No 1907/2006 and published in accordance with Article 59(10); - substances with a level of concern comparable to substances of very high concern that are not on that list. The list of these substances and its updates are set by order of the minister responsible for the environment after an opinion from ANSES (the national agency for food, environmental and occupational health safety). [Order of 30 August 2023, annex:] Diisooctyl phthalate (DIOP) 27554-26-3 [...] 1,3-benzenediol (resorcinol) 108-46-3","pinpoint":"Décret n° 2021-1285, Article 1; Arrêté du 30 août 2023 (JO n° 213 du 14 septembre 2023), annex","recipient":null,"sender":null,"sourceDate":"2021-10-01","sourceId":"src-34a20747","threshold":null,"timing":null,"verificationMethod":"Fetched the AIDA (INERIS, French Ministry of Ecological Transition) reproduction of the official text; Legifrance returned HTTP 403 to automated requests, so the Legifrance version was not fetched directly. Arrêté read at https://aida.ineris.fr/reglementation/arrete-300823-relatif-a-lidentification-substances-dangereuses-produits-generateurs."},{"claim":"For clothing sold in France, the AGEC product sheet must name the country where each of three steps mainly took place: weaving, dyeing and printing, and making-up. For this jacket that would show Vietnam (in the scenario), but finishing, including the water-repellent treatment, is not a named step, so the place where the DWR chemistry was applied need not be disclosed.","claimType":"legal","conditions":"Products in Code de l'environnement L. 541-10-1 11° (consumer clothing, footwear, household linen)","confidence":"medium","contrary":null,"decisionSupported":"Knowing where the garment's main production steps took place","documentRef":"Code de l'environnement, Article R. 541-228 X","exemptions":null,"fields":["record"],"handovers":["h2","h4"],"id":"LAW-28","jurisdiction":"France","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"Country only, not facility. The FAQ (2.9.2) says that where steps differ between textile sub-parts, the country where the largest share of fibre mass is made is given, so a membrane or lining made elsewhere may not appear. That finishing is not covered is a reading of the three named steps.","materialStatus":"article","note":null,"passage":"« X. L'information du consommateur relative à la traçabilité pour les produits mentionnés au 11° de l'article L. 541-10-1 s'entend de l'indication géographique du pays où s'effectue principalement chacune des opérations suivantes, lorsqu'elles existent : « 1° Le tissage ; « 2° La teinture et l'impression ; « 3° La confection. [...] « Cette information est exprimée sous forme de la mention, pour chaque étape, du pays où celle-ci a été réalisée.","passageLanguage":"fr","passageTranslation":"X. Consumer information on traceability for the products mentioned in 11° of Article L. 541-10-1 means the geographical indication of the country where each of the following operations mainly takes place, where they exist: 1° Weaving; 2° Dyeing and printing; 3° Making-up. [...] This information is expressed as a statement, for each stage, of the country where it was carried out.","pinpoint":"Code de l'environnement, Article R. 541-228 X","recipient":"Consumer, at purchase, via the product sheet","sender":"Producer or importer (in scope per LAW-25)","sourceDate":"2024-04-05","sourceId":"src-bfa1a9a2","threshold":null,"timing":null,"verificationMethod":"Fetched the AIDA (INERIS, French Ministry of Ecological Transition) reproduction of the official text; Legifrance returned HTTP 403 to automated requests, so the Legifrance version was not fetched directly. Ministry FAQ (November 2025) section 2.9 consulted on multi-part products."},{"claim":"Where synthetic fibres make up more than 50% of a garment's mass, the French product sheet must carry the statement 'rejette des microfibres plastiques dans l'environnement lors du lavage' (releases plastic microfibres into the environment when washed). A polyester rain jacket meets that condition.","claimType":"legal","conditions":null,"confidence":"medium","contrary":null,"decisionSupported":"Washing and purchase choices with microfibre release in mind","documentRef":"Code de l'environnement, Article R. 541-228 XI","exemptions":null,"fields":["component","handling"],"handovers":["h4"],"id":"LAW-29","jurisdiction":"France","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"It is a fixed statement about microfibres, not about finishes or PFAS. It sits on the online sheet, not necessarily on the label. That the scenario jacket is over 50% synthetic follows from its polyester face fabric; exact composition is an illustrative assumption.","materialStatus":"article","note":null,"passage":"« XI. L'information du consommateur relative à la présence de microfibres plastiques dans les produits mentionnés au 11° de l'article L. 541-10-1, s'entend comme la proportion en masse de fibres synthétiques dans le produit. Cette information est mise à disposition dès lors que la proportion de fibres synthétiques est supérieure à 50 %. « Elle est exprimée sous la forme de la mention “ rejette des microfibres plastiques dans l'environnement lors du lavage ”. »","passageLanguage":"fr","passageTranslation":"XI. Consumer information on the presence of plastic microfibres in the products mentioned in 11° of Article L. 541-10-1 means the proportion by mass of synthetic fibres in the product. This information is made available where the proportion of synthetic fibres exceeds 50%. It is expressed as the statement 'releases plastic microfibres into the environment during washing'.","pinpoint":"Code de l'environnement, Article R. 541-228 XI","recipient":"Consumer, at purchase, via the product sheet","sender":"Producer or importer (in scope per LAW-25)","sourceDate":"2024-04-05","sourceId":"src-bfa1a9a2","threshold":"la proportion de fibres synthétiques est supérieure à 50 %","timing":null,"verificationMethod":"Fetched the AIDA (INERIS, French Ministry of Ecological Transition) reproduction of the official text; Legifrance returned HTTP 403 to automated requests, so the Legifrance version was not fetched directly."},{"claim":"A French law of 8 July 2026 (Loi n° 2026-602) requires the places of manufacture of clothing sold online to be shown clearly on the platform, in type the same size as the price and next to it.","claimType":"legal","conditions":null,"confidence":"medium","contrary":null,"decisionSupported":"Choosing a garment with knowledge of where it was made","documentRef":"Loi n° 2026-602, Article 2, creating Code de l'environnement Article L. 541-9-1-2","exemptions":null,"fields":["record"],"handovers":["h4"],"id":"LAW-30","jurisdiction":"France","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"'Lieux de fabrication' is not defined in the article; whether it means countries or sites, and which steps, is unresolved. Applies to online sales only. Whether the European Commission was notified or enforcement has begun was not checked.","materialStatus":"article","note":null,"passage":"« Art. L. 541-9-1-2. Les lieux de fabrication du produit mentionné au 11° de l'article L. 541-10-1 vendu en ligne doivent être portés à la connaissance du consommateur de manière claire et lisible sur la plateforme numérique, en caractères d'une taille égale à celle de l'indication du prix et à proximité de celui-ci. »","passageLanguage":"fr","passageTranslation":"Art. L. 541-9-1-2. The places of manufacture of the product mentioned in 11° of Article L. 541-10-1 sold online must be brought to the consumer's attention clearly and legibly on the digital platform, in characters of a size equal to that of the price indication and close to it.","pinpoint":"Loi n° 2026-602, Article 2","recipient":"Consumer buying online","sender":"Online seller or platform (the article does not name the duty holder)","sourceDate":"2026-07-08","sourceId":"src-2cf735e8","threshold":null,"timing":"Article 2 sets no deferred date (other articles of the law carry dates of 1 September 2026 and 1 January 2027)","verificationMethod":"Fetched the AIDA (INERIS, French Ministry of Ecological Transition) reproduction of the official text; Legifrance returned HTTP 403 to automated requests, so the Legifrance version was not fetched directly."},{"claim":"The Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) requires future product rules to let 'substances of concern' be tracked through the product's life: name, location in the product, concentration or range, safe-use instructions and end-of-life information, given on the product or through a data carrier on it. 'Substance of concern' is wider than the Candidate List, covering certain hazard classes, persistent organic pollutants and substances that hinder reuse and recycling. None of this binds a jacket until a textile delegated act is adopted.","claimType":"legal","conditions":"Only once a product-specific delegated act is adopted under Article 4; the Commission may set thresholds and justified exemptions, but not for Candidate List SVHCs (Article 7(6)(b))","confidence":"high","contrary":null,"decisionSupported":"Safe use, sorting, reuse and recycling decisions down the life cycle","documentRef":"Regulation (EU) 2024/1781, Articles 2(27), 7(5) and 7(7)","exemptions":null,"fields":["chemical","result","handling","component"],"handovers":["h3","h4","h5","h6"],"id":"LAW-31","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"future","limitations":"A framework duty only. Whether PFAS used in DWR would count as substances of concern depends on classification and on the delegated act; the act could set thresholds and exemptions. A data carrier on a removable tag may not survive to the sorter.","materialStatus":"article","note":null,"passage":"the information requirements shall make it possible to track the substances of concern, throughout the life cycle of the products concerned, [...] and shall include at least the following: (a) the name or numerical code of the substances of concern present in the product, [...] (b) the location of the substances of concern within the product; (c) the concentration, maximum concentration or concentration range of the substances of concern, at the level of the product, its relevant components, or spare parts; (d) relevant instructions for the safe use of the product; (e) information relevant for disassembly, preparation for reuse, reuse, recycling and the environmentally sound management of the product at end-of-life. [...] Information that makes it possible to track substances of concern pursuant to paragraph 5 shall be given either on the product or be accessible through a data carrier included on the product. [Article 2(27):] (c) is regulated under Regulation (EU) 2019/1021; or (d) negatively affects the reuse and recycling of materials in the product in which it is present;","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 7(5), Article 7(7) final subparagraph, Article 2(27)(c) and (d)","recipient":"Consumers, repairers, sorters, recyclers and authorities, according to access rights set in the delegated act","sender":"Manufacturer or importer placing the product on the market (under a future delegated act)","sourceDate":"2024-06-28","sourceId":"src-791450bd","threshold":null,"timing":null,"verificationMethod":"Fetched official consolidated text from the EU Publications Office (Cellar content negotiation); the EUR-Lex web front end blocked automated requests."},{"claim":"The Commission's first ESPR working plan (April 2025) ranks textiles and apparel first among final products, with indicative adoption of the delegated act in 2027, and says its information requirements will work with the Textile Labelling Regulation, then under review.","claimType":"proposal","conditions":null,"confidence":"high","contrary":null,"decisionSupported":null,"documentRef":"COM(2025) 187 final, priority table, row 'Textiles/Apparel'","exemptions":null,"fields":["chemical","component"],"handovers":["h3","h4"],"id":"LAW-32","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":null,"limitations":"'Indicative' timing. No draft delegated act or Ecodesign Forum document for textiles was found on the JRC product bureau page at 23 October 2026.","materialStatus":"article","note":null,"passage":"Textiles/Apparel 1st High support EUR 78 billion (out of EUR 142 billion of all textiles and footwear in market size, 2019) High potential to improve product lifetime extension, material efficiency and to reduce impacts on water, waste generation, climate change and energy consumption. Information requirements under the ESPR will work in synergy with the Textile Labelling Regulation, currently under review. 2027","passageLanguage":"en","passageTranslation":null,"pinpoint":"Priority product table, 'Final products', row 'Textiles/Apparel'","recipient":null,"sender":null,"sourceDate":"2025-04-16","sourceId":"src-d1181e6b","threshold":null,"timing":"Indicative adoption 2027; application would follow later","verificationMethod":"Fetched the official text (CELEX 52025DC0187) from the Publications Office Cellar; table cells joined in reading order."},{"claim":"A study for the JRC (13 May 2026) recommends that a textile digital product passport (DPP) give substance-of-concern data per batch, covering all chemicals for every colour in the batch. The substance identity and concentration would be public, while the substance's location in the garment and end-of-life handling information would be limited to actors with a 'legitimate interest'. Substances not intentionally added and absent from the final product would be exempt. It is a recommendation, not a draft act, and it does not mention PFAS.","claimType":"proposal","conditions":null,"confidence":"medium","contrary":null,"decisionSupported":"Sorting, recycling and safe-use decisions by downstream actors (proposed)","documentRef":"JRC study Textiles_DPP_20260513, granularity discussion and Tables 13 and 14","exemptions":"Exempting those that are not intentionally added to the final products and that are not present in the final product but that are related to the life cycle of the products (Table 7)","fields":["chemical","result","handling"],"handovers":["h3","h4","h5","h6"],"id":"LAW-33","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":null,"limitations":"External study for the JRC; the Commission's delegated act may differ. A search of the full text for 'PFAS', 'fluor' and 'water-repell' found no matches. 'Public' access depends on the DPP data carrier staying attached and readable.","materialStatus":"article","note":null,"passage":"Chemical properties might vary significantly even within a batch due to the application of distinct dyes. For these, the minimum recommended level of granularity is batch level, while it should be ensured that all chemicals associated with all possible colours within that batch are included, reflecting a worst-case scenario. [...] Table 14. Proposed level of access rights by data point. [...] Substances of Concern (SoC) Public | Location of the SoC Legitimate interest | Concentration of SoC Public | Relevant instructions for the safe use Public | Information relevant for disassembly, reuse, recycling and management at EoL Legitimate interest","passageLanguage":"en","passageTranslation":null,"pinpoint":"p. 64 (granularity); Table 13 (p. 66); Table 14 (p. 68); Table 7 (p. 48)","recipient":"Public for identity and concentration; actors with legitimate interest for location and end-of-life information; authorities for restricted data (proposed)","sender":"Operator placing the garment on the market (proposed)","sourceDate":"2026-05-13","sourceId":"src-b9cc3aff","threshold":null,"timing":null,"verificationMethod":"Fetched the official JRC PDF from susproc.jrc.ec.europa.eu via WebFetch (direct curl was rejected) and extracted the text locally with pdftotext; table rows transcribed in reading order. The study states it does not necessarily reflect the Commission's position."},{"claim":"Stakeholders interviewed for the JRC study report that apparel brands and retailers rely on supplier declarations, contract terms and third-party certification to support claims that regulated substances are absent. OEKO-TEX Standard 100 is the most cited mechanism and works as a pass or fail against thresholds. Substance-level concentration and location data are not reported and, they say, are not available in a form that could be disclosed reliably.","claimType":"reported-practice","conditions":null,"confidence":"medium","contrary":null,"decisionSupported":"The brand's decision that a product meets restriction limits","documentRef":"JRC study Textiles_DPP_20260513, readiness analysis, 'Regarding information on substances'","exemptions":null,"fields":["record","chemical","result"],"handovers":["h2","h3"],"id":"LAW-34","jurisdiction":"EU (reported practice across global supply chains)","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Stakeholder reports collected by the study, not measured practice; not specific to rain jackets or Vietnam. Pass or fail certification answers 'below the limit?', not 'which substance, how much, where'. Voluntary standards are detailed by the other research packages.","materialStatus":"article","note":null,"passage":"Regarding information on substances, many retailers and other operators placing textile apparel on the market have implemented chemical management strategies to enable compliance and to meet their due-diligence obligations in this regard. These normally rely on supply chain information. In this sense retailers rely on declarations by suppliers, binding contractual terms and third-party certification to support compliance claims related to the absence of regulated / controlled substances. OEKO-TEX Standard 10037 is cited by stakeholders as the most prevalent mechanism for chemical verification across the sector. It provides trusted verification against regulatory thresholds but operate on a binary pass/fail basis. Stakeholders consistently indicated that substance-level concentration and location data are not reported, and noted that such information is unavailable in a form that could be disclosed reliably and proportionately.","passageLanguage":"en","passageTranslation":null,"pinpoint":"p. 31 (readiness analysis); Table 7 'Readiness' column rates substance-of-concern data 'Low – Not current practice' (p. 48)","recipient":"Brands and retailers placing apparel on the EU market","sender":"Suppliers (mills, garment makers) and certification bodies","sourceDate":"2026-05-13","sourceId":"src-b9cc3aff","threshold":null,"timing":null,"verificationMethod":"Fetched the official JRC PDF (see LAW-33) and extracted text locally. '10037' is the standard number followed by footnote marker 37."},{"claim":"The General Product Safety Regulation (GPSR, Regulation (EU) 2023/988), applying since 13 December 2024, requires a consumer product to carry a type, batch or serial number, and the name, postal and electronic address of the manufacturer and, for imports, of the importer, on the product or, where that is not possible, on packaging or an accompanying document. This gives the jacket an identity key back to the operators who hold its records, though it carries no chemical information, and technical documentation goes to authorities only on request.","claimType":"legal","conditions":"Applies only to risks not covered by specific EU product-safety law (Article 2(1)); chemical content is mainly governed by REACH","confidence":"high","contrary":null,"decisionSupported":"Identifying the product and whom to contact about it, including for recalls and complaints","documentRef":"Regulation (EU) 2023/988, Articles 9(3), 9(5), 9(6) and 11(3)","exemptions":null,"fields":["record","component"],"handovers":["h3","h4"],"id":"LAW-35","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"The GPSR does not say whether the identifier goes on the sewn-in label or a removable tag; for a jacket 'on the product' is possible, but practice was not checked. Article 9(3) keeps technical documentation, including test reports, for authorities for 10 years; it does not reach retailers, consumers or sorters.","materialStatus":"article","note":null,"passage":"Manufacturers shall ensure that their products bear a type, batch or serial number or other element enabling the identification of the product and which is easily visible and legible for consumers, or, where the size or nature of the product does not allow it, that the required information is provided on the packaging or in a document accompanying the product. [...] Manufacturers shall indicate their name, their registered trade name or registered trade mark, their postal and electronic address [...] That information shall be placed on the product or, where that is not possible, on its packaging or in a document accompanying the product. [...] Importers shall indicate their name, their registered trade name or registered trade mark, their postal and electronic address [...] Importers shall ensure that any additional label does not obscure any information required by Union law on the label provided by the manufacturer.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 9(5) and (6); Article 11(3)","recipient":"Consumer (on the product); market surveillance authorities (technical documentation, on request)","sender":"Manufacturer and EU importer","sourceDate":"2026-05-29","sourceId":"src-c5ae058e","threshold":null,"timing":"Applies from 13 December 2024 (Article 52)","verificationMethod":"Fetched official consolidated text from the EU Publications Office (Cellar content negotiation); the EUR-Lex web front end blocked automated requests (CELEX 02023R0988-20260529)."},{"claim":"Viet Nam's Law on Chemicals requires every producer or importer of a chemical, not only of a hazardous one, to classify it under the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) and label it before it is used or sold. Information also has to travel back up the chain: any business handling the chemical that finds a new hazard must promptly tell the producer or importer so that it reclassifies and relabels.","claimType":"legal","conditions":"Applies to 'hóa chất' (chemicals: substances and mixtures). Circular 01/2026/TT-BCT Art 7 allows classification under its Annex XV or under GHS 'từ phiên bản 2 năm 2007 trở lên' (revision 2 of 2007 or later), so suppliers may classify against different GHS revisions. Labelling follows goods-labelling law (Decree 37/2026/ND-CP; see VN-04).","confidence":"high","contrary":null,"decisionSupported":"Mill deciding how to store, handle and protect workers from the finishing agent; producer deciding whether to reclassify","documentRef":"Law 69/2025/QH15, Art 23","exemptions":null,"fields":["chemical","handling"],"handovers":["h1"],"id":"VN-01","jurisdiction":"Viet Nam","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"Classification under GHS is a hazard classification, not a risk assessment, and it says nothing about whether a polymer is fluorinated unless that drives a hazard class. The law does not define how 'promptly' or in what form the Art 23(5) notice travels.","materialStatus":"mixture","note":null,"passage":"1. Tổ chức, cá nhân sản xuất, nhập khẩu hóa chất có nghĩa vụ phân loại, ghi nhãn hóa chất trước khi đưa hóa chất vào sử dụng, lưu thông trên thị trường; chịu trách nhiệm trước pháp luật về kết quả phân loại hóa chất và thông tin thể hiện trên nhãn hóa chất. 2. Việc phân loại hóa chất thực hiện theo quy tắc, hướng dẫn kỹ thuật của Hệ thống hài hòa toàn cầu về phân loại và ghi nhãn hóa chất (GHS) và theo quy định chi tiết của Thủ trưởng cơ quan quản lý nhà nước ở trung ương về hóa chất. [...] 5. Khi phát hiện đặc tính nguy hiểm mới của hóa chất chưa được thể hiện trong thông tin phân loại hóa chất, tổ chức, cá nhân hoạt động hóa chất có nghĩa vụ kịp thời thông báo cho tổ chức, cá nhân sản xuất, nhập khẩu hóa chất đó để thực hiện lại việc phân loại, ghi nhãn hóa chất theo quy định của Thủ trưởng cơ quan quản lý nhà nước ở trung ương về hóa chất.","passageLanguage":"vi","passageTranslation":"1. Organisations and individuals producing or importing chemicals are obliged to classify and label the chemicals before putting them into use or circulation on the market, and are legally responsible for the classification result and the information shown on the chemical label. 2. Classification follows the rules and technical guidance of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) and the detailed rules of the head of the central state chemicals authority. [...] 5. On discovering a new hazardous property of a chemical not yet reflected in its classification information, organisations and individuals engaged in chemical activities must promptly notify the producer or importer of that chemical so that it reclassifies and relabels the chemical, as the head of the central state chemicals authority prescribes.","pinpoint":"Art 23(1), (2) and (5); consolidated text, PDF pp. 17 to 18","recipient":"Finishing mill and its workers (via the label); the producer or importer (for new-hazard notices)","sender":"Producer or importer of the DWR finishing agent in Viet Nam (and, for Art 23(5), any downstream business that finds a new hazard)","sourceDate":"2025-06-14","sourceId":"src-58079d29","threshold":null,"timing":"Law in force from 1 January 2026 (Art 47).","verificationMethod":"Fetched official consolidated PDF (35/VBHN-VPQH, consolidating Law 69/2025/QH15 as amended by Cybersecurity Law 116/2025/QH15) from datafiles.chinhphu.vn and extracted text. Translation ours."},{"claim":"A Vietnamese seller of a hazardous chemical must give the buyer a safety data sheet (SDS, 'phiếu an toàn hóa chất'), and the buyer must ask for it and keep it where the chemical is stored. The law also says the SDS and the chemical's trade name cannot be kept confidential. The SDS duty attaches only to chemicals that meet the legal definition of hazardous, so a finishing agent with no GHS hazard class carries no statutory SDS duty.","claimType":"legal","conditions":"Only for 'hóa chất nguy hiểm' (hazardous chemicals), defined in Art 2(4) as a chemical with at least one hazardous property under the classification rules. Art 25(3) requires the SDS to be updated on changes or new hazards. Art 27 requires anyone engaged in chemical activities to keep hazardous-chemical records, including GHS hazard classification, for at least 3 years.","confidence":"high","contrary":null,"decisionSupported":"Mill deciding safe handling, storage, protective equipment and emergency response for the finishing agent","documentRef":"Law 69/2025/QH15, Arts 2(4), 25 and 26(2)","exemptions":null,"fields":["chemical","handling","record"],"handovers":["h1"],"id":"VN-02","jurisdiction":"Viet Nam","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"Whether a given DWR emulsion is 'hazardous' depends on its classification; many are supplied with an SDS anyway as commercial practice, which this law does not require. Art 26 governs information declared to the state; it does not stop the SDS from withholding composition under trade-secret rules (see VN-03). The law does not state the SDS language.","materialStatus":"mixture","note":null,"passage":"4. Hóa chất nguy hiểm là hóa chất gây hại cho con người, cơ sở vật chất, tài sản, môi trường và có ít nhất một đặc tính nguy hiểm theo nguyên tắc phân loại [...] Điều 25. Phiếu an toàn hóa chất 1. Tổ chức sản xuất hóa chất nguy hiểm, tổ chức, cá nhân nhập khẩu hóa chất nguy hiểm phải lập phiếu an toàn hóa chất khi nhập khẩu hóa chất, trước khi đưa hóa chất vào sử dụng, lưu thông trên thị trường và chịu trách nhiệm trước pháp luật về thông tin thể hiện trong phiếu an toàn hóa chất. 2. Tổ chức bán hóa chất nguy hiểm có nghĩa vụ cung cấp phiếu an toàn hóa chất cho tổ chức, cá nhân mua hóa chất. Tổ chức, cá nhân mua hóa chất nguy hiểm có nghĩa vụ yêu cầu tổ chức bán hóa chất cung cấp phiếu an toàn hóa chất, lưu giữ phiếu an toàn hóa chất tại địa điểm tồn trữ hóa chất. [...] 2. Những thông tin không được bảo mật bao gồm: a) Tên thương mại của hóa chất; [...] c) Phiếu an toàn hóa chất quy định tại Điều 25 của Luật này;","passageLanguage":"vi","passageTranslation":"4. A hazardous chemical is a chemical that harms people, facilities, property or the environment and has at least one hazardous property under the classification principles [...] Article 25. Safety data sheet 1. Organisations producing hazardous chemicals and organisations and individuals importing hazardous chemicals must prepare a safety data sheet when importing, and before putting the chemical into use or circulation on the market, and are legally responsible for its contents. 2. Organisations selling hazardous chemicals must provide the safety data sheet to the buyer. Buyers of hazardous chemicals must ask the seller for the safety data sheet and keep it at the place where the chemical is stored. [...] 2. Information that may not be kept confidential includes: a) the trade name of the chemical; [...] c) the safety data sheet under Article 25 of this Law;","pinpoint":"Art 2(4) (PDF p. 1); Art 25(1) and (2) (p. 18); Art 26(2)(a) and (c) (p. 19)","recipient":"Finishing mill (buyer), kept at the chemical store where workers handle it","sender":"Producer, importer or seller of the DWR finishing agent in Viet Nam","sourceDate":"2025-06-14","sourceId":"src-58079d29","threshold":null,"timing":"In force from 1 January 2026.","verificationMethod":"Fetched official consolidated PDF (35/VBHN-VPQH, consolidating Law 69/2025/QH15 as amended by Cybersecurity Law 116/2025/QH15) from datafiles.chinhphu.vn and extracted text. Translation ours."},{"claim":"For a mixture such as a DWR emulsion, the Vietnamese SDS template asks only for the identity and concentration range of hazardous components above the set thresholds, and says trade-secret (confidential business information, CBI) rules take priority when listing composition. A non-hazardous fluorinated or fluorine-free polymer need not appear, so the SDS a mill receives may not show whether the finish is PFAS-based.","claimType":"legal","conditions":"Applies to SDSs required under Law Art 25 (hazardous chemicals). Art 5(1) lists 16 content headings including 'c) Thông tin về thành phần các chất' (information on composition); Annex I item 1(a) asks for CAS number, UN number and EC number 'nếu có' (if any) and trade name.","confidence":"high","contrary":"Commercial SDSs often list more than the legal minimum; this claim concerns the legal floor only.","decisionSupported":"Mill deciding whether the finishing agent's ingredients matter for worker protection, wastewater and customer requirements","documentRef":"Circular 01/2026/TT-BCT, Art 5 and Annex I (SDS form), item 3","exemptions":null,"fields":["chemical","result"],"handovers":["h1"],"id":"VN-03","jurisdiction":"Viet Nam","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"The template does not say what the threshold is or which CBI rules apply; Decree 26/2026 Art 26 handles confidentiality by coded information. Neither Art 5 nor Annex I states the language of the SDS. A group name such as 'fluoropolymer' would be a group description, not a substance identity.","materialStatus":"mixture","note":null,"passage":"c) Thông tin về thành phần các chất; [...] Hỗn hợp chất / Nhận dạng hóa chất, nồng độ, phần trăm nồng độ trong khoảng xác định của tất cả các chất độc hại trên ngưỡng quy định / Ghi chú: Các quy định pháp lý về thông tin bí mật thương mại (CBI) sẽ được ưu tiên khi liệt kê thành phần các chất","passageLanguage":"vi","passageTranslation":"c) Information on the composition of substances; [...] Mixture / Chemical identity, concentration, and concentration percentage within a defined range, of all hazardous substances above the prescribed threshold / Note: Legal rules on confidential business information (CBI) take priority when listing the composition","pinpoint":"Art 5(1)(c); Annex I, row 3 'Thông tin về thành phần các chất', mixture cell (table cells joined with ' / ')","recipient":"Finishing mill","sender":"Producer or importer of the DWR finishing agent","sourceDate":"2026-05-26","sourceId":"src-eb0c7cc1","threshold":"'trên ngưỡng quy định' (above the prescribed threshold); the threshold value is not stated in Annex I.","timing":"Circular in force from 17 January 2026; replaced Circular 32/2017/TT-BCT.","verificationMethod":"Fetched official consolidated DOCX (32/VBHN-BCT, 26 May 2026, consolidating Circular 01/2026/TT-BCT as amended by Circular 26/2026/TT-BCT) from the Official Gazette site and extracted text. Translation ours."},{"claim":"A drum of finishing agent sold in Viet Nam must carry a Vietnamese-language label showing, among other items, its composition or quantitative composition, its chemical identification code if any, hazard pictograms, signal word and hazard statement if any, precautions and instructions for use and storage.","claimType":"legal","conditions":"Art 39(1): compulsory label content for goods circulating in Viet Nam must be in Vietnamese; Art 39(4)(b) lets international names and formulae of chemicals be written in Latin-script languages. Law on Chemicals Art 23(3) and (4) route chemical labelling to this decree and to GHS guidance.","confidence":"high","contrary":null,"decisionSupported":"Worker identifying the product and its hazards at the point of use","documentRef":"Decree 37/2026/ND-CP, Art 39(1) and Annex I row 55 'Hóa chất'","exemptions":null,"fields":["chemical","handling"],"handovers":["h1"],"id":"VN-04","jurisdiction":"Viet Nam","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"'Thành phần' (composition) is not defined here; a trade-name formulation could state it at a generic level. Hazard elements apply only 'if any', so a non-hazardous finishing agent carries no pictogram. The decree does not cover the composition of a polymer as a substance identity.","materialStatus":"mixture","note":null,"passage":"1. Những nội dung bắt buộc thể hiện trên nhãn hàng hóa lưu thông tại thị trường Việt Nam phải ghi bằng tiếng Việt, trừ hàng hóa xuất khẩu không tiêu thụ trong nước và trừ trường hợp quy định tại khoản 4 Điều này. [...] Hóa chất / a) Định lượng; b) Ngày, tháng, năm sản xuất; c) Hạn sử dụng (nếu có); d) Thành phần hoặc thành phần định lượng; đ) Mã nhận dạng hóa chất (nếu có); e) Hình đồ cảnh báo, từ cảnh báo, cảnh báo nguy cơ (nếu có); g) Biện pháp phòng ngừa (nếu có); h) Hướng dẫn sử dụng, hướng dẫn bảo quản.","passageLanguage":"vi","passageTranslation":"1. Compulsory content on labels of goods circulating in the Vietnamese market must be written in Vietnamese, except exported goods not consumed domestically and the cases in clause 4. [...] Chemicals / a) Net quantity; b) Date of manufacture; c) Expiry date (if any); d) Composition or quantitative composition; đ) Chemical identification code (if any); e) Hazard pictogram, signal word, hazard statement (if any); g) Precautionary measures (if any); h) Instructions for use and storage.","pinpoint":"Art 39(1); Annex I, row 55","recipient":"Finishing mill and the workers who handle the drum","sender":"Producer or importer of the DWR finishing agent","sourceDate":"2026-01-23","sourceId":"src-59269c83","threshold":null,"timing":"In force on signature, 23 January 2026.","verificationMethod":"Fetched official DOCX from the Official Gazette site and extracted text. Translation ours."},{"claim":"Viet Nam's import declaration for chemicals, which requires the SDS to be filed through the National Single Window before customs clearance, covers only goods in chapters 28 and 29 of the tariff nomenclature (inorganic and organic chemicals). Mixtures classed outside those chapters are exempt even if they contain chapter 28 or 29 chemicals.","claimType":"legal","conditions":"Documents listed in Art 6(2) include the original commercial invoice, with a Vietnamese translation authenticated by the importer if the invoice is in a foreign language, and the SDS. Circular 01/2026/TT-BCT Form 13a field 13 reads 'Tệp phiếu an toàn hóa chất bằng tiếng Việt đính kèm' (attached safety data sheet file in Vietnamese), the only explicit Vietnamese-language SDS requirement found in this review.","confidence":"high","contrary":null,"decisionSupported":"State deciding whether to clear an imported chemical; not a supply-chain handover in itself","documentRef":"Decree 26/2026/ND-CP, Art 6","exemptions":"Art 6(7): specially controlled or banned chemicals already holding an import licence; under 10 kg; under 1 kg of a new chemical for testing; mixtures outside chapters 28 and 29 that contain chapter 28 or 29 chemicals.","fields":["chemical","record"],"handovers":["h1"],"id":"VN-05","jurisdiction":"Viet Nam","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"This is a duty to the state, not to the next business in the chain. Whether the jacket's finishing agent falls in chapters 28 or 29 is addressed in VN-06.","materialStatus":"mixture","note":null,"passage":"1. Tổ chức, cá nhân nhập khẩu hóa chất thuộc các chương 28 và chương 29 của Danh mục hàng hóa xuất khẩu, nhập khẩu Việt Nam do Bộ trưởng Bộ Tài chính ban hành phải có trách nhiệm thực hiện khai báo hóa chất nhập khẩu trước khi thông quan qua Cổng thông tin một cửa quốc gia. [...] c) Phiếu an toàn hóa chất; [...] 7. Các trường hợp miễn trừ khai báo [...] đ) Nhập khẩu hỗn hợp chất không thuộc các chương 28 và chương 29 của Danh mục hàng hóa xuất khẩu, nhập khẩu Việt Nam do Bộ trưởng Bộ Tài chính ban hành có chứa hóa chất thuộc các chương 28 và chương 29","passageLanguage":"vi","passageTranslation":"1. Organisations and individuals importing chemicals in chapters 28 and 29 of the Vietnamese Export and Import Goods Nomenclature issued by the Minister of Finance must declare the imported chemicals through the National Single Window before customs clearance. [...] c) Safety data sheet; [...] 7. Cases exempt from declaration [...] đ) Import of mixtures not in chapters 28 and 29 of the Vietnamese Export and Import Goods Nomenclature issued by the Minister of Finance that contain chemicals in chapters 28 and 29","pinpoint":"Art 6(1), 6(2)(c), 6(7)(đ); official scan pp. 7 to 8","recipient":"Ministry of Industry and Trade (MOIT) system and Customs, via the National Single Window","sender":"Importer of the chemical (for example a distributor or the mill itself)","sourceDate":"2026-01-17","sourceId":"src-1f70e987","threshold":null,"timing":"In force on signature, 17 January 2026. A draft amending decree (consultation 20 to 27 August 2026) would repeal Art 6(7)(c) and (d) but leaves (đ) unchanged.","verificationMethod":"Text taken from atld.vn (secondary host, https://www.atld.vn/law/4226/content) and checked visually against the official signed scan on datafiles.chinhphu.vn for the quoted article. Translation ours. Art 6(1) to (2) checked on scan p. 7 and Art 6(7) on p. 8."},{"claim":"Interpretation: a DWR emulsion sold as a textile finishing preparation would ordinarily fall under Harmonized System (HS) heading 38.09 'finishing agents ... of a kind used in the textile ... industries' (or chapter 39 if presented as a polymer in primary form), not chapters 28 or 29. If so, its import into Viet Nam is exempt from the chemical import declaration, so the Vietnamese-language SDS field on that declaration does not reach it.","claimType":"interpretation","conditions":"Depends on the tariff classification of the specific product, which is a customs decision.","confidence":"medium","contrary":"A product presented as a pure chemical compound would fall in chapter 29 and be declared.","decisionSupported":"Researcher judging whether a state-held SDS record exists for the jacket's finishing agent","documentRef":"Heading 38.09; subheading 3809.91","exemptions":null,"fields":["chemical","record"],"handovers":["h1"],"id":"VN-06","jurisdiction":"International (HS nomenclature) applied to Viet Nam","lastVerified":"2026-10-23","legalStatus":"unresolved","limitations":"No customs ruling on a DWR product was found. sourceDate is the HS 2022 entry-into-force date, not a document date.","materialStatus":"mixture","note":null,"passage":"38.09 Finishing agents, dye carriers to accelerate the dyeing or fixing of dyestuffs and other products and preparations (for example, dressings and mordants), of a kind used in the textile, paper, leather or like industries, not elsewhere specified or included. [...] 3809.91 -- Of a kind used in the textile or like industries","passageLanguage":"en","passageTranslation":null,"pinpoint":"Chapter 38, heading 38.09","recipient":"MOIT and Customs (if declared); otherwise no state recipient at import","sender":"Importer of the DWR finishing agent","sourceDate":"2022-01-01","sourceId":"src-65d379ea","threshold":null,"timing":null,"verificationMethod":"Fetched official WCO PDF and extracted text. Viet Nam's nomenclature (issued by the Minister of Finance) was not fetched; the assumption that it follows the HS heading structure was not checked against it."},{"claim":"The Law on Chemicals separately obliges anyone engaged in chemical activities to give the authorities and users full and accurate information on the content of hazardous chemicals in chemicals and in products containing them. This is a general information duty towards users, but the law does not say how, when or in what form it is met.","claimType":"legal","conditions":"'Hoạt động hóa chất' (chemical activities) covers production, trade, storage, use and other activities with chemicals. Applies to hazardous-chemical content only.","confidence":"medium","contrary":null,"decisionSupported":"User deciding how to handle a chemical or product containing hazardous chemicals","documentRef":"Law 69/2025/QH15, Art 28(2)","exemptions":null,"fields":["result","chemical"],"handovers":["h1","h2"],"id":"VN-07","jurisdiction":"Viet Nam","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"Confidence is medium on reach, not on text: 'users' is not defined, no implementing provision sets a format, and whether a finished fabric roll is a 'product containing hazardous chemicals' depends on classification. We found no guidance applying it to textile intermediates.","materialStatus":"mixture","note":null,"passage":"2. Tổ chức, cá nhân hoạt động hóa chất có nghĩa vụ cung cấp đầy đủ, chính xác thông tin hàm lượng hóa chất nguy hiểm trong hóa chất, sản phẩm, hàng hóa chứa hóa chất nguy hiểm cho cơ quan có thẩm quyền và người sử dụng.","passageLanguage":"vi","passageTranslation":"2. Organisations and individuals engaged in chemical activities are obliged to provide full and accurate information on the content of hazardous chemicals in chemicals and in products and goods containing hazardous chemicals to competent authorities and users.","pinpoint":"Art 28(2), consolidated text p. 20","recipient":"'người sử dụng' (users) and competent authorities","sender":"Chemical supplier (to the mill); mill (to the garment factory), if it is engaged in 'chemical activities'","sourceDate":"2025-06-14","sourceId":"src-58079d29","threshold":null,"timing":"In force from 1 January 2026.","verificationMethod":"Fetched official consolidated PDF (35/VBHN-VPQH, consolidating Law 69/2025/QH15 as amended by Cybersecurity Law 116/2025/QH15) from datafiles.chinhphu.vn and extracted text. Translation ours."},{"claim":"Workers who handle chemicals directly must receive chemical safety training at least every two years, with a first cycle of at least 8 hours. The training must cover the hazardous properties and SDSs of the site's hazardous chemicals, classification and labelling, and practice in recognising hazardous chemicals by their labels and pictograms.","claimType":"legal","conditions":"Law on Chemicals Art 36(1) sets the periodic training duty; Art 36(2) ties it to the Occupational Safety and Health (OSH) Law. Retraining is also required on change of chemicals, technology or job (Art 29(2)). Later cycles are 50% of the first (Art 32(1)(b)). Training records kept 3 years (Art 32(4)).","confidence":"high","contrary":null,"decisionSupported":"Worker recognising a hazardous chemical and choosing protective equipment and safe handling","documentRef":"Decree 25/2026/ND-CP, Arts 29, 30 and 32","exemptions":null,"fields":["handling"],"handovers":["h1"],"id":"VN-08","jurisdiction":"Viet Nam","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"Training covers hazardous chemicals; a finishing agent with no hazard class may fall outside it. The decree does not set a training language. A legal duty to train is not evidence that training happens or is understood.","materialStatus":"mixture","note":null,"passage":"1. Tổ chức, cá nhân hoạt động hóa chất có trách nhiệm tổ chức huấn luyện an toàn chuyên ngành hóa chất cho các đối tượng được quy định tại khoản 3 Điều này định kỳ 02 năm một lần [...] c) Nhóm 3, bao gồm: Người lao động liên quan trực tiếp đến hóa chất; [...] 4. Nội dung huấn luyện đối với Nhóm 3: [...] c) Các đặc tính nguy hiểm của hóa chất, phiếu an toàn hóa chất của các hóa chất nguy hiểm trong hoạt động hóa chất của cơ sở; phân loại, ghi nhãn hóa chất; sắp xếp hóa chất; [...] đ) Nội dung thực hành tại cơ sở hoạt động hóa chất: Nhận biết hóa chất nguy hiểm thông qua nhãn hóa chất và hình đồ cảnh báo; sử dụng, bảo quản trang thiết bị bảo hộ cá nhân phục vụ công tác ứng phó sự cố hóa chất; [...] a) Thời gian huấn luyện an toàn chuyên ngành hóa chất chu kỳ đầu tiên tối thiểu là 08 giờ, bao gồm cả thời gian kiểm tra;","passageLanguage":"vi","passageTranslation":"1. Organisations and individuals engaged in chemical activities must organise specialised chemical safety training for the persons in clause 3 every 2 years [...] c) Group 3 includes: workers directly involved with chemicals; [...] 4. Training content for Group 3: [...] c) Hazardous properties of chemicals and the safety data sheets of the hazardous chemicals in the facility's chemical activities; classification and labelling of chemicals; arrangement of chemicals; [...] đ) Practical content at the facility: recognising hazardous chemicals through chemical labels and hazard pictograms; using and maintaining personal protective equipment for chemical incident response; [...] a) The first cycle of specialised chemical safety training is at least 8 hours, including testing;","pinpoint":"Art 29(1) and (3)(c); Art 30(4)(c) and (đ); Art 32(1)(a)","recipient":"Mill workers who handle chemicals directly ('Nhóm 3', Group 3)","sender":"Finishing mill (employer), itself or through a licensed consultancy","sourceDate":"2026-01-17","sourceId":"src-8c745a8b","threshold":"First cycle at least 8 hours including testing; every 2 years.","timing":"Decree in force on signature, 17 January 2026.","verificationMethod":"Fetched official DOCX from the Official Gazette site and extracted text. Translation ours."},{"claim":"Under Viet Nam's Occupational Safety and Health (OSH) Law, workers have a right to full information about hazardous and harmful factors at the workplace and the preventive measures, and to OSH training. Employers must inform workers about those factors, and manufacturers must supply safety information with products that may be unsafe at work. Warning signs and instructions for substances with strict safety requirements must be in Vietnamese and in the language the workers commonly use, placed where they are easy to read and see.","claimType":"legal","conditions":"Applies to employers and workers in Viet Nam; Art 6(7) gives foreign workers in Viet Nam the same rights and duties. Decree 26/2026/ND-CP Art 4(3) (production) requires: 'Mã nhận dạng hóa chất; hình đồ cảnh báo, từ cảnh báo, cảnh báo nguy cơ' (chemical identification code; hazard pictogram, signal word, hazard statement); verified on the official scan p. 6. Art 5(2) applies Art 4(2) to (5) to chemical traders' warehouses.","confidence":"high","contrary":null,"decisionSupported":"Worker deciding whether a task is safe and what protection to use, and recognising a hazard at the point of use","documentRef":"Law 84/2015/QH13, Arts 6(1)(b), 13(1) to (2) and 16(6)","exemptions":null,"fields":["handling"],"handovers":["h1"],"id":"VN-09","jurisdiction":"Viet Nam","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"The right is framed around hazardous and harmful factors, not substance identity. A draft law amending the OSH Law is before the National Assembly (see notes). Art 16(6) applies to 'chất có yêu cầu nghiêm ngặt' (substances with strict requirements), a category defined by list, not to every chemical. Legible signs in a worker's language are a usability requirement; they do not add composition information.","materialStatus":"n/a","note":null,"passage":"b) Được cung cấp thông tin đầy đủ về các yếu tố nguy hiểm, yếu tố có hại tại nơi làm việc và những biện pháp phòng, chống; được đào tạo, huấn luyện về an toàn, vệ sinh lao động; [...] 1. Người sử dụng lao động phải thông tin, tuyên truyền, giáo dục về an toàn, vệ sinh lao động, các yếu tố nguy hiểm, yếu tố có hại và các biện pháp bảo đảm an toàn, vệ sinh lao động tại nơi làm việc cho người lao động; [...] 2. Nhà sản xuất phải cung cấp thông tin về các biện pháp bảo đảm an toàn, vệ sinh lao động kèm theo sản phẩm, hàng hóa có khả năng gây mất an toàn cho người sử dụng trong quá trình lao động. [...] 6. Phải có biển cảnh báo, bảng chỉ dẫn bằng tiếng Việt và ngôn ngữ phổ biến của người lao động về an toàn, vệ sinh lao động đối với máy, thiết bị, vật tư và chất có yêu cầu nghiêm ngặt về an toàn, vệ sinh lao động tại nơi làm việc, nơi lưu giữ, bảo quản, sử dụng và đặt ở vị trí dễ đọc, dễ thấy.","passageLanguage":"vi","passageTranslation":"b) To be given full information about hazardous and harmful factors at the workplace and the preventive measures; to be trained in occupational safety and health; [...] 1. Employers must inform, communicate and educate workers about occupational safety and health, hazardous and harmful factors and the measures to ensure safety and health at the workplace; [...] 2. Manufacturers must provide information on measures to ensure occupational safety and health with products and goods that may be unsafe for users during work. [...] 6. There must be warning signs and instruction boards in Vietnamese and in the language commonly used by the workers on occupational safety and health for machines, equipment, materials and substances with strict safety and health requirements at the workplace and at places of storage, preservation and use, placed where they are easy to read and see.","pinpoint":"Art 6(1)(b), Công báo No. 1169+1170 (29 October 2024), p. 88; Art 13(1) and (2), Công báo No. 1171+1172 (29 October 2024), p. 2; Art 16(6), Công báo No. 1171+1172, p. 5","recipient":"Mill workers","sender":"Mill (employer); chemical manufacturer (for products supplied to the mill)","sourceDate":"2024-09-16","sourceId":"src-4ee36529","threshold":null,"timing":"In force since 1 July 2016; consolidated text 14/VBHN-VPQH dated 16 September 2024.","verificationMethod":"Fetched official Gazette PDFs of the consolidated text and extracted text. Translation ours."},{"claim":"Viet Nam lists PFOS (perfluorooctane sulfonic acid, with its sulfonates, sulfonamides and sulfonyls) and PFOA (perfluorooctanoic acid) and PFHxS (perfluorohexane sulfonic acid), each with salts and related compounds, as Group 2 'specially controlled chemicals' under the Stockholm and Rotterdam conventions. A mixture is specially controlled if it contains more than 1% by weight of one of them. These are the only per- and polyfluoroalkyl substances (PFAS) entries we found; there is no PFAS group listing.","claimType":"legal","conditions":"Decree 26/2026/ND-CP Art 15(1): users of specially controlled chemicals for production must declare the chemical type and purpose on the chemical database 'trước 30 ngày khi đưa hóa chất vào sử dụng lần đầu' (30 days before first use). Art 30(3): production and trading of chemicals that are specially controlled under Decree 24/2026 but were not restricted chemicals or industrial precursors under the old Decree 113/2017 must meet the decree's rules before 31 December 2026. Footnote (*): POPs on the list also follow environmental protection law.","confidence":"high","contrary":null,"decisionSupported":"Chemical supplier or mill deciding whether a finishing agent triggers licensing and declaration duties","documentRef":"Decree 24/2026/ND-CP, Annex III 'Danh mục hóa chất cần kiểm soát đặc biệt', I.1.2 Group 2 part C, and part II","exemptions":"Decree 26/2026 Art 21: production and trading certificates not needed below 0.1% in a mixture; export and import permits not needed below 5% for Group 2.","fields":["chemical","result"],"handovers":["h1"],"id":"VN-10","jurisdiction":"Viet Nam","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"A group entry such as 'PFOA-related compounds' is not a substance identity: the list gives only the parent acid's CAS number, so a supplier must decide for itself whether a side-chain fluorinated polymer counts as 'related'. Long-chain perfluorocarboxylic acids (C9 to C21), listed under the Stockholm Convention in 2025, are not on this list. A listing triggers licensing and declaration to the state; it is not by itself a duty to inform the next buyer.","materialStatus":"mixture","note":null,"passage":"HÓA CHẤT THUỘC CÁC CÔNG ƯỚC QUỐC TẾ VỀ HÓA CHẤT / Hóa chất thuộc Công ước Rotterdam và Công ước Stockholm (*) [...] Perfluorohexane sulfonic acid (PFHxS), its salts and PFHxS - related compounds / Axit perflo hexan sulfonic (PFHxS), các muối của chúng và các hợp chất liên quan đến PFHxS / 355-46-4 [...] Perfluorooctanoic acid (PFOA) and its salts and PFOA - related compounds / Axit perflo-octanoic (PFOA), các muối của chúng và các hợp chất liên quan đến PFOA / 335-67-1 [...] Hỗn hợp chất cần kiểm soát đặc biệt là hỗn hợp chất chứa ít nhất một thành phần: [...] - Hóa chất thuộc công ước cấm phát triển, sản xuất, tàng trữ, sử dụng và phá hủy vũ khí hóa học và hóa chât thuộc các công ước quốc tế về hóa chất thuộc nhóm 2 của Danh mục hóa chất cần kiểm soát đặc biệt của Nghị định này có hàm lượng lớn hơn 1% khối lượng.","passageLanguage":"vi","passageTranslation":"CHEMICALS UNDER INTERNATIONAL CHEMICALS CONVENTIONS / Chemicals under the Rotterdam Convention and the Stockholm Convention (*) [...] PFHxS, its salts and PFHxS-related compounds / 355-46-4 [...] PFOA and its salts and PFOA-related compounds / 335-67-1 [...] A specially controlled mixture is a mixture containing at least one component: [...] - chemicals under the Chemical Weapons Convention and chemicals under international chemicals conventions in Group 2 of the List of specially controlled chemicals of this Decree at a content greater than 1% by weight.","pinpoint":"Annex III, section I.1.2 (Nhóm 2), part C; section II; table cells joined with ' / '","recipient":"Producers, traders, importers and users of the chemicals, including a mill using a controlled mixture","sender":"Government (list); chemical supplier (to know whether its product is controlled)","sourceDate":"2026-01-17","sourceId":"src-a1696bea","threshold":"Mixture: more than 1% by weight ('lớn hơn 1% khối lượng').","timing":"Decree 24/2026 in force on signature, 17 January 2026; ministries review the lists before 30 June each year (Art 5(2)).","verificationMethod":"Fetched official DOCX from the Official Gazette site and extracted text; searched the full annex text for other PFAS names. Translation ours."},{"claim":"Viet Nam registered a Stockholm Convention specific exemption for PFOA in 'textiles for oil and water repellency for the protection of workers from dangerous liquids'. The register shows it expired on 3 December 2025. Viet Nam's only active PFOA exemption is for perfluorooctyl iodide used to make perfluorooctyl bromide, so no PFOA exemption for textiles remains open to it. In the same register, the Government of Viet Nam gave as its reason that PFOA was still used in Viet Nam in several fields including textiles (an undated government statement, not measured data).","claimType":"legal","conditions":"The PFOA listing (decision SC-9/12) entered into force on 3 December 2020 for every Party without an Article 25(4) declaration or a notice of non-acceptance (UN depositary notification C.N.552.2020.TREATIES-XXVII.15). The UN treaty status page records Viet Nam's ratification on 22 July 2002 and no declaration or non-acceptance, so the listing binds Viet Nam. The PFHxS listing (SC-10/13) entered into force on the same basis on 16 November 2023 (C.N.481.2023.TREATIES-XXVII.15).","confidence":"high","contrary":null,"decisionSupported":"Mill or brand judging whether any PFOA use in a Vietnamese textile finish can still be lawful under the Convention","documentRef":"Expired specific exemptions table, Viet Nam rows; active table, Viet Nam row","exemptions":null,"fields":["chemical"],"handovers":["h1"],"id":"VN-11","jurisdiction":"International (Viet Nam entry)","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"The exemption, even while active, was limited to worker-protection textiles, not consumer rain jackets. Domestic Decree 08/2022/ND-CP Annex XVII still lists 'Dệt may (làm chất chống thấm dầu và nước)' as a PFOA use area; see VN-14. Undated statement by a government, not measured data; it does not say whether the textile use was finishing, which products, or in what volume, and it predates the expiry. It is not evidence about the 2026 jacket.","materialStatus":"substance","note":null,"passage":"Expired specific exemptions [...] Use: 03.Textiles for oil and water repellency for the protection of workers from dangerous liquids that comprise risks to their health and safety | Viet Nam | 03/12/2025 | To be updated [...] Currently, Viet Nam has still used Perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds as input materials for direct production and in the articles, products, commodities and equipment containing PFOA in several fields such as: Fire-fighting foam; textiles; pharmaceutical products, photolithography; polyfluoroethylene propylene","passageLanguage":"en","passageTranslation":null,"pinpoint":"'Expired specific exemptions' table, category 03, Viet Nam row (cells joined with ' | '); Viet Nam rows, 'Reasons for need' column (text truncated on the page as shown)","recipient":"Parties, businesses and the public reading the register","sender":"Government of Viet Nam (registration); Stockholm Convention Secretariat (register)","sourceDate":null,"sourceId":"src-8f3f6b3d","threshold":null,"timing":"Expired 3 December 2025 (five years after the PFOA listing entered into force).","verificationMethod":"Fetched the official register page (HTML) and extracted the table text. Page carries no publication date. Entry into force checked against the two depositary notifications (treaties.un.org PDFs) and the treaty status page (https://treaties.un.org/Pages/ViewDetails.aspx?src=TREATY&mtdsg_no=XXVII-15&chapter=27&clang=_en)."},{"claim":"The Stockholm Convention's listing of long-chain perfluorocarboxylic acids (PFCAs, C9 to C21), their salts and related compounds (decision SC-12/12) was communicated to Parties on 16 December 2025. Under Article 22 it enters into force one year after that communication for every Party that has not refused it or made an Article 25(4) declaration, which on the current record would include Viet Nam. Viet Nam's chemical lists do not yet include these substances.","claimType":"legal","conditions":"Viet Nam could still notify non-acceptance before the one-year period ends.","confidence":"high","contrary":null,"decisionSupported":"Government updating domestic lists; supplier anticipating controls on long-chain fluorinated chemistry","documentRef":"C.N.672.2025.TREATIES-XXVII.15","exemptions":null,"fields":["chemical"],"handovers":["h1"],"id":"VN-12","jurisdiction":"International (applies to Viet Nam)","lastVerified":"2026-10-23","legalStatus":"future","limitations":"The exact entry-into-force date will be set by a later depositary notice. Domestic effect depends on Viet Nam amending its lists.","materialStatus":"substance","note":null,"passage":"adopted amendments to Annex A in its decisions SC-12/9, SC-12/10 and SC-12/12, to list the following chemicals in the annex: [...] SC-12/12: Listing of long-chain perfluorocarboxylic acids, their salts and related compounds [...] On the expiry of one year from the date of the communication by the depositary of the adoption of the amendment to Annex A, B or C, the amendment shall enter into force for all Parties that have not submitted a notification in accordance with the provisions of paragraph 3 (b) of article 22.","passageLanguage":"en","passageTranslation":null,"pinpoint":"C.N.672.2025, paras 1 and 2","recipient":"Government of Viet Nam","sender":"Conference of the Parties, via the UN depositary","sourceDate":"2025-12-16","sourceId":"src-a6d120fb","threshold":null,"timing":"Communicated 16 December 2025; by the one-year rule, entry into force on or about 16 December 2026 (date not yet notified by the depositary).","verificationMethod":"Fetched depositary notification PDF from treaties.un.org, which annexes the amendment text: long-chain PFCAs are defined by the formula CnF2n+1COOH where 8 ≤ n ≤ 20 (C9 to C21 acids). Decree 24/2026 annex searched for these substances; none found."},{"claim":"Viet Nam's Law on Environmental Protection bans producing, exporting, importing and using persistent organic pollutants (POPs) in Stockholm Annex A, and goods containing them above the legal maximum, unless an exemption is registered. It also requires source control, information disclosure, labelling and conformity assessment for POPs and for goods containing them.","claimType":"legal","conditions":"The ban applies 'có hàm lượng vượt giới hạn tối đa cho phép theo quy định của pháp luật' (above the maximum permitted content under law); the limit values sit in implementing rules.","confidence":"medium","contrary":null,"decisionSupported":"Mill or exporter deciding whether a PFOA- or PFHxS-containing input or fabric may be used or exported","documentRef":"Law 72/2020/QH14, Art 69(1)(a) and (b)","exemptions":null,"fields":["chemical","result"],"handovers":["h1","h2","h3"],"id":"VN-13","jurisdiction":"Viet Nam","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"A restriction is not an information duty: Art 69(1)(a) bans use, while (1)(b) makes disclosure and labelling depend on implementing rules. Confidence is medium because amendments to the law since 2020 were not checked for this article.","materialStatus":"article","note":null,"passage":"a) Không được sản xuất, xuất khẩu, nhập khẩu và sử dụng chất ô nhiễm hữu cơ khó phân hủy và nguyên liệu, nhiên liệu, vật liệu, sản phẩm, hàng hóa, thiết bị có chứa chất ô nhiễm hữu cơ khó phân hủy thuộc Phụ lục A của Công ước Stockholm có hàm lượng vượt giới hạn tối đa cho phép theo quy định của pháp luật, trừ chất ô nhiễm hữu cơ khó phân hủy đã được đăng ký miễn trừ theo quy định của Công ước Stockholm; b) Phải kiểm soát nguồn phát sinh và công bố thông tin, dán nhãn, đánh giá sự phù hợp, kiểm tra đối với chất ô nhiễm khó phân hủy và nguyên liệu, nhiên liệu, vật liệu, sản phẩm, hàng hóa, thiết bị có chứa chất ô nhiễm khó phân hủy theo quy định của pháp luật;","passageLanguage":"vi","passageTranslation":"a) Persistent organic pollutants, and raw materials, fuels, materials, products, goods and equipment containing persistent organic pollutants, in Annex A of the Stockholm Convention, at a content exceeding the maximum permitted under law, must not be produced, exported, imported or used, except persistent organic pollutants with an exemption registered under the Stockholm Convention; b) Sources must be controlled, and information disclosure, labelling, conformity assessment and inspection must be carried out for persistent pollutants and raw materials, fuels, materials, products, goods and equipment containing them, as provided by law;","pinpoint":"Art 69(1)(a) and (b); Công báo No. 1185+1186 (25 December 2020), p. 73","recipient":"Buyers and the environment ministry (now the Ministry of Agriculture and Environment)","sender":"Businesses producing, importing or trading POPs or goods containing them","sourceDate":"2020-11-17","sourceId":"src-1adee5b2","threshold":null,"timing":"In force since 1 January 2022.","verificationMethod":"Fetched the official Gazette PDF of the original law and extracted text. Later amending laws were not checked for changes to Art 69; the consolidated Decree 08/2022 (April 2026) still cites this structure. Translation ours."},{"claim":"Viet Nam's environmental decree requires anyone importing, producing or trading goods containing POPs to label them with the POP's name and content, or with compliance with a relevant international standard. That duty is keyed to a national technical regulation on POP limits in goods, which we could not confirm has been issued. Whether it binds a PFOA-treated fabric today is unresolved.","claimType":"legal","conditions":"Art 39(1) starts 'Căn cứ quy chuẩn kỹ thuật môi trường về giới hạn các chất ô nhiễm khó phân hủy...' (based on the national environmental technical regulation on POP limits). Art 40 requires conformity assessment before goods circulate. Annex XVII (as amended by Decree 05/2025) lists PFOA with a use area 'Dệt may (làm chất chống thấm dầu và nước)' (textiles, as oil and water repellent), although Viet Nam's matching Convention exemption expired on 3 December 2025.","confidence":"medium","contrary":"The 2024 draft regulation, if issued, would supply the missing limits: '≤0,025 mg/kg' for PFOA and its salts and '≤1 mg/kg' for PFOA-related compounds in substances, mixtures, materials and components of goods. Its PFOA row lists HS code '3809.91' (textile finishing agents) and its sampling table covers 'Sản phẩm dệt may, sợi' (textile products, yarn). Text read from the draft PDF; it is a proposal by a ministry that has since merged, and we found no issued version.","decisionSupported":"Buyer of a fabric or chemical deciding whether it contains a regulated POP","documentRef":"Decree 08/2022/ND-CP as amended by Decrees 05/2025, 48/2026 and 110/2026, Art 39(1) and (2)(b); Annex XVII","exemptions":null,"fields":["chemical","result"],"handovers":["h1","h2","h3"],"id":"VN-14","jurisdiction":"Viet Nam","lastVerified":"2026-10-23","legalStatus":"unresolved","limitations":"Text verified; applicability not. If the regulation exists, the label would carry POP name and content, a positive information duty that would reach the fabric buyer. The duty is keyed to goods containing POPs, which on current Vietnamese lists means PFOS, PFOA and PFHxS among PFAS, not fluorotelomer or fluorine-free finishes.","materialStatus":"article","note":null,"passage":"1. Căn cứ quy chuẩn kỹ thuật môi trường về giới hạn các chất ô nhiễm khó phân hủy trong nguyên liệu, nhiên liệu, vật liệu, sản phẩm, hàng hóa, thiết bị, tổ chức, cá nhân nhập khẩu, sản xuất, kinh doanh nguyên liệu, nhiên liệu, vật liệu, sản phẩm, hàng hóa, thiết bị có chứa chất ô nhiễm khó phân hủy phải thực hiện dán nhãn và công bố thông tin theo quy định tại khoản 2 và khoản 3 Điều này. [...] b) Nội dung thể hiện trên nhãn nguyên liệu, nhiên liệu, vật liệu, sản phẩm, hàng hóa, thiết bị có chứa chất ô nhiễm khó phân hủy, bao gồm: tên và hàm lượng chất ô nhiễm khó phân hủy được quy định trong quy chuẩn kỹ thuật môi trường về giới hạn các chất ô nhiễm khó phân hủy trong nguyên liệu, nhiên liệu, vật liệu, sản phẩm, hàng hóa, thiết bị hoặc thông tin về việc đáp ứng tiêu chuẩn quốc tế có liên quan đến chất ô nhiễm khó phân hủy và các thông tin khác theo quy định của pháp luật về nhãn hàng hóa.","passageLanguage":"vi","passageTranslation":"1. Based on the national environmental technical regulation on limits for persistent pollutants in raw materials, fuels, materials, products, goods and equipment, organisations and individuals importing, producing or trading raw materials, fuels, materials, products, goods and equipment containing persistent pollutants must label them and disclose information under clauses 2 and 3. [...] b) Label content for raw materials, fuels, materials, products, goods and equipment containing persistent pollutants includes: the name and content of the persistent pollutant specified in the national environmental technical regulation on limits for persistent pollutants in raw materials, fuels, materials, products, goods and equipment, or information on compliance with an international standard on persistent pollutants, and other information under goods-labelling law.","pinpoint":"Art 39(1) and (2)(b), consolidated text PDF p. 79; Annex XVII 'Danh mục các chất POP và nội dung đăng ký miễn trừ theo quy định của Công ước Stockholm', row 8 (PFOA), PDF pp. 288 to 289","recipient":"Buyers, via the label; Ministry of Agriculture and Environment, via conformity results","sender":"Importer, producer or trader of goods containing POPs (for example a mill selling treated fabric)","sourceDate":"2026-04-17","sourceId":"src-260cbaf3","threshold":null,"timing":null,"verificationMethod":"Fetched official consolidated PDF (49/VBHN-BNNMT, authenticated 17 April 2026) from datafiles.chinhphu.vn and extracted text. Searched for an issued national technical regulation on POP limits in goods; found only drafts (November 2021 on vea.mae.gov.vn; a 2024 draft 'QCVN …:2024/BTNMT' on vibonline.com.vn, the Vietnam Chamber of Commerce and Industry's consultation portal, https://vibonline.com.vn/wp-content/uploads/2024/08/3_Du-thao-QCVN-ve-gioi-han-cac-chat-POP_Signed.pdf). Translation ours."},{"claim":"Viet Nam has a product-level disclosure regime for hazardous chemicals in goods, but the Ministry of Industry and Trade's list of chemicals whose presence in products must be disclosed has 10 entries (acetone, cadmium, chromium VI compounds, formaldehyde, hydrochloric acid, lead, mercury, methanol, sulphuric acid and toluene), each tied to products such as glue, cleaners, plywood, batteries and electronics. No textile product and no PFAS is listed.","claimType":"legal","conditions":"Law on Chemicals Art 31(1) brings products with a technical regulation into the regime; Art 31(2) covers products without one through ministry lists. Art 11(2) lets the Chemicals Agency take comments and propose additions.","confidence":"high","contrary":null,"decisionSupported":"Mill or garment factory deciding whether it has a product-disclosure duty for the fabric or jacket","documentRef":"Circular 01/2026/TT-BCT, Art 11(1) and Annex XIX","exemptions":null,"fields":["chemical"],"handovers":["h2","h3"],"id":"VN-15","jurisdiction":"Viet Nam","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"Other ministries may issue their own lists under Law Art 31(2); none covering textiles was found, but this was not searched exhaustively. Textiles do have a technical regulation (QCVN 01:2017/BCT), so whether Art 31(1) pulls formaldehyde and azo amine content into the disclosure regime is unresolved.","materialStatus":"article","note":null,"passage":"1. Danh mục hóa chất nguy hiểm trong sản phẩm hàng hóa phải công bố thông tin trong lĩnh vực công nghiệp ban hành tại Phụ lục XIX ban hành kèm theo Thông tư này. [...] PHỤ LỤC XIX / DANH MỤC HÓA CHẤT NGUY HIỂM TRONG SẢN PHẨM HÀNG HÓA PHẢI CÔNG BỐ THÔNG TIN TRONG LĨNH QUẢN LÝ CỦA BỘ CÔNG THƯƠNG [...] 4 / Formaldehyde / 50-00-0 / Ván ép, chất tẩy rửa","passageLanguage":"vi","passageTranslation":"1. The List of hazardous chemicals in products and goods requiring information disclosure in the industrial sector is in Annex XIX of this Circular. [...] ANNEX XIX / LIST OF HAZARDOUS CHEMICALS IN PRODUCTS AND GOODS REQUIRING INFORMATION DISCLOSURE UNDER THE MANAGEMENT OF THE MINISTRY OF INDUSTRY AND TRADE [...] 4 / Formaldehyde / 50-00-0 / Plywood, cleaning agents","pinpoint":"Art 11(1); Annex XIX, rows 1 to 10 (cells joined with ' / ')","recipient":"Producers and importers of listed products","sender":"MOIT (list)","sourceDate":"2026-05-26","sourceId":"src-eb0c7cc1","threshold":null,"timing":"List in force since 17 January 2026; disclosure compliance date 1 March 2026 under Decree 26/2026 Art 30(8).","verificationMethod":"Fetched official consolidated DOCX (32/VBHN-BCT, 26 May 2026, consolidating Circular 01/2026/TT-BCT as amended by Circular 26/2026/TT-BCT) from the Official Gazette site and extracted text. Translation ours. All ten Annex XIX rows read."},{"claim":"Where the product-disclosure regime does apply, it requires positive information: before sale, the producer or importer declares for each lot the product name, the hazardous chemical's name, its hazard, its content and the field of use on the national chemicals database, and publishes composition and content on its website or at the point of sale and on the product label.","claimType":"legal","conditions":"Only for products within Law Art 31(1) or (2); the exported jacket's DWR chemistry is not within the current lists (see VN-15).","confidence":"high","contrary":null,"decisionSupported":"Buyer deciding whether and how to use a product containing a hazardous chemical","documentRef":"Decree 26/2026/ND-CP, Art 29","exemptions":null,"fields":["chemical","result","record"],"handovers":["h2","h3"],"id":"VN-16","jurisdiction":"Viet Nam","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"Shows what Vietnamese law asks for when it does reach a product; it does not reach this jacket. A draft amendment would add annual production and import volumes to the declaration (MOIT draft amending Decree 26/2026, consultation 20 to 27 August 2026; see notes).","materialStatus":"article","note":null,"passage":"1. Khai báo các thông tin sau đây lên Cơ sở dữ liệu chuyên ngành hoá chất (khai báo theo lô hàng sản xuất hoặc nhập khẩu) trước khi đưa sản phẩm, hàng hoá lưu thông trên thị trường: a) Tên sản phẩm, hàng hoá chứa hoá chất nguy hiểm; b) Tên hoá chất nguy hiểm; c) Đặc tính nguy hiểm của hoá chất; d) Hàm lượng; đ) Lĩnh vực sử dụng của sản phẩm chứa hoá chất nguy hiểm. 2. Công bố thông tin về thành phần và hàm lượng hoá chất nguy hiểm và khuyến cáo hạn chế sử dụng đối với của sản phẩm, hàng hoá chứa hoá chất nguy hiểm, thể hiện trên cổng thông tin điện tử, trang thông tin điện tử của tổ chức, cá nhân hoặc tại nơi trực tiếp cung cấp sản phẩm, hàng hóa cho bên mua và trên nhãn hàng hoá của sản phẩm, hàng hoá.","passageLanguage":"vi","passageTranslation":"1. Declare the following on the specialised chemicals database (per production or import lot) before putting the product on the market: a) name of the product containing the hazardous chemical; b) name of the hazardous chemical; c) hazardous property of the chemical; d) content; đ) field of use of the product. 2. Publish information on the composition and content of the hazardous chemical and recommendations limiting use of the product, on the organisation's web portal or website or at the place where the product is supplied to the buyer, and on the product label.","pinpoint":"Art 29(1) and (2); official scan p. 40","recipient":"MOIT chemicals database; buyers, via website, point of sale and label","sender":"Producer or importer of a product containing a listed hazardous chemical","sourceDate":"2026-01-17","sourceId":"src-1f70e987","threshold":null,"timing":"In force from 17 January 2026; compliance by 1 March 2026 (Art 30(8)).","verificationMethod":"Text taken from atld.vn (secondary host, https://www.atld.vn/law/4226/content) and checked visually against the official signed scan on datafiles.chinhphu.vn for the quoted article. Translation ours. Art 29 checked on scan p. 40."},{"claim":"Viet Nam's technical regulation for textiles, QCVN 01:2017/BCT as amended in 2026, limits formaldehyde (30, 75 or 300 mg/kg by product group) and each aromatic amine released from azo dyes (30 mg/kg) in textile products before they go on the Vietnamese market. It sets no limit or information duty for PFAS or water-repellent finishes.","claimType":"legal","conditions":"Domestic market only: amended clause 1.1.1 applies 'trước khi đưa ra lưu thông trên thị trường Việt Nam' (before being placed on the Vietnamese market). Conformity is certified by testing under method 5 or method 7 of Annex II to Circular 14/2026/TT-BKHCN (amended clause 3.1.1). Product list now in Circular 33/2026/TT-BCT.","confidence":"high","contrary":null,"decisionSupported":"Producer deciding whether a textile may be placed on the Vietnamese market","documentRef":"QCVN 01:2017/BCT, 2.1.1 and 2.1.2; Amendment 01:2026 (https://datafiles.chinhphu.vn/cpp/files/vbpq/2026/7/37-bct.signed.pdf), 1.1.1","exemptions":null,"fields":["result"],"handovers":["h3"],"id":"VN-17","jurisdiction":"Viet Nam","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"A restriction, not an information duty. The water-repellent finish is outside its scope; formaldehyde can arise from some finishing resins, but that is separate from DWR chemistry.","materialStatus":"article","note":null,"passage":"Sản phẩm dệt may cho trẻ em dưới 36 tháng tuổi / 30 [...] Sản phẩm dệt may tiếp xúc trực tiếp với da / 75 [...] Sản phẩm dệt may không tiếp xúc trực tiếp với da / 300 [...] Hàm lượng mỗi amin thơm không được vượt quá 30 mg/kg. [...] Quy chuẩn này quy định mức giới hạn hàm lượng formaldehyt và các amin thơm chuyển hóa từ thuốc nhuộm azo trong sản phẩm, hàng hóa dệt may trước khi đưa ra lưu thông trên thị trường Việt Nam.","passageLanguage":"vi","passageTranslation":"Textile products for children under 36 months / 30 [...] Textile products in direct contact with skin / 75 [...] Textile products not in direct contact with skin / 300 [...] The content of each aromatic amine must not exceed 30 mg/kg. [...] This regulation sets limits on the content of formaldehyde and aromatic amines derived from azo dyes in textile products and goods before they are placed on the Vietnamese market.","pinpoint":"QCVN 01:2017/BCT 2.1.1 table (scan p. 6) and 2.1.2; Amendment 01:2026 clause 1.1.1 (scan p. 8)","recipient":"Market surveillance authority and buyers in Viet Nam","sender":"Producer or importer of textiles sold in Viet Nam (by conformity declaration)","sourceDate":"2017-10-23","sourceId":"src-f2158e3b","threshold":"Formaldehyde: 30 mg/kg (children under 36 months), 75 mg/kg (skin contact), 300 mg/kg (no skin contact). Each azo amine: 30 mg/kg.","timing":"Original in force 1 May 2018; Amendment 01:2026 (Circular 37/2026/TT-BCT, 30 June 2026) in force 1 July 2026.","verificationMethod":"Read the official signed scans of Circular 21/2017/TT-BCT and Circular 37/2026/TT-BCT (image PDFs rendered and read page by page) from datafiles.chinhphu.vn; metadata on vanban.chinhphu.vn. Translation ours."},{"claim":"Viet Nam's labelling decree sends export goods to the importing country's rules. Labels on exported goods follow the law of the importing country, contracts and treaties, and goods made only for export need not meet the rules for goods sold in Viet Nam. The Vietnamese textile label (composition, specifications, warnings, use and care instructions, year of manufacture) is therefore not required on a jacket made only for France.","claimType":"legal","conditions":"Goods sold both for export and in Viet Nam must meet both sets of rules (Art 87(1)). Domestic textile label content: Annex I row 25 'a) Thành phần hoặc thành phần định lượng; b) Thông số kỹ thuật; c) Thông tin cảnh báo; d) Hướng dẫn sử dụng, hướng dẫn bảo quản; đ) Năm sản xuất.'","confidence":"high","contrary":null,"decisionSupported":"Garment factory deciding which label and product rules the jacket must meet","documentRef":"Decree 37/2026/ND-CP, Arts 42(3) and 87(1)","exemptions":null,"fields":["chemical","handling"],"handovers":["h3"],"id":"VN-18","jurisdiction":"Viet Nam","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"This is continuity by design, not a gap: Vietnamese law hands the jacket's product information rules to the destination market. It does not remove production-side duties (chemicals, worker safety, environment) in Viet Nam.","materialStatus":"article","note":null,"passage":"3. Nhãn của hàng hóa xuất khẩu được thực hiện theo quy định pháp luật của nước nhập khẩu, hợp đồng, các điều ước quốc tế mà Việt Nam là thành viên, đồng thời tuân thủ quy định tại khoản 2 Điều 50 Nghị định này. [...] Hàng hóa chỉ dành cho xuất khẩu phải tuân thủ đầy đủ các quy định của nước nhập khẩu, không phải tuân thủ các quy định cho hàng hóa lưu thông trong nước; trừ những hàng hóa vừa xuất khẩu vừa lưu thông trong nước thì phải tuân thủ đầy đủ quy định của cả nước nhập khẩu và của Việt Nam.","passageLanguage":"vi","passageTranslation":"3. Labels of exported goods follow the law of the importing country, contracts and international treaties to which Viet Nam is a party, and must also comply with Article 50(2) of this Decree. [...] Goods intended only for export must fully comply with the rules of the importing country and need not comply with the rules for goods circulating domestically; goods both exported and circulated domestically must fully comply with the rules of both the importing country and Viet Nam.","pinpoint":"Art 42(3); Art 87(1), second paragraph; Annex I row 25","recipient":"Brand or importer in France, and the French market","sender":"Garment factory (exporter)","sourceDate":"2026-01-23","sourceId":"src-59269c83","threshold":null,"timing":"In force on signature, 23 January 2026; the former labelling Decrees 43/2017/ND-CP and 111/2021/ND-CP lapsed on 1 July 2026 (Art 97).","verificationMethod":"Fetched official DOCX from the Official Gazette site and extracted text. Art 50(2) not read. Translation ours."},{"claim":"The Zero Discharge of Hazardous Chemicals (ZDHC) Manufacturing Restricted Substances List (MRSL), version 3.1, does not permit any chemical formulation based on, or including, per- and polyfluoroalkyl substances (PFAS) for fashion, sport or outdoor clothing. A PFAS formulation is always deemed non-conformant, even for technical end uses that may need it, so a fluorinated durable water-repellent (DWR) agent for this jacket cannot be ZDHC-conformant.","claimType":"voluntary-standard","conditions":"Applies to formulations used in processing textiles for fashion, sport or outdoor clothing and apparel and home textiles, where the mill or its customers adopt the ZDHC MRSL. Restricts intentional use in commercial formulations; sets no limits for finished articles.","confidence":"high","contrary":"ZDHC's June 2026 position reports PFAS findings in articles made with formulations previously considered compliant (VN-27).","decisionSupported":"Finishing mill choosing a DWR finishing agent for outdoor apparel fabric that conforms to the MRSL its brand customers require","documentRef":"ZDHC MRSL V3.1, Chapter 1, group 1N Perfluorinated and Polyfluorinated Chemicals (PFAS)","exemptions":"None for apparel. Critical technical textile end uses (e.g. military, medical, protective clothing, transportation) are acknowledged, but such formulations are always deemed non-conformant.","fields":["chemical"],"handovers":["h1"],"id":"VN-19","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"Voluntary; binds those who adopt it, usually via brand contracts. The MRSL states it 'is not intended nor can be used as a statement of legal requirements' (section 3, p. 4). Conformance concerns intentional use in formulations, not the finished fabric, and says nothing about which non-fluorinated chemistry replaced PFAS.","materialStatus":"mixture","note":null,"passage":"Formulations containing PFAS (Per and Polyfluorinated alkylated substances) are often used for water or stain repellency. The use of any formulation based on, or including PFAS, including those listed below, is not permitted (for fashion, sport or outdoor clothing and apparel and home textiles). It should be noted that there may be certain critical (technical textile) end uses where legally or contractually mandated standards may only be achieved using these substances (e.g. military, medical, protective clothing, transportation). The formulations will always be deemed ZDHC MRSL NON-CONFORMANT and it is intended that the ZDHC Supplier Platform will appraise the end uses of any PFAS within an inventory.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Chapter 1, 1N, 'Potential uses', PDF p. 34 (repeated pp. 35 to 37)","recipient":"Finishing mill buying the DWR agent","sender":"ZDHC Foundation (sets the list); chemical formulator (supplies the DWR agent)","sourceDate":"2026-08-27","sourceId":"src-442e145b","threshold":"Group rule: any formulation based on, or including PFAS is not permitted. Marker limits in R2-020.","timing":"Introduced in MRSL V3.0 (Nov 2022) with a twelve-month transition beginning 1 November 2022; text unchanged in V3.1 (March 2023 according to TÜV Rheinland). ZDHC planned MRSL-related PFAS updates for October 2026; none found published on 2026-10-23.","verificationMethod":"Fetched PDF of the ZDHC-generated MRSL V3.1 (footer 'V3.1 Aug 2026', created 27 Aug 2026) hosted by Lindex; ZDHC's own download and e-MRSL servers refused connections. Identical wording in the ZDHC MRSL V3.0 (Nov 2022) PDF hosted by G-Star."},{"claim":"The MRSL enforces its PFAS rule through a short list of marker substances rather than the whole class. ZDHC-approved certifiers test DWR formulations against limits in micrograms per kilogram of formulation (for example perfluorooctanoic acid (PFOA) 25 µg/kg; 6:2 fluorotelomer alcohol 1000 µg/kg) and may, at their discretion, screen for total fluorine with a quantification limit of 50 mg/kg.","claimType":"voluntary-standard","conditions":"Textile applicability; method LC-MS or GC-MS. Total fluorine screen is discretionary.","confidence":"high","contrary":null,"decisionSupported":"Certifier deciding whether a DWR formulation can be listed as MRSL-conformant","documentRef":"ZDHC MRSL V3.1, section 5.1 and Chapter 1, group 1N","exemptions":null,"fields":["result","chemical"],"handovers":["h1"],"id":"VN-20","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"Relies on ZDHC's premise that useful PFAS repellents always carry markers; side-chain fluorinated polymers are not themselves listed. The PFAS ZDHC Guidance Sheet could not be fetched. Test results stay between certifier and formulator; what travels downstream is a conformance level (VN-21).","materialStatus":"mixture","note":null,"passage":"Note on PFAS and testing: There are thousands of individual chemicals that are categorised as PFAS but only a few are actually useful in terms of oil / water repellency and their use is always accompanied by the presence of common, known 'marker' chemicals such as those listed below. ZDHC approved MRSL certifiers will check for the deliberate use of PFAS or high levels of contamination of PFAS by testing for the marker chemicals listed below and ,at their discretion, use a screening test for total fluorine (quantification limit: 50mg/kg) followed by confirmatory testing for specific series e.g. the other PFAS mentioned in the PFAS ZDHC Guidance Sheet. [...] Formulation limits are concentration limits for the substances in commercial chemical formulations available from chemical manufacturers. These limits ban intentional use while allowing for reasonable expected manufacturing impurities, which should be consistently achievable by responsible chemical manufacturers.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Chapter 1, 1N 'Note on PFAS and testing' and substance table, PDF pp. 34 to 37; section 5.1, PDF p. 5","recipient":"Chemical formulator; the finishing mill sees only the resulting conformance listing","sender":"ZDHC-approved MRSL certifier (tests the formulation)","sourceDate":"2026-08-27","sourceId":"src-442e145b","threshold":"Formulation limits as stated: PFBS 1000 μg/kg; PFHxS 1000 μg/kg; PFOS and related substances Sum = 2000 μg/kg; PFDS 1000 μg/kg; PFBA 1000 μg/kg; PFHxA = 25 μg/kg, PFHxA-related substances = 1000 μg/kg; PFOA = 25 μg/kg, PFOA-related substances = 1000 μg/kg; PFDA 1000 μg/kg; 4:2, 6:2, 8:2 and 10:2 FTOH 1000 μg/kg each; total fluorine screening quantification limit 50mg/kg.","timing":"As VN-19.","verificationMethod":"Fetched PDF (as VN-19)"},{"claim":"The ZDHC ChemCheck report, which ZDHC says chemical formulators should share with customers, identifies a DWR product by organisation, product name, product ID and classification, and states its MRSL conformance level, MRSL version, certification body and certificate dates. Its listed contents include no Chemical Abstracts Service (CAS) numbers or composition: chemical supplier to mill, this channel passes a product name plus a conformance level, not chemical identity.","claimType":"voluntary-standard","conditions":"Only for products published on the ZDHC Gateway Chemical Module. ZDHC's supplier guidance tells mills to 'Request all chemical formulators to provide a ChemCheck Summary Report' (programme page, 6 Aug 2026).","confidence":"medium","contrary":null,"decisionSupported":"Mill confirming before purchase that a named DWR product is certified MRSL-conformant, and until when","documentRef":"Sections 'What's in a ChemCheck Report?' and 'Reports'","exemptions":null,"fields":["chemical","record"],"handovers":["h1"],"id":"VN-21","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"Absence of CAS numbers is inferred from the listed contents, not stated by ZDHC. Search snippets of a ZDHC Knowledge Base article say a safety data sheet (SDS) is required to publish a product and is accessible to registered suppliers and brands, but the page was blocked (Cloudflare) and is not verified. The Gateway was relaunched on 20 Aug 2026; report contents may have changed.","materialStatus":"mixture","note":null,"passage":"A ChemCheck Report is a product passport for a chemical formulation. It demonstrates the conformance of the product, in line with the ZDHC MRSL. [...] Each report includes the organisation name, product name and product ID, current ZDHC MRSL conformance level (Level 1, 2, or 3), the ZDHC MRSL version the certification is based on, name of the certification body, certification issue date and expiration date, and product classification. [...] ZDHC ChemCheck is a product passport of chemical formulations that verifies ZDHC MRSL conformance. Chemical formulators should share this report with their customers.","passageLanguage":"en","passageTranslation":null,"pinpoint":"'What's in a ChemCheck Report?'; 'Reports'","recipient":"Finishing mill; brands and vendors using the ZDHC Gateway","sender":"Chemical formulator (DWR supplier)","sourceDate":null,"sourceId":"src-a6773f6a","threshold":null,"timing":null,"verificationMethod":"Fetched official ZDHC Gateway web page (undated; footer copyright 2023). Corroborated by ZDHC slide deck 'Introduction to ZDHC-MRSL' (2025, hosted by TURI), slide 20: 'The ChemCheck Report provides a SUMMARY of the MRSL Conformance of your chemical formulation: • ZDHC MRSL conformance level • Product name'."},{"claim":"Since November 2025, chemical formulators can print a ZDHC QR code on drums or packaging. A mill worker who scans it, without logging in, sees product name, product ID, status, expiry, MRSL conformance level, Chemicals to Zero level, substrate and use category, enough to check conformance on delivery. The listed fields include no composition and no hazard or handling information.","claimType":"voluntary-standard","conditions":"Optional for formulators; only for products published on the Gateway.","confidence":"medium","contrary":null,"decisionSupported":"Mill confirming on delivery that the drum's product is a valid, in-date MRSL-conformant listing","documentRef":"ZDHC news post","exemptions":null,"fields":["record","chemical","handling"],"handovers":["h1"],"id":"VN-22","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"Announced before the 20 Aug 2026 Gateway relaunch; not confirmed to persist. Uptake unknown. Worker hazard information comes from the SDS and the drum's hazard label under national law, outside this claim.","materialStatus":"mixture","note":null,"passage":"These QR codes can be printed on product barrels or packaging, making it easier for suppliers and other stakeholders to instantly access key product information. [...] When a supplier scans a QR code, they’ll immediately see: / Product Name, PID, Status, Expiration Date, and Last Updated Date / ZDHC MRSL Conformance Level and Chemicals to Zero Level / Substrate, Use Category, and Use Type [...] Instant verification: Check ZDHC MRSL conformance upon delivery. / Quick access to details: View key product data in one scan, even without logging in. [...] While the use of QR codes remains optional, ZDHC encourages all formulators to start implementing them to make chemical information more accessible, transparent, and trusted across the industry.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Sections 'What's changing?', 'For Suppliers', 'What's Next?' (list items joined with ' / ')","recipient":"Finishing mill goods-in staff and workers","sender":"Chemical formulator (QR code on drum or packaging)","sourceDate":"2025-10-30","sourceId":"src-4978a5fd","threshold":null,"timing":"Available from the week of 3 November 2025.","verificationMethod":"Fetched official ZDHC news post (HTML)"},{"claim":"ECO PASSPORT by OEKO-TEX certifies textile and leather chemicals, colourants and auxiliaries, such as a DWR agent. It is a chemical product certification, not a digital product passport. ZDHC recognises it as MRSL 3.1 conformance level 1, or level 2 with an on-site visit. However, formulation details given to OEKO-TEX stay confidential, and the mark does not guarantee that treated fabric will meet STANDARD 100.","claimType":"voluntary-standard","conditions":"Validity is at most 12 months, and 'the testing processes and threshold values apply that were valid at the time the certificate was issued'. Level 3 needs passing the optional chemical hazard assessment questions.","confidence":"high","contrary":"Continuity: one certificate gives the mill a third-party conclusion that maps onto the ZDHC MRSL, which many brands require.","decisionSupported":"Whether a DWR agent has been screened by CAS (Chemical Abstracts Service) number and tested against the OEKO-TEX and ZDHC restricted lists, so a ZDHC-aligned mill can accept it. Not how to handle it, and not what it contains.","documentRef":"Sections 1, 3.1, 4.2, 4.3.1, 4.3.6, 4.7.2","exemptions":null,"fields":["chemical","record"],"handovers":["h1"],"id":"VN-23","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"It does not give mill workers hazard or handling information; that is the safety data sheet's job. The standard does not mention digital product passports, so 'not a digital product passport' is the plain reading of its scope. Disclosing the formulation to OEKO-TEX does not disclose it to the mill.","materialStatus":"mixture","note":null,"passage":"The OEKO-TEX® ECO PASSPORT standard is a normative document that defines the technical conditions for the certification of textile and leather chemicals, colourants and auxiliaries [...] the trademark is not a statement regarding quality or legal aspects, such as bans in certain regions of the world. [...] The trademark does not represent a guarantee that the articles treated with the products always fulfil the requirements of OEKO-TEX® STANDARD 100 [...] Certification of ECO PASSPORT with CAS Number Screening, Analytical Verification and Self-Assessment is recognized by the ZDHC organisation as \"MRSL 3.1 conformance level 1\". A certification with an added On-Site Visit raises the conformance level to level 2. [...] The details given here are handled strictly confidential and are not given to third parties under any circumstances. [...] Any substances restricted in the Annex 4 as well as the ECO PASSPORT RSL may not be added to a product for intentional use, even if it is below the threshold. If a substance serves a function in the product it is seen as intentional use.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Section 1 (p.3); 3.1 (pp.3 to 4); 4.2 (p.5); 4.3.1 (p.6); 4.3.6 (p.7); 4.7.2 (p.9)","recipient":"Finishing mill (Vietnam)","sender":"Chemical supplier holding the ECO PASSPORT certificate, issued by an OEKO-TEX institute","sourceDate":"2026-08-21","sourceId":"src-33740c8a","threshold":"For water repellents: total fluorine 50 mg/kg; PFAS 25 µg/kg; restrictions not possible (R2-030).","timing":"Edition 03.2026, dated 21 August 2026. A new PFAS testing method for ECO PASSPORT applies from January 2026 (OEKO-TEX news, 6 October 2025).","verificationMethod":"Fetched official PDF"},{"claim":"AFIRM's PFAS phase-out guidance asks material suppliers, such as a finishing mill, to tell downstream customers when a material is water-repellent and what type of treatment (finish, coating, membrane or other) is used, and to collect and share safety data sheets (SDSs) and technical data sheets (TDSs). Because PFAS not classified as hazardous might not appear on an SDS, it recommends written confirmation from chemical suppliers that formulations are not PFAS-based.","claimType":"voluntary-standard","conditions":"Recommended best practice of AFIRM member brands; Vietnamese edition available.","confidence":"high","contrary":null,"decisionSupported":"Garment factory and brand learning that the fabric is DWR-treated and the treatment type, to decide what evidence to request","documentRef":"Communicating & Implementing PFAS Elimination from Products","exemptions":null,"fields":["chemical","record"],"handovers":["h1","h2"],"id":"VN-24","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"Recommendation, not requirement; no evidence here that mills actually notify. The notification covers treatment type, not identity or concentration; a written statement is a declaration, not a test.","materialStatus":"mixture","note":null,"passage":"1 Ask your chemical suppliers to provide a durable water-repellent/resistant/proof (DWR) or stain/oil-repellent/resistant finish that does not contain and is not based on PFAS. 2 Notify your downstream customers if a material is considered stain/oil-repellent/resistant, water-repellent/resistant/proof (DWR), or quick-dry and what type of treatment (finish, coating, membrane, or other) you plan to use. 3 Collect and share up-to-date SDSs and TDSs for all chemicals used in your manufacturing facility, such as finishing mixtures, mold sprays, machinery lubricants, cleaning agents, etc. None of these should indicate the presence of PFAS. Note that PFAS not classified as hazardous might not be listed in SDSs, therefore ask your chemical suppliers to confirm that all chemical formulations do not contain PFAS and are not based on PFAS chemistry. [...] Ask your suppliers to provide evidence and/or a written statement from their upstream chemical and material suppliers that PFAS substances, including membranes like PTFE, are not present in their materials or chemical formulations and are not formed during manufacturing.","passageLanguage":"en","passageTranslation":null,"pinpoint":"p. 3, 'Steps for Material Suppliers' 1 to 3; 'Steps for Brands' 5 (footnote marker 8 omitted)","recipient":"Finishing mill; garment factory and brand","sender":"Chemical supplier (to mill); finishing mill (to garment factory and brand)","sourceDate":"2025-10-31","sourceId":"src-0a0b3a4c","threshold":null,"timing":null,"verificationMethod":"Fetched official PDF"},{"claim":"AFIRM publishes its 2026 RSL and its PFAS phase-out guidance in Vietnamese. The Vietnamese RSL carries the PFAS limits and a note that French Decree No. 2025-1376 on PFAS risks entered into force on 1 January 2026, so the French market rule is signposted in the mill's own language at the production end of the chain.","claimType":"voluntary-standard","conditions":"Vietnamese PFAS guidance: https://afirm-group.com/wp-content/uploads/2025/12/VI-AFIRM_Phaseout_PFAS_2025_1031.pdf","confidence":"high","contrary":null,"decisionSupported":"Vietnamese supplier understanding which PFAS limits and market rules its brand customers apply","documentRef":"PFAS rows","exemptions":null,"fields":["chemical","result"],"handovers":["h1","h2"],"id":"VN-25","jurisdiction":"International (Vietnamese edition; refers to France)","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"Availability in Vietnamese does not show that staff receive, read or use it. AFIRM's summary of the decree is not the legal text. The Vietnamese cover renders 'Version 11' as 'Phiên bản Tháng 11' (literally 'November version').","materialStatus":"article","note":null,"passage":"Tất cả PFAS được đo bằng tổng flo [...] 50 ppm [...] Lưu ý: Kể từ ngày 1 tháng 1 năm 2026, Nghị Định Số 2025-1376 của Pháp về phòng ngừa rủi ro liên quan đến PFAS đã chính thức có hiệu lực. Quy định này áp dụng các biện pháp kiểm soát nghiêm ngặt đối với PFAS trong nhiều loại sản phẩm tiêu dùng, phù hợp với các giới hạn, hạn chế PFAS chung do EU đề xuất, đồng thời quy định các trường hợp miễn trừ bao gồm vật liệu tái chế và đưa ra thời gian bán hết hàng tồn kho hiện có được sản xuất trước ngày 1 tháng 1 năm 2026. Hướng dẫn bổ sung về Nghị Định sẽ sớm được ban hành.","passageLanguage":"vi","passageTranslation":"All PFAS as measured by total fluorine [...] 50 ppm [...] Note: From 1 January 2026, French Decree No. 2025-1376 on the prevention of risks related to PFAS has officially entered into force. This regulation applies strict controls on PFAS in many types of consumer products, consistent with the general PFAS limits and restrictions proposed by the EU, while providing exemptions including recycled materials and a period to sell off existing stock produced before 1 January 2026. Further guidance on the Decree will be issued soon.","pinpoint":"PFAS rows, PDF p. 35","recipient":"Vietnamese-speaking staff at finishing mills and garment factories","sender":"AFIRM Group","sourceDate":"2026-03-02","sourceId":"src-8a35cb96","threshold":"Tất cả PFAS được đo bằng tổng flo: 50 ppm (All PFAS as measured by total fluorine: 50 ppm)","timing":"AFIRM: 'further guidance on the Decree is forthcoming'.","verificationMethod":"Fetched official PDF (created 2 Mar 2026, modified 22 Sep 2026); translation ours"},{"claim":"A finishing mill's monthly ZDHC Performance InCheck report summarises the MRSL conformance of its whole chemical inventory, and brands connected to the mill on the ZDHC Gateway can review it. This channel runs straight from mill to brand. It reports facility-wide inventory conformance, not which chemicals went into a given fabric roll, and the garment factory is not a named recipient.","claimType":"voluntary-standard","conditions":"In scope for standard chemical users (more than 10 formulations and more than 100 kg per month on average); optional for low chemical users. Self-uploaded; optional on-site Verified InCheck Level 1 or 2.","confidence":"high","contrary":null,"decisionSupported":"Brand monitoring whether a mill uses MRSL-conformant chemicals; not whether a given jacket's fabric is PFAS-free","documentRef":"Version 1","exemptions":null,"fields":["record"],"handovers":["h2","h3"],"id":"VN-26","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"ZDHC's Gateway page adds: 'The report shows what percentage of products in the inventory comply to the ZDHC MRSL, and at what level.' The detailed 'Information and data' pop-up did not load, so whether brands see line items as well as the summary is not established. A conformant inventory does not prove a given roll was finished without PFAS.","materialStatus":"mixture","note":null,"passage":"The Performance InCheck Report generated through the providers' platform is also automatically stored in the supplier’s profile on the ZDHC Gateway, along with the monthly inventory details uploaded by the supplier. [...] The uploaded inventory must not be limited only to a brand-specific inventory (chemicals associated with manufacturing products for a specific brand), as the Performance InCheck aims to reflect the supplier’s full inventory conformance, not just the conformance of products used for particular brand customers. [...] Suppliers should generate a Performance InCheck Report once every month to monitor and improve their chemical inventory continuously. Brands can review reports from their connected suppliers in the ZDHC Gateway to track their chemical inventory performance for ZDHC Chemicals to Zero conformance.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Sections 'Generating the Performance InCheck Report', 'Type of inventory', 'InCheck update frequency'","recipient":"Brands connected to the mill on the ZDHC Gateway","sender":"Finishing mill (wet processor), via a ZDHC-approved InCheck provider","sourceDate":"2026-08-06","sourceId":"src-b7c537c0","threshold":null,"timing":"Monthly; report due within 42 days after the reporting month.","verificationMethod":"Fetched official ZDHC programme web page (HTML)"},{"claim":"In June 2026 ZDHC said PFAS have no place in standard manufacturing and that its immediate focus is intentionally used PFAS in inputs. It acknowledged that newer test methods and broader definitions now find PFAS in some finished articles made with formulations previously considered compliant. ZDHC promised MRSL-related updates and a fuller PFAS communication, including how information should be communicated, for October 2026. None was found on ZDHC's news page on 23 October 2026.","claimType":"voluntary-standard","conditions":null,"confidence":"high","contrary":null,"decisionSupported":"Brand interpreting a PFAS finding in a finished article when inputs were MRSL-conformant","documentRef":"ZDHC news post","exemptions":null,"fields":["chemical","result"],"handovers":["h1","h3"],"id":"VN-27","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"Position statement, not a revised MRSL. Gives no frequency of such findings. Content of the pending update unknown.","materialStatus":"n/a","note":null,"passage":"ZDHC’s position remains clear: PFAS have no place in standard manufacturing. Our immediate focus is to eliminate intentionally used PFAS in manufacturing inputs, while addressing the more complex challenges of detection, trace presence, and practical implementation in a credible, science-based way. At the same time, the industry is undergoing a period of transition. New testing methodologies and evolving regulatory definitions are increasing the detectability of PFAS in finished articles. In some cases, this leads to findings in products manufactured with formulations that were previously considered compliant. [...] It aims to provide clearer direction on PFAS-related risks in chemical formulations, how information should be communicated, and how expectations can be applied in practice. ZDHC will continue this engagement as we develop the next stage of guidance, including MRSL-related updates and a more comprehensive PFAS communication planned for publication in October 2026.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Paragraphs 2, 3, 6 and 7","recipient":"Formulators, mills, brands and solution providers","sender":"ZDHC Foundation","sourceDate":"2026-06-26","sourceId":"src-66e62330","threshold":null,"timing":"Communication planned for October 2026; not published as of 2026-10-23 (news listing checked; latest posts 14, 15, 22 Oct 2026 not about PFAS).","verificationMethod":"Fetched official ZDHC news post (HTML)"},{"claim":"For finished articles, the BSSL (bluesign System Substances List) bans intentional use of PFAS. It checks this against 50 mg/kg total fluorine (TF), a limit that also covers fluoropolymers such as PTFE (polytetrafluoroethylene), and against 25 µg/kg per substance and 250 µg/kg in sum for non-polymer PFAS. A TF result at or above 50 mg/kg requires a review of the chemical formulation, safety data sheet (SDS), technical data sheet (TDS) and other supply-chain records.","claimType":"voluntary-standard","conditions":"'The limits and restrictions shall be applied for each individual component of an intermediate or finished article.' (section 4.1). TF screening and targeted PFAS analysis 'shall be performed in parallel'.","confidence":"high","contrary":"The BSSL says compliance 'only through article testing or supplier declarations alone (as in the conventional RSL approach) is not feasible' (p.3). It also says 'information from the supply chain on possible fluorine compounds should be gathered as part of the overall PFAS assessment' (p.11). The scheme therefore depends on information travelling upstream, not only on testing the finished article.","decisionSupported":"Whether a bluesign Guide-registered fabric can go into a jacket sold with a bluepass claim, and which documents to ask for when a fluorine screen comes back high.","documentRef":"BSSL v17.0, sections 4.1 and 5.8; PFAS limit tables","exemptions":"'Exceptions might be possible for essential use (e.g. for certain PPE)' (section 5.8). PPE means personal protective equipment, and the scenario jacket is not PPE.","fields":["chemical","result","record"],"handovers":["h2","h3"],"id":"VN-28","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"A TF result below 50 mg/kg is not 'PFAS not detected'. TF is a screen with a 20 mg/kg quantification limit and does not identify substances. Guide registration is a conclusion about a component's production process, not a test report the garment factory holds. Whether the scenario membrane is PTFE is not established.","materialStatus":"article","note":null,"passage":"From July 2023 bluesign Guide registration of new articles that were treated with PFAS containing chemicals was no longer possible. [...] By January 2025 all bluesign Approved articles that were treated with PFAS containing chemicals were being removed from the bluesign Guide. [...] Where the TF result is equal to or greater than 50 mg F/kg, the source of the fluorine shall be investigated through a review of the chemical formulation, SDS, TDS, raw-material information, and other relevant supply-chain documentation. [...] The article fails where: [...] The source of an elevated TF result cannot be adequately demonstrated to be non-PFAS. [...] PFAS Polymers | Several | All | Usage ban | [...] Limit 50 mg/kg (total fluorine) applies for all polymers. [...] Polytetrafluoroethylene - PTFE | 9002-84-0","passageLanguage":"en","passageTranslation":null,"pinpoint":"Section 5.8 (pp.10 to 11); PFAS tables (pp.68 to 70)","recipient":"Garment factory and brand","sender":"Finishing mill or laminator (bluesign System Partner), via the bluesign Guide","sourceDate":"2026-07-01","sourceId":"src-04f20c62","threshold":"PFAS: 'Usage ban 50 mg/kg', 'Limit refers to total fluorine content.' PFAS Polymers, including PTFE (9002-84-0): 'Limit 50 mg/kg (total fluorine) applies for all polymers.' PFAS other than polymers and dyes: 'Usage ban 250 μg/kg', 'The limit applies to the sum of all substances, with an additional individual limit of 25 μg/kg for each substance.' TF quantification limit: 20 mg/kg.","timing":"New PFAS-treated articles could not be registered in the bluesign Guide from July 2023. PFAS-treated articles were 'being removed' from the Guide by January 2025. BSSL v17.0 came into force on 1 July 2026. Revised sections are effective by 1 July 2028 at the latest, and the non-polymer PFAS entries state 'Articles shall comply latest 01 July 2028.'","verificationMethod":"Fetched official PDF"},{"claim":"The bluesign system is run by bluesign technologies ag, an SGS company. In 2026 it replaced bluesign APPROVED and bluesign PRODUCT with one mark, bluepass, whose claims 'refer to processes, not to the product itself being certified'. A chemical supplier may give brands the hangtag wording 'bluepass fluorine-free water repellent'. The brand must verify the certified component by its bluesign Guide ID, and cannot call the jacket bluepass certified unless every component meets the thresholds.","claimType":"voluntary-standard","conditions":"Ingredient-level claims need the supplier's authorisation to use its Guide ID. The brand is 'responsible for verifying that the article is in fact certified'.","confidence":"high","contrary":"Hohenstein, an OEKO-TEX institute, states 'OEKO-TEX® does NOT certify the product as \"PFAS-free\"' (secondary source), so the two schemes treat free-from wording differently.","decisionSupported":"What fluorine-free or bluepass wording the brand may use about the water-repellent finish, and whether it may describe the whole jacket as certified.","documentRef":"V4.0, July 2026 (day not stated)","exemptions":null,"fields":["chemical","record"],"handovers":["h1","h3","h4"],"id":"VN-29","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"'Fluorine-free' here is scheme wording for a certified chemical product, bounded by the BSBL usage ban and the 50 mg/kg total fluorine limit. It is not a test result for the jacket and not a legal definition. bluesign assesses 'processes, not facilities as entities, and not products or management systems' (p.33). Hangtags are removed after sale.","materialStatus":"article","note":null,"passage":"© bluesign technologies ag - An SGS Company [...] bluepass replaces the previous bluesign® PRODUCT and bluesign® APPROVED designations. [...] Claims refer to processes, not to the product itself being certified. [...] Manufacturers and chemical suppliers need to prepare the label or hangtag for their certified component and provide it to the brand. They also need to authorise brands to use their bluesign Guide IDs to declare those components in the brand’s own communication. The brand making an ingredient-level claim is then responsible for verifying that the article is in fact certified, using the article’s bluesign Guide ID. [...] A chemical supplier providing a specific chemical product creating a relevant performance may state “bluepass fluorine-free water repellent” on their own consumer facing communication . E.g. hangtags for brands [...] The brand cannot state that the jacket itself is bluepass certified unless every component meets the certification thresholds.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Page footer; p.5; p.24 (principle 01); p.26; p.27","recipient":"Brand placing the jacket on the French market, and then the consumer via the hangtag","sender":"Chemical supplier and fabric manufacturer (bluesign System Partners), who prepare the label or hangtag and authorise use of their bluesign Guide IDs","sourceDate":"2026-07-01","sourceId":"src-d42fba95","threshold":null,"timing":"Guide version 4.0, July 2026. bluepass was 'approved for Europe in 2026'. bluesign has published a note on bluepass and the EU Empowering Consumers Directive, which applies from 27 September 2026. That news item is dated 10 September 2026 and I did not review it in full.","verificationMethod":"Fetched official PDF; ownership also confirmed on bluesign FAQs ('bluesign is an SGS company')"},{"claim":"OEKO-TEX's current restricted substances list (RSL, version 03.2026) marks PFAS 'n.i.u.' (no intentional use). It also sets test limits for STANDARD 100 in every product class: 25 µg/kg for each PFAS, 250 µg/kg for their sum and 50 mg/kg total fluorine. For water repellents certified under ECO PASSPORT, the limits are 50 mg/kg total fluorine and 25 µg/kg for PFAS, and 'restrictions are not possible'.","claimType":"voluntary-standard","conditions":"STANDARD 100 values apply to all product classes and to both Annex 4 and Annex 6. ECO PASSPORT values apply to the chemical product.","confidence":"high","contrary":"Hohenstein states 'OEKO-TEX® does NOT certify the product as \"PFAS-free\"', yet the same page still says 'Limit value is 100 mg/kg'. Secondary pages lag the RSL.","decisionSupported":"Whether a certified DWR agent or finished fabric met defined PFAS and total fluorine limits when tested for certification.","documentRef":"Version 03.2026 - 01.09.2026","exemptions":"[34] 'Total fluorine limits do not apply to fluorine from non-PFAS sources. For STANDARD 100, LEATHER STANDARD and ORGANIC COTTON, when this exception applies it must be mentioned in the scope of the certificate.' Under the 2026 regulations this needs verified evidence and manufacturing documentation identifying the non-PFAS source.","fields":["chemical","result"],"handovers":["h1","h2","h3"],"id":"VN-30","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"The limits apply to the samples tested for certification, not to every production lot. A pass shows measured values below the limits by the stated methods; it is not 'not detected' at all levels, and it does not establish the formulation. The RSL's PFAS definition is OEKO-TEX's own, not a legal one.","materialStatus":"article","note":null,"passage":"PFAS (according to OECD) | various | n.i.u. [...] n.i.u. | no intentional use [...] Sum all PFAS [...] 250 [...] Total fluorine (TF) [34] [...] 50 [...] [28] For repellent products all PFAS threshold and limit values are 25 μg/kg. [34] Total fluorine limits do not apply to fluorine from non-PFAS sources. For STANDARD 100, LEATHER STANDARD and ORGANIC COTTON, when this exception applies it must be mentioned in the scope of the certificate. PFAS definition: fluorinated organic chemicals containing at least one fully fluorinated carbon atom. [35] For water repellents the total fluorine limit value is set to 50 mg/kg [49] For water repellents the limit value is set to 25 µg/kg and restrictions are not possible","passageLanguage":"en","passageTranslation":null,"pinpoint":"RSL worksheet rows 489 (PFAS), 512 (PFHxA), 559 (Sum all PFAS), 561 (Total fluorine); legend; footnotes 28, 34, 35, 49","recipient":"Finishing mill (ECO PASSPORT repellents); garment factory and brand (STANDARD 100 fabric and garments)","sender":"OEKO-TEX institute (test and certificate), via the certified supplier","sourceDate":"2026-09-01","sourceId":"src-4ee17b85","threshold":"'PFAS (according to OECD)': n.i.u. Individual PFAS such as PFHxA: 25 µg/kg. 'Sum all PFAS': 250 µg/kg (STANDARD 100, all classes). 'Total fluorine (TF)': 50 mg/kg (STANDARD 100, all classes); ECO PASSPORT threshold 100 mg/kg, but [35] 'For water repellents the total fluorine limit value is set to 50 mg/kg'. [49] 'For water repellents the limit value is set to 25 µg/kg and restrictions are not possible'.","timing":"The RSL header reads 'Version 03.2026 - 01.09.2026'. The OEKO-TEX primary texts I fetched do not date the cut in total fluorine from 100 to 50 mg/kg. Hohenstein says it is 'being reduced from 100 ppm to 50 ppm in 2026' and that French PFAS requirements were integrated into STANDARD 100 from October 2025 (secondary source).","verificationMethod":"Fetched official spreadsheet (oeko-tex.com); Hohenstein hosts an identical copy"},{"claim":"A STANDARD 100 certificate covers only the articles and components described in its scope, in their as-produced state, for one year. The mark 'is not a quality label', and the certificate number lets anyone check online which criteria applied. From 2026, renewal requires every supplier that does wet or chemical processing, such as the DWR finishing mill, to hold a certificate for that product, and requires upstream certificates from the direct supplier. Both rules have a transition period until June 2027.","claimType":"voluntary-standard","conditions":"The scope lists product category, material composition and processed state (for example 'finished'). Product class II covers articles 'worn with a large part of their surface in direct contact with the skin'; class III covers those 'with only a little part'. The 2026 text gives no jacket example, so the institute sets the class. PFAS limits are the same in all classes.","confidence":"high","contrary":"Continuity: once the transition ends in June 2027, a renewed garment certificate should rest on certificates for each wet-processing step, including DWR finishing. The holder must also 'inform the relevant institute immediately' of changes to materials, procedures or recipes (section 5.10).","decisionSupported":"Whether a named fabric or garment, in the processed state given in the scope, passed OEKO-TEX's harmful-substance limits. Not whether a particular roll or jacket did.","documentRef":"Sections 3.1, 4.3, 5.7, 5.8, 5.10, 6.4","exemptions":null,"fields":["component","record"],"handovers":["h2","h3","h4"],"id":"VN-31","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"A certificate shows that samples met the limits; the holder declares that production stays consistent with them (section 6.3). The mark says nothing about SVHCs (substances of very high concern) outside Annex 4 or 6, or about textile labelling law. The text describes the online lookup as showing which annex applied, not test results. Because the mark covers the as-produced state, it says nothing about a used jacket at H5.","materialStatus":"article","note":null,"passage":"Via the OEKO‑TEX® website (www.oeko-tex.com) and about the certificate number mentioned on the OEKO-TEX® STANDARD 100 mark information can be obtained, whether the testing and certification of the products were performed on the basis of the conditions and criteria according to Annex 4 of this standard or according to those of the Annex 6 [...] The OEKO-TEX® STANDARD 100 trademark is not a quality label. The mark relates only to the as-produced state of the textile or accessory [...] The OEKO-TEX® STANDARD 100 certification and testing by the OEKO-TEX® Institute does not include a check for the availability or provision of complete evidence, certificates, correct information brochures, etc. [...] It is a product description to define the certified articles and components, ensuring that each part of an article group can be clearly identified. [...] For a product to be eligible for STANDARD 100 certification renewal, every manufacturer or commissioner in the product’s supply chain that carries out any wet or chemical processing must hold a valid STANDARD 100 certificate covering that product. [...] For renewals, the upstream certificate must be issued by the direct supplier in order to be accepted. [...] Any product certified under this standard will automatically lose the right to be referred to as certified and to use the STANDARD 100 mark as soon as it is professionally physically or chemically altered or treated. This includes also washing and chemical cleaning. [...] The certificate is permitted to be used in business correspondence only with restricted conditions.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Section 3.1 (pp.4 to 5); 4.3 (p.6); 5.7 and 5.8 (p.10); 5.10 (p.12); 6.4 (p.13)","recipient":"Garment factory and brand; the consumer through the certificate number on the label","sender":"Finishing mill or garment factory holding the certificate, issued by an OEKO-TEX institute","sourceDate":"2026-03-03","sourceId":"src-10f293ff","threshold":"'Any value measured in the laboratory must be below the specified limit to obtain the certificate.' (Annex 4)","timing":"Edition 01.2026, dated 3 March 2026. New or stricter requirements normally apply after a transition 'until the following 1st of June'. The wet-process and direct-supplier rules have a transition until June 2027. Renewal keeps the certificate number and adds exactly one year.","verificationMethod":"Fetched official PDF"},{"claim":"AFIRM separates claims about water-repellent products. 'Water-resistant, -repellent, or -proof' means the product may contain PFAS. 'No PFAS-based DWR finishing' cannot rule out a PFAS membrane such as polytetrafluoroethylene (PTFE). 'No intentional use of PFAS' allows contamination to be detected. Only 'no intentional use of PFAS, and PFAS not detected' covers both, and AFIRM strongly discourages 'free' claims.","claimType":"voluntary-standard","conditions":null,"confidence":"high","contrary":null,"decisionSupported":"Brand judging what a supplier's 'PFAS-free' or 'fluorine-free' statement covers for a jacket with a laminated membrane","documentRef":"Table 1. Examples of PFAS-related Terms and Statements","exemptions":null,"fields":["chemical","record"],"handovers":["h2","h3"],"id":"VN-32","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"'Not detected' is bounded by methods and reporting limits (VN-33). Nothing obliges suppliers to use this vocabulary.","materialStatus":"article","note":null,"passage":"Water-resistant, -repellent, or -proof / Product may contain or be treated with PFAS [...] No PFAS- or PFC-based DWR finishing / Product is not treated with a PFAS-based durable water-repellent (DWR) finish. Sometimes referred to as “C0” by development teams. Inclusion of a PFAS-based membrane like PTFE cannot be ruled out. [...] No intentional use of PFAS / Product is not intentionally treated with PFAS and does not intentionally contain a PFAS-based membrane like PTFE; however, it is possible that PFAS can be detected due to unintended PFAS use in material streams, use of recycled materials that contain PFAS, or other sources of PFAS contamination. / No intentional use of PFAS, and PFAS not detected / Product is not intentionally treated with PFAS, does not contain a PFAS-based membrane like PTFE, and no PFAS can be detected using standardized industry test methods. This is the highest standard and implies alternative treatments, proper chemicals management, and control of contamination and residuals. [...] * AFIRM strongly discourages use of the term “free” to imply that a product does not contain any specific substance.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Table 1 and footnote, p. 2 (term and description joined with ' / ')","recipient":"Garment factory and brand","sender":"Material supplier or brand making a claim","sourceDate":"2025-10-31","sourceId":"src-0a0b3a4c","threshold":null,"timing":null,"verificationMethod":"Fetched official PDF"},{"claim":"AFIRM says no single test both shows compliance with all PFAS rules and proves PFAS were not intentionally used. Total fluorine screening cannot distinguish PFAS from inorganic fluorine, and its best common detection limit is about 20 ppm. Targeted analysis of named PFAS is no guarantee that PFAS were not used. Untreated apparel can show several hundred ppm total fluorine, compared with several thousand ppm typically seen after intentional treatment.","claimType":"voluntary-standard","conditions":null,"confidence":"high","contrary":"The same page also recommends 'a 50 ppm limit on Total Fluorine until a validated method for determining Total Organic Fluorine becomes widely available', so the acceptance basis is internally unsettled.","decisionSupported":"Brand interpreting a fabric or jacket test report as evidence of no intentional PFAS use","documentRef":"Recommended Testing Approach; Defining Acceptance Criteria for Total Fluorine Screening","exemptions":null,"fields":["result","record"],"handovers":["h2","h3"],"id":"VN-33","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"No data source given for 'several hundred ppm'.","materialStatus":"article","note":null,"passage":"There is currently no single test method available that can both validate compliance with all global PFAS restrictions and validate that PFAS were not intentionally used. [...] Does not differentiate between inorganic and organic Fluorine. [...] Does not provide information on the specific Fluorine compounds present. (Total Fluorine content is not the same as PFAS content.) [...] Best detection limit among global commercial labs is generally 20 ppm for individual samples and 50 ppm for a composite of two samples.* [...] Not a guarantee that PFAS have not been used in production or that PFAS are not present in the sample as contamination: PFAS which are not specifically analyzed may still be present.** [...] While intentional use of PFAS is likely to result in concentrations of several thousand parts per million (ppm) Total Fluorine, early screening results for apparel and footwear indicate that Total Fluorine content may be several hundred ppm in samples that have not been intentionally treated with PFAS. [...] In alignment with technical experts and new regulation, AFIRM currently recommends an acceptance limit of 50 ppm Total Organic Fluorine to demonstrate no intentional PFAS use.","passageLanguage":"en","passageTranslation":null,"pinpoint":"p. 3 step 4; Table 3, p. 5; p. 6","recipient":"Mill, garment factory, brand","sender":"Testing laboratory","sourceDate":"2025-10-31","sourceId":"src-0a0b3a4c","threshold":"AFIRM recommends 50 ppm Total Organic Fluorine as acceptance limit (p. 6).","timing":null,"verificationMethod":"Fetched official PDF"},{"claim":"A Nordic Council of Ministers study, submitted to the Strategic Approach to International Chemicals Management (SAICM, predecessor of the Global Framework on Chemicals), drew on interviews mainly with brand owners. It found that textile supply-chain chemical information is mainly SDSs and test reports of variable quality, and mostly 'negative information' about absence rather than which chemicals were used. Exact composition is often withheld as a trade secret, test reports may not state methods or detection limits, and inventories cannot show per-batch use.","claimType":"reported-practice","conditions":null,"confidence":"high","contrary":"The same study reports AFIRM's view that transparency has increased, with some suppliers sharing tier 2 or 3 information (p. 19).","decisionSupported":"Brand verifying supplier compliance claims","documentRef":"SAICM/IP.4/INF/36, annex","exemptions":null,"fields":["chemical","result","record"],"handovers":["h1","h2","h3"],"id":"VN-34","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"2022 interview study of a small, mainly Nordic set of brand owners plus AFIRM; not DWR- or Vietnam-specific; predates the Global Framework on Chemicals (adopted 2023).","materialStatus":"n/a","note":null,"passage":"To show compliance, the core type of chemical information through the supply chain is mainly based on communication of safety data sheets and test reports, both of which can vary significantly in quality. Currently, most information in the textile supply chain is therefore based on “negative information” i.e., information on absence of certain substances as opposed to “positive information” listing which chemicals that are used to produce a certain garment or product. [...] Some companies are experiencing difficulties to get data on the exact composition of chemical products as this information is considered a trade secret, against company policy to disclose or patented by suppliers. [...] It may also be difficult to know which method laboratories are using, what the detection limits are etc, as there is no standard. [...] Even though some companies are working with chemical inventories at their supplier’s factories, it is difficult to know how much was used in the production of exactly each batch.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Annex section 1 Summary, p. 4 (PDF p. 5); section 5.2.1, p. 18 (PDF p. 19)","recipient":"Brand owners","sender":"Chemical suppliers and tiered textile suppliers","sourceDate":"2022-12-30","sourceId":"src-9ed9513c","threshold":null,"timing":null,"verificationMethod":"Fetched official PDF from saicm.org"},{"claim":"In 2025 Vietnam was the second-largest supplier from outside the EU, after China, of synthetic-fibre anoraks and wind-jackets imported into the EU (CN 6201 40 and 6202 40). Those imports were worth €733 million, about 12% of extra-EU imports of these goods, against about 6% of all woven apparel (CN chapter 62). France imported €67 million of these goods directly from Vietnam.","claimType":"technical","conditions":null,"confidence":"high","contrary":"Bangladesh is close behind in both codes (€335 million and €334 million), so the ranking is narrow.","decisionSupported":"For the piece's editors: supports Vietnam as a plausible origin for a rain jacket sold in France.","documentRef":"DS-045409; reporters EU and FR; partners VN, CN, EXT_EU; products 620140, 620240, 621040, 621050, 62; import; VALUE_IN_EUROS; 2025","exemptions":null,"fields":[],"handovers":["h3"],"id":"VN-35","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Shares are calculated from the API values. Chapter 62: Vietnam €2,557,782,339 of €44,823,658,732 extra-EU. A jacket of fabric laminated with plastics may be classified under CN 6210 40 or 6210 50 instead. In 6210 40 Vietnam was third (€58.5 million); in 6210 50 it was outside the top eight. France's total imports under 6201 40 (€610 million) are mostly intra-EU, so the importer of record may be in another member state. Trade value says nothing about chemical information.","materialStatus":"n/a","note":null,"passage":"Men's or boys' overcoats, car-coats, capes, cloaks, anoraks, incl. ski jackets, wind-cheaters, wind-jackets and similar articles, of man-made fibres (excl. knitted or crocheted, suits, ensembles, jackets, blazers and trousers) | reporter EU | partner VN | IMPORT | VALUE_IN_EUROS | 2025 | 348299257 [...] partner EXT_EU | 2565066367 [...] partner CN | 1147417427 [...] product 620240 | partner VN | 384395207 [...] partner EXT_EU | 3340627584 [...] partner CN | 1673686959","passageLanguage":"en","passageTranslation":null,"pinpoint":"DS-045409 API responses for 2025, products 620140 and 620240 (also 62, 621040, 621050, and reporter FR)","recipient":null,"sender":null,"sourceDate":"2026-10-16","sourceId":"src-0947c5db","threshold":null,"timing":"Calendar year 2025; dataset updated 16 October 2026. The EU-Vietnam trade agreement has been in force since 1 August 2020 (European Commission DG Trade).","verificationMethod":"Fetched official API data (Eurostat Comext); the shares and totals are my calculation"},{"claim":"The waterproof membrane laminated into many rain jackets is polytetrafluoroethylene (PTFE), often in expanded form (ePTFE). The Swedish Chemicals Agency (KEMI) classes PTFE as a fluoropolymer within the per- and polyfluoroalkyl substances (PFAS) group, so a jacket can contain PFAS in its membrane whatever chemistry is used for the durable water-repellent (DWR) finish.","claimType":"technical","conditions":"Applies only where the membrane is PTFE or ePTFE. Polyurethane and polyester membranes are also used (TECH-03).","confidence":"high","contrary":"Fluoropolymer producers have argued that fluoropolymers such as PTFE are 'polymers of low concern' to be managed separately from other PFAS; Lohmann et al. (2020, Environmental Science & Technology 54(20):12820, open access) dispute this. Whether a given legal restriction treats fluoropolymers differently is for R1.","decisionSupported":"Whether a 'fluorine-free DWR' or 'PFAS-free' statement covers the whole jacket or only the face-fabric finish","documentRef":"KEMI Report 7/15, section 6.2 'Textiles and leather'","exemptions":null,"fields":["component","chemical"],"handovers":["h2","h3","h4","h5","h6"],"id":"TECH-01","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Does not show which membrane any particular jacket uses. The 10 micrometre figure is the report's example, not a general specification. Classing PTFE as PFAS is a structural classification, not a hazard, exposure or risk conclusion.","materialStatus":"article","note":null,"passage":"1) High molecular weight polytetrafluoroethylene (PTFE), which belongs to the PFAS group of fluoropolymers. [...] A 10 micrometre thick membrane of PTFE is laminated onto a conventional textile material to impart mechanical strength.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Page 33, section 6.2","recipient":"Garment factory; brand or importer; later holders of the jacket","sender":"Finishing mill or laminator (H2); garment factory (H3)","sourceDate":"2015-01-01","sourceId":"src-afd02524","threshold":null,"timing":null,"verificationMethod":"Fetched official PDF from kemi.se and extracted text; title page confirms Report 7/15 despite the file name. Source gives year only (2015); recorded as 1 January. A trade name in the original is omitted."},{"claim":"EU law already uses the Organisation for Economic Co-operation and Development (OECD) structural definition of PFAS: any substance with at least one fully fluorinated methyl (CF3) or methylene (CF2) carbon atom. PTFE, built from repeating CF2 units, and side-chain fluorinated DWR polymers both fall within it. The definition names a group, not an exact substance.","claimType":"legal","conditions":"The definition appears in REACH Annex XVII entry 82, which restricts PFAS in firefighting foams only. It is cited here for its scope; this entry places no duty on textiles. Restrictions that apply to clothing, including France's, are covered by R1 and may word the definition differently.","confidence":"high","contrary":null,"decisionSupported":"Whether a material counts as 'PFAS' where a buyer's requirement or a restriction uses the OECD-based definition","documentRef":"Regulation (EU) 2025/1988, recital 1 and Annex (REACH Annex XVII, entry 82)","exemptions":null,"fields":["chemical"],"handovers":["h1","h2","h3"],"id":"TECH-02","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":null,"limitations":"The text does not name PTFE or side-chain fluorinated polymers. That they fall within it follows from their structure and is stated by the European Environment Agency (EEA, 'PFAS polymers in focus', 29 April 2025: 'the PFAS polymer polytetrafluorethylene (PTFE)') and KEMI (TECH-01). A group definition does not tell a recipient which PFAS is present or how much.","materialStatus":"n/a","note":null,"passage":"PFAS are defined by the Organisation for Economic Cooperation and Development (‘OECD’) as any substances that contain at least one fully fluorinated methyl (CF3) or methylene (CF2) carbon atom (without any H/Cl/Br/I atom attached to it) [...] ‘82. Per- and polyfluoroalkyl substances (PFAS) defined as: any substance that contains at least one fully fluorinated methyl (CF3) or methylene (CF2) carbon atom (without any H/Cl/Br/I attached to it).","passageLanguage":"en","passageTranslation":null,"pinpoint":"Recital 1; Annex, entry 82, column 1","recipient":null,"sender":null,"sourceDate":"2025-10-02","sourceId":"src-fa0c0778","threshold":null,"timing":null,"verificationMethod":"Fetched official text from the EU Publications Office (CELEX 32025R1988) by content negotiation. Subscripts in CF3 and CF2 flattened."},{"claim":"The waterproof layer of a rain jacket can be a microporous membrane of PTFE or polyurethane (PU), or a non-porous hydrophilic membrane of PU or polyester. A DWR finish is applied to the outer fabric of all shell garments whichever membrane is used, so the finish and the membrane raise separate chemical questions.","claimType":"technical","conditions":null,"confidence":"high","contrary":null,"decisionSupported":"Which components a chemical declaration must cover, and whether the membrane is a possible fluorine source","documentRef":"Hill, P.J., PhD thesis, School of Design, University of Leeds, sections 1.2.2.1 and 1.2.2.3","exemptions":null,"fields":["component"],"handovers":["h2","h3"],"id":"TECH-03","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"A doctoral thesis, not a standard. Gives no market shares of membrane types and says nothing about which is used in Vietnamese production.","materialStatus":"article","note":null,"passage":"Microporous membranes or coatings – thin films of polymer with interconnected holes allowing the transfer of moisture vapour but too small for the penetration of water droplets [3]. Made from polyurethane (PU) or polytetrafluoroethylene (PTFE) this technology is used widely within outer layers [...] Hydrophilic membranes or coatings – continuous impermeable membranes which rely on the diffusion gradient for transfer of moisture vapour through the hydrophilic segments [3,34]. Made from hydrophilic polyurethanes or polyesters with polyethylene oxide (PEO) [...] To all shell garments, a DWR is applied to the outer fabric surface to impart liquid resistance","passageLanguage":"en","passageTranslation":null,"pinpoint":"Printed pages 10 and 12 (PDF pages 36 and 38)","recipient":"Garment factory; brand or importer","sender":"Finishing mill or laminator","sourceDate":"2019-04-01","sourceId":"src-d7647d75","threshold":null,"timing":null,"verificationMethod":"Fetched thesis PDF from White Rose eTheses and extracted text. Month of award only (April 2019); day recorded as 1. Trade names omitted."},{"claim":"In all-weather clothing, fluorine can come from two places: a porous PTFE membrane and an outer nylon or polyester fabric treated with side-chain fluorinated polymers (SFPs). KEMI reports that the volatile fluorotelomer alcohols (FTOHs) found in clothing come from the SFP finish, not the membrane, and puts PFAS at about 2 to 3 per cent of fibre weight in treated textiles.","claimType":"technical","conditions":null,"confidence":"high","contrary":"KEMI (pages 14 to 15) notes that although fluoropolymers are not made from perfluorinated carboxylic acids (PFCAs), PFCA variants are used as process chemicals and 'the finished product may contain residues of these substances', so a PTFE membrane is not necessarily free of non-polymeric PFAS.","decisionSupported":"Which component a positive fluorine or FTOH result should be attributed to","documentRef":"KEMI Report 7/15, section 6.2 'Textiles and leather'","exemptions":null,"fields":["component","chemical","result"],"handovers":["h2","h3","h5","h6"],"id":"TECH-04","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"The 2 to 3 per cent figure is a general figure for treated textiles from 2015, not a measured add-on for any jacket. KEMI cites Buck et al. (2011) for the FTOH attribution; that study was not fetched.","materialStatus":"article","note":null,"passage":"PFAS contribute circa 2-3 percent of fibre weight in textiles and around 15 percent in synthetic carpets. [...] With so-called all-weather clothing it is normal for different parts of the garment to consist of different types of polymers. A porous PTFE membrane is often used to allow the garment to \"breathe\". Moreover, the outer later can consist of nylon or polyester that has been treated with side-chain fluorinated polymers. [...] The fluorotelomer alcohols observed in clothing are from the side-chain fluorinated polymer and not from the PTFE membrane. (Buck et al. 2011).","passageLanguage":"en","passageTranslation":null,"pinpoint":"Pages 33 to 34, section 6.2 ('later' is sic for 'layer')","recipient":"Garment factory; brand or importer; sorter","sender":"Finishing mill (H2); garment factory (H3)","sourceDate":"2015-01-01","sourceId":"src-afd02524","threshold":null,"timing":null,"verificationMethod":"Fetched official PDF from kemi.se and extracted text. Source gives year only (2015); recorded as 1 January."},{"claim":"The DWR finish is applied at the finishing mill, after dyeing or printing and before garment making, as a thin film by a pad-dry-cure process together with other finishing auxiliaries, then cured in an oven at up to 180°C. The mill is therefore the last actor in the chain to handle the finish as a chemical mixture; from H2 onwards it travels as part of a treated fabric.","claimType":"technical","conditions":null,"confidence":"high","contrary":"Garments can be re-treated after sale with consumer reproofing products, which are mixtures with their own labelling; Hill (2019, TECH-03 source, section 3.2) studied brand advice on cleaning and reproofing.","decisionSupported":"Which actor needs hazard and handling information for the DWR as a mixture, and which receives only a treated article","documentRef":"Danish EPA Survey No. 137 (Lassen, Jensen and Warming; COWI and NIPSECT), ISBN 978-87-93352-16-2, section 2.1","exemptions":null,"fields":["chemical","handling"],"handovers":["h1","h2"],"id":"TECH-05","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Describes general practice, not a specific Vietnamese mill. That the mill is the last actor to handle the finish as a mixture is our inference from the process description.","materialStatus":"mixture","note":null,"passage":"durable water repellent (DWR) finishes are mostly applied to fabrics after dyeing and/or printing, but before the fabrics are made into garments. [...] The side-chain fluorinated polymers are applied as a thin film on the fabric surface, usually in combination with other finishing auxiliaries, by a pad-dry-cure process [...] followed by drying and curing in an oven at temperatures up to 180°C.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Page 19, section 2.1","recipient":"Finishing mill and its workers (H1); garment factory (H2)","sender":"Chemical supplier (H1); finishing mill (H2)","sourceDate":"2015-05-01","sourceId":"src-a3cfb170","threshold":null,"timing":null,"verificationMethod":"Fetched official PDF from mst.dk and extracted text. Month taken from the publication path (May 2015); day recorded as 1."},{"claim":"A chain-length description such as 'C6' describes the intended chemistry of an SFP product, not its full content. KEMI reports an industry figure of under 0.01 per cent C8 residue in C6 products alongside studies finding large contents of C8 and longer chains in products marketed as 'C6', and notes that SFPs can contain or degrade to FTOHs and to perfluorinated carboxylic acids such as perfluorooctanoic acid (PFOA) and perfluorohexanoic acid (PFHxA).","claimType":"technical","conditions":null,"confidence":"high","contrary":"Industry figure cited by KEMI on the same page: residual C8 below 0.01 per cent in C6 end products.","decisionSupported":"Whether a supplier's chain-length description is enough to conclude that a finish meets limits on PFOA, PFHxA or longer-chain related substances","documentRef":"KEMI Report 7/15, pages 16 and 33","exemptions":null,"fields":["chemical","result","record"],"handovers":["h1","h2","h3"],"id":"TECH-06","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"2015 evidence; impurity levels may have fallen since and much of the market has moved to fluorine-free DWRs. The underlying studies (SUPFES 2015, Posner 2015) were not fetched. Describes no specific product.","materialStatus":"mixture","note":null,"passage":"The intermediate C6 product contains around 20 percent C8 which to a large extent is removed before the end product is brought onto the market. According to industry residual content is less than 0.01% of C8 in the C6 end product (European Commission 2014). However, there are studies which show that C6 products have large contents of both C8 and longer carbon chains. In some cases the content of C8 can be more or less higher than that of C6 despite the fact that it is marketed as \"C6\" (SUPFES 2015). [...] These polymers can contain residues of, or are broken down to, fluorotelomers (such as 8:2 FTOH and 6:2 FTOH) or perfluorinated carboxylic acids (such as PFOA and PFHxA) (Posner 2015).","passageLanguage":"en","passageTranslation":null,"pinpoint":"Page 16; page 33, section 6.2","recipient":"Finishing mill; later, garment factory and brand","sender":"Chemical supplier","sourceDate":"2015-01-01","sourceId":"src-afd02524","threshold":null,"timing":null,"verificationMethod":"Fetched official PDF from kemi.se and extracted text. Source gives year only (2015); recorded as 1 January."},{"claim":"Fabric coated with an SFP-based DWR can carry unreacted residues and impurities, the DWR emulsion itself mixes polymers with shorter and longer side chains, and ageing of coated fabric increased the measured perfluoroalkyl acids (PFAAs). The chemistry on a jacket at sale or at collection is not the same as the chemistry in the finishing bath.","claimType":"technical","conditions":null,"confidence":"high","contrary":"The same study found that washing decreased PFAA concentrations and that tumble drying did not affect PFAS concentrations.","decisionSupported":"Whether a test or declaration made at one handover still describes the garment at a later one","documentRef":"van der Veen et al. 2022, Environ. Sci. Technol. 56(9):5886–5897, doi:10.1021/acs.est.1c07876","exemptions":null,"fields":["chemical","result"],"handovers":["h1","h2","h4","h5"],"id":"TECH-07","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Laboratory-coated polyamide and polyester fabrics with FC-6 and FC-8 DWRs, not commercial jackets; says nothing about fluorine-free DWRs. Consistent with a 2025 study of multi-layer outdoor jacket fabrics treated with a C6 SFP (Journal of Hazardous Materials 487:137218, abstract only), which reports that 'aging causes a reduction in TF content and an increase in PFAS migration to inner fabric layers'.","materialStatus":"article","note":null,"passage":"Although the DWR coating of fabrics consists mainly of SFPs, after coating, some unreacted ionic or volatile PFAS residuals or impurities might still be present on the fabrics. [...] DWR emulsions used for coating the fabrics often consist of a mixture of the desired SFPs and fluorinated polymers with shorter and longer side chains as a result of the production process. [...] Results show that aging of the coated fabrics causes an increase in concentration and formation of perfluoroalkyl acids (PFAAs).","passageLanguage":"en","passageTranslation":null,"pinpoint":"Introduction; Abstract","recipient":null,"sender":null,"sourceDate":"2022-04-11","sourceId":"src-dbac4720","threshold":null,"timing":null,"verificationMethod":"Fetched open-access full text (PubMed Central PMC9069696)."},{"claim":"Researchers comparing DWR chemistries coated their own fabrics because, for commercial outdoor clothing, it is often unknown which DWR chemistry and other additives were applied. Even specialists could not rely on information travelling with commercial garments to tell which finish they carried.","claimType":"technical","conditions":null,"confidence":"high","contrary":"Some care labels name the membrane (TECH-28).","decisionSupported":"Whether the finish chemistry can be established from the garment and the information that comes with it","documentRef":"van der Veen et al. 2022, Environ. Sci. Technol. 56(9):5886–5897, doi:10.1021/acs.est.1c07876","exemptions":null,"fields":["chemical","record"],"handovers":["h3","h4","h5","h6"],"id":"TECH-08","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"An authors' remark explaining study design, not a survey of disclosure practice. Brands and their suppliers may hold this information without it reaching researchers or consumers.","materialStatus":"article","note":null,"passage":"Commercially available textiles of outdoor clothing are less suitable to make a good comparison between different DWR chemistries, because it is often unknown what type of DWR chemistry was applied on those textiles and which other additives are present.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Introduction","recipient":"Consumer; sorter; researcher","sender":"Brand or retailer","sourceDate":"2022-04-11","sourceId":"src-dbac4720","threshold":null,"timing":null,"verificationMethod":"Fetched open-access full text (PubMed Central PMC9069696)."},{"claim":"Fluorine-free DWRs can provide water repellency, but a Danish Environmental Protection Agency (Danish EPA) survey found none that repel oil, alcohol or oil-based dirt as PFAS-based finishes do. Water repellency is therefore not evidence of PFAS; strong oil repellency points towards fluorinated chemistry but is not a test for it.","claimType":"technical","conditions":null,"confidence":"high","contrary":"Hill et al. (2017, Chemosphere, abstract only) found water repellency ratings 'similar across the range of all finished fabrics tested' and called PFAS chemistry for such garments 'over-engineering', so the oil-repellency difference may not matter to the wearer.","decisionSupported":"Whether a performance claim or repellency rating can stand in for a chemistry declaration","documentRef":"Danish EPA Survey No. 137, summary","exemptions":null,"fields":["chemical"],"handovers":["h1","h3","h4"],"id":"TECH-09","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"2015 market. The inference from oil repellency to fluorinated chemistry is ours and is not a substitute for analysis. Consistent with Schellenberger et al. (2018, Chemosphere 193:675–684, abstract only): 'Non-fluorinated alternatives were unable to repel oil', and 'A strong decline in oil repellency and durability with perfluoroalkyl chain length was shown for SFP DWRs', so short-chain fluorinated finishes also repel oil less well.","materialStatus":"article","note":null,"passage":"Many different agents providing water repellency are marketed, but none of these agents provides efficient repellency against oil, alcohol and oil-based dirt. [...] In summary, it can be concluded that no alternatives matching the PFAS-based repellents on all technical parameters are available. For some applications, where repellency against oil, alcohol and oil-based dirt is not required, the alternatives are considered to provide acceptable properties","passageLanguage":"en","passageTranslation":null,"pinpoint":"Page 7, summary","recipient":"Finishing mill; consumer","sender":"Chemical supplier; brand","sourceDate":"2015-05-01","sourceId":"src-a3cfb170","threshold":null,"timing":null,"verificationMethod":"Fetched official PDF from mst.dk and extracted text. Month taken from the publication path; day recorded as 1."},{"claim":"'Fluorine-free' does not mean 'hazard-free'. A 2016 review found that impurities or degradation products of every DWR chemistry reach the environment, ranked hydrocarbon DWRs as the most environmentally benign followed by silicone and then SFP-based chemistries, and found hazard data lacking for dendrimer and nanoparticle finishes. This is a hazard ranking, not a product-specific exposure or risk conclusion.","claimType":"technical","conditions":null,"confidence":"medium","contrary":"The same abstract notes that 'Industrial commitments to reduce the levels of impurities in silicone based and side-chain fluorinated polymer based DWR formulations will lower the actual risks.'","decisionSupported":"What hazard information a mill or brand needs about a fluorine-free finish beyond whether it is fluorinated","documentRef":"Holmquist et al. 2016, Environ. Int. 91:251–264","exemptions":null,"fields":["chemical","handling"],"handovers":["h1","h2"],"id":"TECH-10","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Abstract only. A corrigendum was published in 2020 and was not reviewed. The ranking covers environmental hazard of selected emitted substances, not worker exposure at the mill.","materialStatus":"mixture","note":null,"passage":"Our review shows that there are large differences in performance between the alternative DWRs, most importantly the lack of oil repellence of non-fluorinated alternatives. It also shows that for all alternatives, impurities and/or degradation products of the DWR chemistries are diffusively emitted to the environment. Our hazard ranking suggests that hydrocarbon based DWR is the most environmentally benign, followed by silicone and side-chain fluorinated polymer-based DWR chemistries. [...] There is a lack of information on the hazards associated with DWRs, in particular for the dendrimer and inorganic nanoparticle chemistries, and these data gaps must be filled.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Abstract","recipient":"Finishing mill and its workers","sender":"Chemical supplier","sourceDate":"2016-03-16","sourceId":"src-5bd0f09e","threshold":null,"timing":null,"verificationMethod":"Abstract only, fetched via Europe PMC; full text paywalled."},{"claim":"The Danish EPA found the compositions of alternative water-repellent agents mainly confidential, with some containing isocyanates, dipropylene glycol, metal salts or other unspecified substances. It found hardly any information on the trace raw materials, intermediates and degradation products left in finished textiles.","claimType":"reported-practice","conditions":null,"confidence":"high","contrary":"Confidential disclosure to authorities or to buyers under contract is not captured by a review of public information.","decisionSupported":"Whether the mill or brand can learn the full formulation, and what remains on the fabric","documentRef":"Danish EPA Survey No. 137, summary and conclusions","exemptions":null,"fields":["chemical","result","record"],"handovers":["h1","h2","h3"],"id":"TECH-11","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Refers to public information in 2015. A mill or brand may receive more under contract or through industry chemical-management programmes (other work packages). Does not cover Vietnamese suppliers.","materialStatus":"mixture","note":null,"passage":"The compositions of the products are mainly confidential, but some products also contain isocyanates, dipropylene glycol, metal salts or other unspecified substances, which may be harmful. [...] For most of the alternative impregnation agents reviewed, there is insufficient qualitative and quantitative public information about the ingredients. Most products do not have information available because they are protected by trade secrets. [...] For all of the alternatives, hardly any information on trace levels of raw materials, intermediates and degradation products in the final textile products is available.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Pages 7 and 9","recipient":"Finishing mill; garment factory; brand","sender":"Chemical supplier","sourceDate":"2015-05-01","sourceId":"src-a3cfb170","threshold":null,"timing":null,"verificationMethod":"Fetched official PDF from mst.dk and extracted text."},{"claim":"Supplier information for alternative water-repellent agents summarised by the Danish EPA described ingredients only as 'an unknown functionalized polymer' or 'an unknown organic silicon compound' with concentration ranges, and producers' statements that products need no environmental classification could not be verified. A record like this tells the mill a polymer is present but not what it is.","claimType":"reported-practice","conditions":null,"confidence":"medium","contrary":"Suppliers may list all ingredients voluntarily, as GHS and REACH allow (TECH-13, TECH-15).","decisionSupported":"Whether the mill can tell from supplier documents if a finish is fluorinated","documentRef":"Danish EPA Survey No. 137, summary and product assessments","exemptions":null,"fields":["chemical","result","record"],"handovers":["h1"],"id":"TECH-12","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"The report does not always say whether each detail came from a safety data sheet or other supplier information. The examples are fluorine-free products sold in Europe in 2015, not Vietnamese supplies. 'Unknown' reflects what was disclosed, not what the supplier knows.","materialStatus":"mixture","note":null,"passage":"Environmental assessment - The composition of the commercial product is not detailed, either qualitatively or quantitatively. According to the producer's information, the products should not be labelled or classified as harmful for the environment. However, it is not possible to verify these claims because of lack of relevant data. [...] The product contains 5-15% of an unknown functionalized polymer, and 0.5-1% of an unknown cationic surfactant. [...] Information about the exact composition of the product is not available; however, it contains <10.5% of an unknown organic silicon compound","passageLanguage":"en","passageTranslation":null,"pinpoint":"Page 9; page 53","recipient":"Finishing mill","sender":"Chemical supplier","sourceDate":"2015-05-01","sourceId":"src-a3cfb170","threshold":null,"timing":null,"verificationMethod":"Fetched official PDF from mst.dk and extracted text. Product names omitted."},{"claim":"Under the UN Globally Harmonized System of Classification and Labelling of Chemicals (GHS), a mixture's safety data sheet (SDS) must give the identity and concentration of ingredients that are hazardous within GHS and present above cut-off levels: 1 per cent for most classes, 0.1 per cent for sensitisers, carcinogens, reproductive toxicants and category 1 mutagens. Listing non-hazardous ingredients is optional, and the cut-off table has no class for persistence, so an unclassified polymer need not appear.","claimType":"legal","conditions":"GHS is a UN model system. It binds only as adopted in national law, and countries may adopt different building blocks. Vietnam's implementation is covered by R2.","confidence":"high","contrary":"Suppliers may list all ingredients voluntarily (same passage).","decisionSupported":"What hazard and handling information the mill's workers receive, and whether the SDS will disclose a fluorinated polymer","documentRef":"ST/SG/AC.10/30/Rev.10, Annex 4, A4.3.3.2.1; chapter 1.5, 1.5.2 and Table 1.5.1","exemptions":null,"fields":["chemical","result","handling","record"],"handovers":["h1"],"id":"TECH-13","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"unresolved","limitations":"Rev.11 was not checked and wording may differ. GHS sets SDS content, not delivery: it does not show that an SDS reached the mill floor, or in a language the workers read.","materialStatus":"mixture","note":null,"passage":"For a mixture, provide the chemical identity, identification number (within the meaning of A4.3.3.1.3) and concentration or concentration ranges of all hazardous ingredients, which are hazardous to health or the environment within the meaning of the GHS, and are present above their cut-off levels. Manufacturers or suppliers may choose to list all ingredients, including non-hazardous ingredients.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Annex 4, A4.3.3.2.1 (page 412); 1.5.2 and Table 1.5.1 (page 35)","recipient":"Finishing mill and its workers","sender":"Chemical supplier","sourceDate":"2023-01-01","sourceId":"src-925702b8","threshold":"GHS Rev.10 Table 1.5.1 cut-off values: acute toxicity, skin corrosion/irritation, serious eye damage/eye irritation, germ cell mutagen category 2, specific target organ toxicity, aspiration hazard and hazardous to the aquatic environment ≥ 1.0%; respiratory or skin sensitiser, germ cell mutagen category 1, carcinogen and reproductive toxicant ≥ 0.1%.","timing":null,"verificationMethod":"Fetched official PDF from the UN Digital Library (UNECE site blocked). Year of publication only (2023); recorded as 1 January. The eleventh revised edition was not checked."},{"claim":"GHS lets national rules on confidential business information override ingredient identification on an SDS, provided this does not compromise the health and safety of workers or consumers or the protection of the environment. Where identity is withheld, the SDS should say that composition information was omitted.","claimType":"legal","conditions":"A UN model provision; what may be withheld, and how, depends on national law (R2 for Vietnam).","confidence":"high","contrary":null,"decisionSupported":"Whether a gap in SDS section 3 means 'nothing hazardous to list' or 'withheld'","documentRef":"ST/SG/AC.10/30/Rev.10, Annex 4, A4.3.3 (note); 1.4.8.1","exemptions":null,"fields":["chemical","record"],"handovers":["h1"],"id":"TECH-14","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"unresolved","limitations":"Further GHS principles on disclosure of withheld information in emergencies (chapter 1.4.8) were not reviewed. Says nothing about how often identity is withheld in practice.","materialStatus":"mixture","note":null,"passage":"For information on ingredients, the competent authority rules for confidential business information take priority over the rules for product identification. When applicable, indicate that confidential information about the composition was omitted. [...] Such provisions should not compromise the health and safety of workers or consumers, or the protection of the environment.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Annex 4, A4.3.3 (note); chapter 1.4, 1.4.8.1","recipient":"Finishing mill","sender":"Chemical supplier","sourceDate":"2023-01-01","sourceId":"src-925702b8","threshold":null,"timing":null,"verificationMethod":"Fetched official PDF from the UN Digital Library. Year of publication only; recorded as 1 January."},{"claim":"In the EU, the SDS for a mixture that is not itself classified must still list substances hazardous at 1 per cent or more, and substances at 0.1 per cent or more that are persistent, bioaccumulative and toxic (PBT), very persistent and very bioaccumulative (vPvB), on the Candidate List of substances of very high concern, or endocrine disruptors. Unclassified substances, including most polymers, may be listed but need not be.","claimType":"legal","conditions":"Applies to SDSs supplied within the EU under REACH Article 31. It does not govern supply from a chemical supplier to a mill in Vietnam, where Vietnamese rules apply (R2). Relevant as a benchmark; whether SDSs supplied in Vietnam follow the EU format was not checked.","confidence":"high","contrary":"CLP Delegated Regulation (EU) 2023/707 adds persistent, mobile and toxic hazard classes that may bring some persistent ingredients into SDSs (TECH-17).","decisionSupported":"Benchmark for what an SDS for a DWR agent must and need not disclose","documentRef":"REACH Annex II, Part B, section 3.2 and point 3.2.2, as replaced by Regulation (EU) 2020/878","exemptions":null,"fields":["chemical","result","record"],"handovers":["h1"],"id":"TECH-15","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"The supplier decides whether an ingredient meets classification criteria. Polymers are exempt from REACH registration (TECH-16), so hazard data for a DWR polymer may be thin.","materialStatus":"mixture","note":null,"passage":"The product identifier, the concentration or concentration ranges and the classifications shall be provided for at least all substances referred to in points 3.2.1 or 3.2.2. Suppliers of mixtures may choose to list in addition all substances in the mixture, including substances not meeting the criteria for classification. [...] 3.2.2. For a mixture not meeting the criteria for classification in accordance with Regulation (EC) No 1272/2008, substances present in an individual concentration equal to or greater than the following concentrations shall be indicated, together with their concentration or concentration range: (a) 1 % by weight in non-gaseous mixtures and 0,2 % by volume in gaseous mixtures for: (i) substances which present a health or environmental hazard within the meaning of Regulation (EC) No 1272/2008; or (ii) substances for which Union workplace exposure limits have been assigned; (b) 0,1 % by weight for substances that meet any of the following criteria: — substances that are persistent, bioaccumulative and toxic in accordance with the criteria set out in Annex XIII, — substances that are very persistent and very bioaccumulative in accordance with the criteria set out in Annex XIII, — substances included in the list established in accordance with Article 59(1) [...]","passageLanguage":"en","passageTranslation":null,"pinpoint":"Annex, Part B, section 3.2 (introductory text) and point 3.2.2","recipient":"EU downstream user","sender":"Supplier of a mixture on the EU market","sourceDate":"2020-06-18","sourceId":"src-3d25b937","threshold":"1 % by weight (non-gaseous mixtures) for substances presenting a health or environmental hazard or with EU workplace exposure limits; 0,1 % by weight for PBT, vPvB, Candidate List and endocrine-disrupting substances; 0,1 % or lower for certain sensitisers, category 2 carcinogens and reproductive toxicants (Annex II, point 3.2.2)","timing":"Annex II as replaced applies from 1 January 2021; non-compliant SDSs could be provided until 31 December 2022 (Regulation (EU) 2020/878, Articles 2 and 3).","verificationMethod":"Fetched official text from the EU Publications Office (CELEX 32020R0878) by content negotiation. Later amendments to Annex II not checked."},{"claim":"Taken together, an SDS for a DWR agent does not necessarily reveal whether the finish is fluorinated. Polymers are exempt from REACH registration, SDS rules require only classified ingredients above cut-offs to be named, and confidentiality rules can withhold identity, so an unclassified side-chain fluorinated polymer, or residual PFAS below cut-offs, can be absent from SDS section 3.","claimType":"interpretation","conditions":null,"confidence":"medium","contrary":"Voluntary full-ingredient listing is allowed (TECH-13, TECH-15), and new EU hazard classes for persistent, mobile substances may bring some PFAS ingredients into EU SDSs (TECH-17).","decisionSupported":"Whether the mill can rely on the SDS alone to answer 'is this finish fluorinated?'","documentRef":"EEA briefing, 29 April 2025","exemptions":null,"fields":["chemical","record"],"handovers":["h1"],"id":"TECH-16","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"An inference from the rules, not a survey of real DWR SDSs. Suppliers often state fluorine content or 'PFAS-free' status outside the SDS, in technical data sheets, declarations or certificates; those records are covered by other work packages. Monomers and some residues are registered even where polymers are not.","materialStatus":"mixture","note":null,"passage":"There is a wide variety of PFAS polymers. Three main types are side-chain fluorinated polymers, fluoropolymers and perfluoropolyethers. [...] Limited information is available on the identities and volumes of PFAS polymers currently used in Europe. This is because, under the REACH regulation (EU, 2006), polymers in general are exempt from registration obligations.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Briefing text, sections on types of PFAS polymers and on available information","recipient":"Finishing mill","sender":"Chemical supplier","sourceDate":"2025-04-29","sourceId":"src-023df489","threshold":null,"timing":null,"verificationMethod":"Fetched EEA web page. The interpretation combines this source with TECH-12 to TECH-15."},{"claim":"EU classification rules gained new hazard classes in 2023, including persistent, mobile and toxic (PMT) and very persistent, very mobile (vPvM). Substances placed on the market before 1 May 2025 must be classified against them by 1 November 2026, and a mixture containing 0.1 per cent or more of a PMT or vPvM component must be classified from 1 May 2026, or by 1 May 2028 if already on the market.","claimType":"legal","conditions":"Applies to substances and mixtures placed on the EU market under Regulation (EC) No 1272/2008 (CLP). Not a Vietnamese duty; affects H1 only where a supplier issues EU-format documents. Classification is substance by substance; there is no group classification of PFAS.","confidence":"high","contrary":null,"decisionSupported":"Whether persistent, mobile ingredients of a DWR agent will appear as a classified hazard on EU labels and SDSs","documentRef":"CLP Annex I, Part 4, sections 4.4.2.5, 4.4.3.1 and 4.4.3.2, as inserted by Delegated Regulation (EU) 2023/707","exemptions":null,"fields":["chemical","handling"],"handovers":["h1"],"id":"TECH-17","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"Whether any DWR polymer, residue or degradation product will be classified PMT or vPvM is not established here. The 1 November 2026 date falls inside the watch window; any amendment after adoption was not checked.","materialStatus":"mixture","note":null,"passage":"From 1 May 2025 at the latest, substances shall be classified in accordance with the criteria laid down in Sections 4.4.2.1 to 4.4.2.4. However, substances which were placed on the market before 1 May 2025 are not required to be classified in accordance with the criteria laid down in Sections 4.4.2.1 to 4.4.2.4 until 1 November 2026. [...] 4.4.3.1 A mixture shall be classified as a PMT or vPvM where at least one of its components has been classified as a PMT or vPvM and is present at or above 0,1 % (weight/weight). 4.4.3.2 Application in time From 1 May 2026 at the latest, mixtures shall be classified in accordance with the criteria laid down in Section 4.4.3.1. However, mixtures which were placed on the market before 1 May 2026 are not required to be classified in accordance with the criteria laid down in Section 4.4.3.1 until 1 May 2028.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Annex I, Part 4, sections 4.4.2.5, 4.4.3.1 and 4.4.3.2","recipient":"EU downstream user","sender":"Supplier of substances and mixtures on the EU market","sourceDate":"2022-12-19","sourceId":"src-dfa3e765","threshold":"0,1 % (weight/weight) of a component classified PMT or vPvM (CLP Annex I, 4.4.3.1)","timing":"Substances: from 1 May 2025; substances already on the market by 1 November 2026. Mixtures: from 1 May 2026; mixtures already on the market by 1 May 2028. The same dates apply to the new endocrine disruptor and PBT/vPvB classes.","verificationMethod":"Fetched the text as adopted from the EU Publications Office (CELEX 32023R0707) by content negotiation. Later amendments to these dates were not checked."},{"claim":"The European standard EN 17681-1:2025 measures a defined target list of PFAS in textiles by liquid chromatography with tandem mass spectrometry (LC-MS/MS). It does not measure side-chain fluorinated polymers directly: alkaline hydrolysis releases degradation products such as PFOA or fluorotelomer alcohols, from which the polymers' contribution is inferred against limits for PFOA and C9 to C14 PFCA-related substances.","claimType":"voluntary-standard","conditions":"A test method; it bears on legal compliance only where a law, authority or contract relies on it. Covers only the Table 2 targets unless validated for more.","confidence":"high","contrary":null,"decisionSupported":"Whether a test report can support compliance with limits on named PFAS, as distinct from a 'PFAS-free' claim","documentRef":"EN 17681-1:2025, clause 1 (Scope)","exemptions":null,"fields":["chemical","result","record"],"handovers":["h2","h3"],"id":"TECH-18","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"Only the scope was read. The Table 2 target list, reporting limits and validation data were not seen. Not a total-PFAS or total-fluorine method, and not designed to detect fluoropolymers such as PTFE.","materialStatus":"article","note":null,"passage":"This document specifies a test method, including the degradation of certain side-chain fluorinated polymers during the extraction with simultaneous alkaline hydrolysis, and using liquid chromatography (LC) and tandem mass spectrometry (MS/MS) for identification and quantification of certain per- and polyfluoroalkyl substances (PFAS). The document is applicable to all materials of textile products. Table 2 indicates a list of target PFAS which can be analysed with this document. PFAS of Table 2 marked with the footnote e) and footnote f) undergo alkaline hydrolysis and only their per- or polyfluorinated degradation products such as PFOA or n:2 fluorotelomer alcohols (n:2 FTOHs, n = 4, 6, 8, 10) can be determined. [...] Certain side-chain fluorinated polymers release n:2 FTOHs (n = 4, 6, 8, 10) under the described extraction conditions. Since these side-chain fluorinated polymers can be PFOA or C9-C14 PFCA-related substances restricted by the EU-POPs [1] or EU-REACH [2] regulations, the amounts of released n:2 FTOHs can be used to indirectly assess whether the concentration of the aforementioned side-chain fluorinated polymers exceed limits for PFOA or C9-C14 PFCA-related substances. This document is also applicable to the determination of further PFAS, provided that the method is validated with the additional substances and that these PFAS are stable to alkaline hydrolysis and dehydrofluorination.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Clause 1, Scope (as published in the EVS catalogue)","recipient":"Garment factory; brand or importer","sender":"Testing laboratory, commissioned by mill, factory or brand","sourceDate":"2025-05-15","sourceId":"src-85d0bdeb","threshold":null,"timing":"EN 17681-1:2025 replaced EN 17681-1:2022; valid in the Estonian national catalogue from 15 May 2025.","verificationMethod":"Fetched the official national standards catalogue page (scope text). The full standard is paid and was not fetched."},{"claim":"Its companion, EN 17681-2:2022, uses gas chromatography for selected volatile PFAS such as fluorotelomer alcohols, and both parts are needed to cover PFOA-related substances. The standard notes that deciding whether side-chain polymers are intentionally present may need an alkaline hydrolysis step that it does not yet include.","claimType":"voluntary-standard","conditions":null,"confidence":"high","contrary":null,"decisionSupported":"Whether a report citing only one part of EN 17681 covers volatile and non-volatile PFAS","documentRef":"EN 17681-2:2022, clause 1 (Scope), Notes 2 and 3","exemptions":null,"fields":["chemical","result","record"],"handovers":["h2","h3"],"id":"TECH-19","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"Target list, reporting limits and validation data not seen. No revised Part 2 was listed in the catalogue on 23 October 2026. An older specification, CEN/TS 15968:2010, covers perfluorooctane sulfonate (PFOS) only; its current status could not be confirmed.","materialStatus":"article","note":null,"passage":"This document specifies a test method (using gas chromatography, GC) for detection and quantification of selected extractable perfluorinated and polyfluorinated substances in textile materials (fibres, yarns, fabrics) and coated fabrics. [...] NOTE 2 Both this document and EN 17681-1 are needed for PFOA related substances. [...] To determine whether these are intentionally present it could be necessary to introduce an alkaline hydrolysis method to remove the side-chain from the polymer. According to Commission Regulation (EU) 2021/1297 [7], this applies similarly to C9-C14 PFCAs-related compounds. A future revision of this document will address this aspect.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Clause 1, Scope, Notes 2 and 3","recipient":"Garment factory; brand or importer","sender":"Testing laboratory","sourceDate":"2022-10-17","sourceId":"src-28c36f48","threshold":null,"timing":"Valid in the Estonian national catalogue from 17 October 2022; the standard announces a future revision.","verificationMethod":"Fetched the official national standards catalogue page (scope text). Full standard not fetched."},{"claim":"Total fluorine methods find fluorine that targeted tests miss but cannot say what it is. Combustion ion chromatography (CIC) cannot distinguish organic from inorganic fluorine or identify compounds, and can lose volatile compounds; particle-induced gamma-ray emission (PIGE) measures a surface at sensitivities of 68 to 238 parts per million and also cannot separate organic from inorganic fluorine. There are no standard methods for total fluorine or total organic fluorine in environmental samples.","claimType":"technical","conditions":null,"confidence":"high","contrary":"The same review notes that CIC captures fluorine compounds undetectable by LC-MS/MS, with combustion efficiency for C4 to C12 PFAS 'generally consistent and minimally affected by co-occurring compounds'.","decisionSupported":"Whether a screening result can show a fabric is free of fluorinated chemistry, and what a positive result does and does not identify","documentRef":"Balasuriya et al. 2026, Anal. Bioanal. Chem. 418(12):3489–3508, doi:10.1007/s00216-026-06458-6","exemptions":null,"fields":["result","record"],"handovers":["h2","h3","h5","h6"],"id":"TECH-20","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"A review centred on environmental samples; 'no standard methods' refers to those, not to textiles. Textile laboratories may run in-house validated total fluorine methods.","materialStatus":"article","note":null,"passage":"However, CIC cannot distinguish OF from IF or identify individual OF species [11], and it can lose volatile compounds prior to combustion, causing substantial underestimation of TF when volatile OF fractions are abundant [19]. [...] PIGE is gaining popularity for TF analysis because it is non-destructive, requires limited sample preparation, exhibits matrix-independent ppm sensitivities (68–238 ppm or 13–45 nmol F/cm2) and can provide complementary information about the co-occurring elements [48, 49]. However, PIGE has not yet been widely adopted because it cannot distinguish between OF and IF, requires highly specialized equipment to generate the incident ion beam [15], and is sensitive to sample heterogeneity [...] Despite their importance, there are no standard methods for determining TF or TOF in environmental samples [18].","passageLanguage":"en","passageTranslation":null,"pinpoint":"Sections 'Overview of techniques used for measuring TF and TOF' (CIC) and on PIGE. OF = organic fluorine; IF = inorganic fluorine; TF = total fluorine; TOF = total organic fluorine.","recipient":"Mill, factory, brand or recycler commissioning the test","sender":"Testing laboratory","sourceDate":"2026-04-05","sourceId":"src-5a4b83dc","threshold":null,"timing":null,"verificationMethod":"Fetched open-access full text via Europe PMC (PMC13221403)."},{"claim":"Other screening methods have blind spots too. Extractable organic fluorine (EOF) is underestimated when compounds are lost during solid-phase extraction. The total oxidisable precursor (TOP) assay converts only some precursors into measurable acids, leaves terminal acids unchanged and gives no speciation, and high-molecular-weight fluoropolymers are often missed by both LC-MS/MS and the TOP assay. Each method answers a different question, and none alone establishes 'PFAS-free'.","claimType":"technical","conditions":null,"confidence":"high","contrary":null,"decisionSupported":"Which method, or combination, a recipient needs for the question being asked","documentRef":"Balasuriya et al. 2026, Anal. Bioanal. Chem. 418(12):3489–3508, doi:10.1007/s00216-026-06458-6","exemptions":null,"fields":["result","record"],"handovers":["h2","h3"],"id":"TECH-21","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Environmental-sample review. The final sentence of the claim is our synthesis across TECH-18 to TECH-21.","materialStatus":"article","note":null,"passage":"Some of the compounds may be lost during SPE, leading to an underestimation of EOF because they have poor retention in the sorbent materials, which depends heavily on the type of sorbent used [21]. [...] 19F-NMR readily detects the fluorine resonances of ultrashort-chain PFAS [35], and high molecular weight fluoropolymers [36] that are often missed by LC-MS/MS and the TOP assay [...] Achieving a complete fluorine mass balance using the TOP assay is challenging due to its limitations: it does not capture all PFAS precursors since only polyfluorinated compounds with at least one non-fluorinated carbon are intended to fully oxidize to PFAAs, terminal PFAAs (e.g., PFOS, PFOA) remain unchanged, and the assay cannot provide precursor speciation or mechanistic insight [58].","passageLanguage":"en","passageTranslation":null,"pinpoint":"Sections on indirect fluorine analysis, 19F-NMR and the TOP assay","recipient":"Mill, factory or brand commissioning the test","sender":"Testing laboratory","sourceDate":"2026-04-05","sourceId":"src-5a4b83dc","threshold":null,"timing":null,"verificationMethod":"Fetched open-access full text via Europe PMC (PMC13221403)."},{"claim":"When papers and textiles treated with PFAS were measured for total fluorine by PIGE, targeted volatile and ionic PFAS accounted for at most 2.2 and 0.41 per cent of it, and most fluorine stayed in the material after solvent extraction. A clean result on a targeted list can therefore coexist with substantial non-extractable fluorine.","claimType":"technical","conditions":null,"confidence":"medium","contrary":"Precursors revealed by the TOP assay accounted for up to 14 per cent, so the TOP assay narrows the gap but does not close it.","decisionSupported":"Whether 'not detected' on a targeted test supports a 'PFAS-free' or 'fluorine-free' claim","documentRef":"Robel et al. 2017, Environ. Sci. Technol., doi:10.1021/acs.est.7b02080","exemptions":null,"fields":["result","record"],"handovers":["h2","h3"],"id":"TECH-22","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Abstract only; sample types and sizes not reviewed. Products predate current restrictions. Does not identify what the non-extractable fluorine is.","materialStatus":"article","note":null,"passage":"Volatile and ionic PFASs and unknown precursors accounted for 0–2.2%, 0–0.41%, and 0.021–14%, respectively, of the total nmol F/cm2 determined by PIGE. After extraction, papers and textiles retained 64 ± 28% to 110 ± 30% of the original nmol F/cm2 as determined by PIGE, indicating that the majority of fluorine remains associated with the papers and textiles.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Abstract","recipient":"Garment factory; brand or importer","sender":"Testing laboratory","sourceDate":"2017-07-15","sourceId":"src-53d66140","threshold":null,"timing":null,"verificationMethod":"Abstract only, via OpenAlex; full text paywalled."},{"claim":"In multi-layer firefighter garments, the PTFE moisture-barrier film carried by far the highest total fluorine (122,000 milligrams of fluorine per kilogram), and researchers needed layer-by-layer testing plus pyrolysis gas chromatography-mass spectrometry (py-GC/MS) to tell PTFE film from SFP-finished fabric. By analogy, a total fluorine result on a whole laminated rain-jacket fabric cannot say whether the fluorine comes from the DWR or the membrane.","claimType":"technical","conditions":"Attribution requires the layers to be separated or tested by a layer-specific technique.","confidence":"medium","contrary":null,"decisionSupported":"Whether a fluorine result can be attributed to the DWR or the membrane, and so whether a 'PFAS-free DWR' claim is consistent with a positive total fluorine test","documentRef":"Muensterman et al. 2022, Environ. Sci. Technol., doi:10.1021/acs.est.1c06322","exemptions":null,"fields":["component","result","record"],"handovers":["h2","h3","h5","h6"],"id":"TECH-23","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Firefighter protective gear, used as an analogue; the scenario jacket is not protective equipment. The application to rain jackets is our inference. Abstract only.","materialStatus":"article","note":null,"passage":"Particle-induced gamma ray emission (PIGE), a surface technique, and instrumental neutron activation analysis (INAA), a bulk technique, were used to measure total fluorine. Bulk characterization of the layers by pyrolysis-GC/MS (py-GC/MS) was used to differentiate fluoropolymer (e.g., PTFE) films from textile layers finished with side-chain polymers. [...] Moisture barrier layers comprised a PTFE film, as determined by py-GC-MS, and gave the highest individual nonvolatile (0.159 mg F/kg) and volatile PFAS (20.7 mg F/kg) as well as total fluorine (122,000 mg F/kg) concentrations.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Abstract","recipient":"Garment factory; brand; recycler","sender":"Testing laboratory","sourceDate":"2021-12-27","sourceId":"src-a1092330","threshold":null,"timing":null,"verificationMethod":"Abstract only, via OpenAlex; full text paywalled."},{"claim":"Reporting limits differ by orders of magnitude between methods. In a study of 93 children's products, total fluorine screening had a detection limit of 10 parts per million and is biased low for heavily fluorinated material, while targeted PFAS had quantification limits of 1.11 to 26.6 nanograms per gram (parts per billion). The authors also found that products labelled waterproof may contain PFAS even where a physical barrier gives the water resistance, and that 'green' assurances did not reliably indicate absence of PFAS.","claimType":"technical","conditions":null,"confidence":"high","contrary":null,"decisionSupported":"What a 'not detected' result means, and whether label claims such as 'waterproof' or 'non-toxic' indicate PFAS status","documentRef":"Rodgers et al. 2022, Environ. Sci. Technol. 56:6294–6304, doi:10.1021/acs.est.1c05175","exemptions":null,"fields":["result","record"],"handovers":["h3","h4"],"id":"TECH-24","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Children's apparel, bedding and furnishings bought in the United States, not rain jackets. The total fluorine method (oxygen-flask combustion with ion-selective electrode) differs from CIC. 'Orders of magnitude' is our arithmetic: 10 ppm is 10,000 ng/g.","materialStatus":"article","note":null,"passage":"The LOD was 10 ppm for almost all products. [...] This method produces a low bias on heavily fluorinated organic materials, such as PFAS, because the oxygen flask combustion preparation may not separate all tightly bound carbon–fluorine bonds. [...] LOQ range: 1.11–26.6 ng/g [...] These results suggest that products labeled as waterproof may still contain PFAS even if a physical barrier is used for water resistance. [...] current green assurances do not consistently indicate the absence of PFAS.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Methods (total fluorine screening); targeted PFAS table (LOQ range); Results and Discussion; Abstract","recipient":"Brand or importer; consumer","sender":"Testing laboratory; brand (label claims)","sourceDate":"2022-05-04","sourceId":"src-c44bc30b","threshold":"Total fluorine limit of detection 10 ppm 'for almost all products'; targeted PFAS limit of quantification range 1.11–26.6 ng/g (as reported by the study)","timing":null,"verificationMethod":"Fetched open-access full text (PubMed Central PMC9118540)."},{"claim":"In a 2026 study of products mainly from the Swiss market chosen for water- or grease-proofing, total fluorine was detected in 87 per cent of 15 textiles while every targeted PFAS was below 165 parts per billion. A modified TOP assay, which converts oxidisable precursors including side-chain fluorinated polymers, raised targeted PFAS in textiles by a factor of 1,300 on average and, across all products, showed a significant share of samples with precursors yielding PFHxA above a 1,000 ppb threshold that direct targeted testing did not reveal.","claimType":"technical","conditions":null,"confidence":"medium","contrary":null,"decisionSupported":"Whether a targeted-test pass shows that a treated textile is free of PFAS that can form restricted acids","documentRef":"Chemosphere 396:144841, doi:10.1016/j.chemosphere.2026.144841","exemptions":null,"fields":["result","record"],"handovers":["h3","h4"],"id":"TECH-25","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Abstract only. Fifteen textiles, Swiss market, not specific to rain jackets, and selected for repellency, so the detection rate is not a market prevalence. Which legal threshold the authors mean by '1000 ppb' was not checked against the full text; EU PFHxA limits are for R1.","materialStatus":"article","note":null,"passage":"Total fluorine was detected in 52 % of impregnation products, 87 % of textiles, and 61 % of food contact materials by combustion ion chromatography. A targeted analysis of perfluoroalkyl carboxylic acids (PFCAs), sulfonic acids (PFSAs), and fluorotelomer sulfonates (FTSs) resulted in individual PFASs concentrations that were all below 165 ppb. The application of a modified total oxydizable precursor (TOP) assay to the samples enabled the transformation of oxidizable precursors, including side-chain fluorinated polymers, into PFCAs, with average increases in concentrations of the targeted PFASs in fluorine equivalents by a factor of 23 600 for impregnation products, 1300 for textiles, and 420 for food contact materials. [...] applying the TOP assay uncovered a significant proportion of samples with precursors providing perfluorohexanoic acid (PFHxA) concentrations above the 1000 ppb threshold, compared to a direct PFASs targeted approach.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Abstract","recipient":"Brand or importer; market surveillance authority","sender":"Testing laboratory","sourceDate":"2026-01-31","sourceId":"src-89231082","threshold":null,"timing":null,"verificationMethod":"Abstract only, via Europe PMC; full text paywalled."},{"claim":"Sixteen outdoor jackets bought in 2011 and 2012 contained PFAS at 0.03 to 719 micrograms per square metre, with PFOA in all of them. After 3.5 years of sealed storage, four jackets kept only 10 to 20 per cent of their initial 8:2 FTOH while PFOA rose, so a test result describes the garment on the day it was tested.","claimType":"technical","conditions":null,"confidence":"medium","contrary":null,"decisionSupported":"How long a test report remains representative of the garment, and why the record date matters","documentRef":"Gremmel, Frömel and Knepper 2016, Chemosphere 160:173–180","exemptions":null,"fields":["result","record"],"handovers":["h3","h4","h5"],"id":"TECH-26","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Jackets bought in 2011 to 2012, before long-chain phase-outs and current restrictions; concentrations do not represent today's market. Abstract only. No brands named here.","materialStatus":"article","note":null,"passage":"The jackets were found to contain PFASs in a range between 0.03 and 719 μg/m(2). Perfluorooctanoic acid (PFOA) was omnipresent (0.02-171 μg/m(2)), although at lower concentrations compared to the precursors of perfluoroalkyl carboxylic acids (PFCAs), namely fluorotelomer alcohols (FTOHs) (<0.001-698 μg/m(2)). [...] To determine the effect of the volatility of FTOHs, four selected jackets were stored in a sealed bag in the dark at room temperature and re-analyzed after 3.5 years. Only 10%-20% of the initial concentration of 8:2-FTOH and 20%-50% of 10:2-FTOH were found, whereas the concentrations of PFOA and perfluorodecanoic acid increased significantly. This supports the hypothesis that PFAS concentrations in textiles are also strongly dependent on age, and conditions of transport and storage.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Abstract","recipient":"Brand; consumer; sorter","sender":"Testing laboratory","sourceDate":"2016-07-01","sourceId":"src-934d7ac2","threshold":null,"timing":null,"verificationMethod":"Abstract only, via Europe PMC; full text paywalled."},{"claim":"Until 2025 there was no certified reference material (CRM) for PFAS in textiles. The first, for 18 PFAS in an outdoor textile, was produced by Germany's Federal Institute for Materials Research and Testing (BAM) for quality control of methods such as EN 17681-1, so laboratories had no certified textile benchmark for these results before then.","claimType":"technical","conditions":null,"confidence":"high","contrary":null,"decisionSupported":"How much weight to place on a laboratory's PFAS result, and on its comparability with another laboratory's","documentRef":"Anal. Bioanal. Chem., doi:10.1007/s00216-025-06098-2 (CRM BAM-B003)","exemptions":null,"fields":["result","record"],"handovers":["h2","h3"],"id":"TECH-27","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"The absence of a CRM does not mean earlier results were wrong; laboratories also use spiked samples and proficiency tests. Covers 18 targeted PFAS, not total fluorine or polymers.","materialStatus":"article","note":null,"passage":"Despite the high relevance of textiles with regard to PFAS contamination and existing PFAS limit values, there are currently no CRMs available for PFAS in textiles. [...] In this project, the first ISO 17034 based CRM for the quantification of 18 PFAS compounds in an outdoor textile material was developed. CRM BAM-B003 is intended to be used for performance control, e.g. for the current standard method EN 17681–1, and for the validation of analytical methods.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Introduction; Conclusion","recipient":"Garment factory; brand or importer","sender":"Testing laboratory","sourceDate":"2025-09-09","sourceId":"src-87b97a08","threshold":null,"timing":null,"verificationMethod":"Fetched open-access full text via Europe PMC (PMC12532723)."},{"claim":"On the care labels of 17 outdoor jackets on sale in 2015 and 2016, none stated the DWR chemistry. Some named the membrane, as a fabric 'with a PTFE membrane' or as an ePTFE or PTFE percentage in the fibre composition, so membrane identity can travel on the label while finish chemistry does not. Swing tags were left out because they are easily removed after purchase.","claimType":"reported-practice","conditions":null,"confidence":"high","contrary":null,"decisionSupported":"Whether a consumer or sorter can tell from the jacket itself whether the finish is fluorinated, or whether it has a PTFE membrane","documentRef":"Hill, P.J., PhD thesis, sections 3.2 and 3.3.1, Table 3.2","exemptions":null,"fields":["component","chemical"],"handovers":["h3","h4","h5","h6"],"id":"TECH-28","jurisdiction":"United Kingdom and Germany (jackets sampled in shops)","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Small sample (one label per brand), 2015 to 2016, before France's PFAS restriction; label practice may have changed. Whether EU fibre-labelling law requires or permits PTFE to appear in the composition is for R1.","materialStatus":"article","note":null,"passage":"Swing tags were not analysed as these can be easily removed post-purchase. [...] Both brands L and M with 100% polyester fabric type with a PTFE membrane advised to wash at 30 °C. [...] The DWR chemistry type was not specified on any care labels. [...] 66% PA, 34% ePTFE [...] 53% PA, 27% PES 20% PTFE","passageLanguage":"en","passageTranslation":null,"pinpoint":"Printed pages 81 to 83 (PDF pages 107 to 109); last two fragments are cells of Table 3.2 (fabric type)","recipient":"Consumer; later collector and sorter","sender":"Brand or importer (label author)","sourceDate":"2019-04-01","sourceId":"src-d7647d75","threshold":null,"timing":null,"verificationMethod":"Fetched thesis PDF and extracted text. Brands are coded by letter in the passage; brand names in the table are not reproduced."},{"claim":"In a 2019 study for the Dutch government of 10,901 post-consumer garments, 24 per cent had no label, a figure that counted visibly cut-out labels as 'no label'. Most recyclers consulted said they do not rely on label composition declarations, partly because labels are often no longer present or legible when material reaches them.","claimType":"reported-practice","conditions":null,"confidence":"high","contrary":null,"decisionSupported":"Whether a sorter or recycler can rely on the sewn-in label to identify material","documentRef":"Wilting and van Duijn, Circle Economy, November 2019; officielebekendmakingen.nl blg-930139","exemptions":null,"fields":["component","record"],"handovers":["h5","h6"],"id":"TECH-29","jurisdiction":"Netherlands","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Dutch garments drawn from Fibersort fractions of single-layer monomaterial items, so laminated rain jackets are unlikely to be in the sample. Does not separate labels removed by owners from those lost to wear. Not a French figure; R4 covers French sorting.","materialStatus":"waste","note":null,"passage":"De meeste recyclers geven aan dat zij niet uitgaan van samenstellingdeclaraties op labels bij het vaststellen van de samenstelling van de grondstof voor hun recyclingproces. Bij het gebruik van post-consumer textiel als grondstof zijn labels niet altijd meer aanwezig of leesbaar wanneer de materialen de recycler bereiken. [...] Van alle geanalyseerde kledingstukken, heeft 24% geen label (meer). [...] Voor alle 10.901 artikelen is aangegeven of er een label aanwezig is. [...] Labels worden vaak uit kledingstukken geknipt. [...] Afgeknipte labels zijn niet beschouwd in dit onderzoek; kledingstukken met een zichtbaar afgeknipt label zijn aangemerkt als 'geen label' tezamen met de kledingstukken zonder sporen van een label.","passageLanguage":"nl","passageTranslation":"Most recyclers indicate that they do not rely on composition declarations on labels when determining the composition of the feedstock for their recycling process. When post-consumer textiles are used as feedstock, labels are not always still present or legible when the materials reach the recycler. [...] Of all garments analysed, 24% have no label (any longer). [...] For all 10,901 items it was recorded whether a label is present. [...] Labels are often cut out of garments. [...] Cut-off labels were not considered in this study; garments with a visibly cut-off label were recorded as 'no label', together with garments without any trace of a label.","pinpoint":"PDF page 7 (recyclers); PDF page 9 (label contamination)","recipient":"Sorter; recycler","sender":"Previous owner, via the garment","sourceDate":"2019-11-15","sourceId":"src-7a1c55ea","threshold":null,"timing":null,"verificationMethod":"Fetched official PDF from officielebekendmakingen.nl and extracted text; translation ours. Date is the official PDF's creation date; the report is dated November 2019."},{"claim":"In the same study, only 59 per cent of readable labels matched the fibre composition found: 77 per cent for single-fibre garments, 41 per cent for multi-fibre garments and 23 per cent for cotton-polyester blends. Accuracy was judged against the sorting machine's near-infrared (NIR) categorisation, not laboratory analysis.","claimType":"reported-practice","conditions":null,"confidence":"high","contrary":"The report itself notes that the composition of a garment may change during use through fibre loss, which would count against the label without the label having been wrong at sale.","decisionSupported":"Whether a sorter can use the label's fibre composition to route a garment to fibre-to-fibre recycling","documentRef":"Wilting and van Duijn, Circle Economy, November 2019; officielebekendmakingen.nl blg-930139","exemptions":null,"fields":["component","record"],"handovers":["h3","h5","h6"],"id":"TECH-30","jurisdiction":"Netherlands","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Accuracy was measured against NIR categorisation with set tolerance bands, so some apparent inaccuracy may reflect the machine or fibre loss during use; the report recommends validating with new textiles. Fibre composition only; says nothing about chemical finishes.","materialStatus":"waste","note":null,"passage":"De conclusies over de nauwkeurigheid van labels kunnen echter enkel worden getrokken over de kledingstukken met een leesbaar label, dit zijn er 7.749. [...] De nauwkeurigheid van labels is vastgesteld op basis van een steekproef van post-consumer kleding, enkel monomaterialen, afkomstig uit acht fracties van de Fibersort waarbij de categorisatie van de Fibersort is vergeleken met de samenstellingdeclaratie op het label van elk individueel kledingstuk. [...] Slechts 59% van de kledingstukken in dit onderzoek had een nauwkeurig label. Nadere analyse van de uitkomsten toont echter dat het probleem genuanceerder is. 77% van de kledingstukken die bestonden uit één vezeltype hadden een nauwkeurig label, waar dit slechts voor 41% van de kledingstukken bestaande uit meerdere vezeltypen het geval was. Het grootste verschil werd gevonden bij kleding bestaande uit een mix van katoen en polyester, waarin kledinglabels slechts in 23% van de gevallen nauwkeurig bleken.","passageLanguage":"nl","passageTranslation":"Conclusions on label accuracy can, however, only be drawn for garments with a readable label, of which there are 7,749. [...] Label accuracy was established from a sample of post-consumer clothing, monomaterials only, from eight Fibersort fractions, in which the Fibersort's categorisation was compared with the composition declaration on the label of each individual garment. [...] Only 59% of the garments in this study had an accurate label. Further analysis of the results shows, however, that the problem is more nuanced. 77% of garments made of a single fibre type had an accurate label, whereas this was the case for only 41% of garments made of several fibre types. The largest difference was found for clothing made of a mix of cotton and polyester, where labels proved accurate in only 23% of cases.","pinpoint":"PDF page 3 (method); PDF page 13 (conclusions)","recipient":"Sorter; recycler","sender":"Brand (label author)","sourceDate":"2019-11-15","sourceId":"src-7a1c55ea","threshold":null,"timing":null,"verificationMethod":"Fetched official PDF from officielebekendmakingen.nl and extracted text; translation ours."},{"claim":"Because it relies on NIR, the Fibersort automated sorting system used in the Dutch study can sort only monomaterial garments, meaning those with a composition homogeneous across the whole product, and therefore only single-layer garments. A laminated rain jacket falls outside what such a system can sort by fibre.","claimType":"technical","conditions":null,"confidence":"high","contrary":"Research on NIR hyperspectral imaging (Textiles 6(4):117, 24 September 2026, abstract only) reports 'the identification of localized fibers, trims, coatings, optically accessible layers, and other secondary constituents', which may relax this limit; it is a research result, not established sorting practice.","decisionSupported":"Whether automated NIR sorting can classify a laminated jacket by material","documentRef":"Wilting and van Duijn, Circle Economy, November 2019; officielebekendmakingen.nl blg-930139","exemptions":null,"fields":["component"],"handovers":["h5","h6"],"id":"TECH-31","jurisdiction":"Netherlands","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Describes one system in 2019; R4 covers current French sorting practice and equipment. The second sentence of the claim is our inference.","materialStatus":"waste","note":null,"passage":"In verband met het gebruik van NIR om de samenstelling van textiel vast te stellen, kan de Fibersort enkel monomaterialen sorteren. Dit zijn materialen waarvan de samenstelling homogeen is over het hele product. De Fibersort sorteert daarom enkel kledingstukken die uit één enkele laag bestaan.","passageLanguage":"nl","passageTranslation":"Because NIR is used to determine the composition of textiles, the Fibersort can only sort monomaterials. These are materials whose composition is homogeneous across the whole product. The Fibersort therefore only sorts garments that consist of a single layer.","pinpoint":"PDF page 3","recipient":"Sorter","sender":null,"sourceDate":"2019-11-15","sourceId":"src-7a1c55ea","threshold":null,"timing":null,"verificationMethod":"Fetched official PDF from officielebekendmakingen.nl and extracted text; translation ours."},{"claim":"NIR recognition reads the surface facing the analyser. In an automated sorting-line study, coatings and finishes caused mismatched recognition depending on which side faced the NIR analyser, very thin fabrics let NIR pass through, and ageing changed spectra. NIR identifies fibre type; it is not a test for DWR chemistry, and for a laminate the reading may depend on which face is scanned.","claimType":"technical","conditions":null,"confidence":"medium","contrary":"NIR hyperspectral imaging research (Textiles 6(4):117, 2026, abstract only) reports identifying localised coatings and optically accessible layers.","decisionSupported":"Whether an NIR sorting result can identify a jacket's fibre, membrane or finish","documentRef":"Cura et al. 2021, Recycling 6(1):11","exemptions":null,"fields":["component","chemical"],"handovers":["h5","h6"],"id":"TECH-32","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Abstract only. No fetched source tested whether NIR detects a DWR at typical add-on levels (about 2 to 3 per cent of fibre weight, TECH-04). A 2026 review (Textiles 6(1):28, abstract only) states that commercial-scale automated sorting 'is not established yet for textile waste recycling'. The last sentence of the claim is our inference.","materialStatus":"waste","note":null,"passage":"The identified properties of fabrics that led non-matching recognition were coating and finishing that lead different recognition of the material depending on the side facing the NIR analyser. In addition, very thin fabrics allowed NIRS to penetrate through the fabric and resulted in the non-matching recognition. Additionally, ageing was found to cause such chemical changes, especially in the spectra of cotton, that hampered the recognition.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Abstract","recipient":"Sorter; recycler","sender":null,"sourceDate":"2021-02-08","sourceId":"src-b517e77c","threshold":null,"timing":null,"verificationMethod":"Abstract only, via the VTT research portal and OpenAlex; MDPI full text blocked (HTTP 403)."},{"claim":"In a 2025 study of 1,682 post-consumer textile items from residual waste in Catalonia, quantitative fibre composition by NIR agreed with the ISO 1833 laboratory method in only 37.9 per cent of cases, which the authors attribute to the limits of automated techniques for fibre blends.","claimType":"technical","conditions":null,"confidence":"medium","contrary":"The same study found mono-component items dominated the stream (54.0 per cent by weight), where NIR is more reliable.","decisionSupported":"Whether NIR can supply the blend percentages a recycler needs when the label is missing or wrong","documentRef":"Textiles 6(1):3","exemptions":null,"fields":["component","result"],"handovers":["h5","h6"],"id":"TECH-33","jurisdiction":"Spain","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Abstract only. Waste from residual bins, not separately collected clothing; instrument and method details not reviewed. Concerns blend percentages, not layers or finishes.","materialStatus":"waste","note":null,"passage":"the quantitative composition determined by Near-Infrared (NIR) spectroscopy agreed with the ISO 1833 standard in only 37.9% of cases, critically exposing the technological limitations of current automated techniques for quantitative analysis in textiles made of fiber blends.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Abstract","recipient":"Sorter; recycler","sender":null,"sourceDate":"2025-12-30","sourceId":"src-108ec553","threshold":null,"timing":null,"verificationMethod":"Abstract only, via OpenAlex; MDPI full text blocked (HTTP 403)."},{"claim":"The European Environment Agency (EEA) finds that by the end-of-life stage any information on PFAS content in a textile has usually been lost, that chemical analysis to find PFAS-containing textile waste is expensive and generally not feasible, and that visual inspection does not work. It suggests sorting based on digital product information or X-ray fluorescence (XRF), at high cost if done at scale.","claimType":"technical","conditions":null,"confidence":"high","contrary":"Same briefing: 'PFAS-containing textiles can in principle be identified and sorted after-use or at end of life, but this is rarely done in practice.'","decisionSupported":"Whether a sorter can identify PFAS-treated garments and route them away from fibre-to-fibre recycling","documentRef":"EEA briefing, 17 September 2024","exemptions":null,"fields":["chemical","record"],"handovers":["h5","h6"],"id":"TECH-34","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":null,"limitations":"The briefing does not say whether XRF can separate a DWR from a PTFE membrane, or organic from inorganic fluorine. The digital product passport (DPP) for textiles is not yet in force; R1 and R4 cover its status.","materialStatus":"waste","note":null,"passage":"When textiles reach the end-of-life stage, any available information on PFAS content has usually been lost. Performing chemical analyses to identify the textile waste containing PFAS is expensive and generally not feasible. [...] It is also highly uncertain if the results would be effective since it is very challenging to identify textiles containing PFAS by visual inspection. [...] A more viable solution would be to develop procedures for semi-automatic or fully automated sorting based on digital information solutions on the presence of PFAS (such as the DPP and the digital label mentioned above) or based on X-ray fluorescence (XRF) machines. However, the implementation of such systems at large scale in waste handling facilities would come with a high cost.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Briefing text, section on end of life and sorting","recipient":"Collector; sorter; recycler","sender":null,"sourceDate":"2024-09-17","sourceId":"src-23cf2e8d","threshold":null,"timing":null,"verificationMethod":"Fetched EEA web page."},{"claim":"The EEA reports that, apart from a few PFAS identified as substances of very high concern, information on the presence and type of PFAS in textiles made outside the EU and sold in it is often extremely difficult to obtain. It gives three reasons: REACH registration does not extend to polymers or finished articles; suppliers may lack technical understanding and find requirements hard to pass up the chain; and suppliers hesitate to disclose.","claimType":"reported-practice","conditions":null,"confidence":"high","contrary":"The SVHC exception is itself a continuity route: REACH Article 33 requires article suppliers to pass on Candidate List information above 0.1 per cent (R1).","decisionSupported":"Whether an EU importer can establish the PFAS status of a jacket made in Vietnam from information supplied up the chain","documentRef":"EEA briefing, 17 September 2024","exemptions":null,"fields":["chemical","record"],"handovers":["h1","h2","h3"],"id":"TECH-35","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":null,"limitations":"A general EU-level assessment, not specific to Vietnam. Vietnam's own chemical information regime is covered by R2 and should not be read as absent. 'Difficult' is not 'impossible': brands using restricted substances lists, declarations and testing do obtain information (other work packages).","materialStatus":"article","note":null,"passage":"Except for a few PFAS that have been identified as substances of very high concern (SVHC), it is often extremely difficult to get information on the presence and type of PFAS in textiles produced outside the EU that are sold in the EU. This is because the registration obligation in REACH does not extend to polymers or finished products (i.e. 'articles' in REACH terms), including textiles. There may also be a lack of technical understanding among suppliers and manufacturers outside Europe regarding PFAS, difficulties in controlling and communicating requirements up the supply chain, and hesitation among suppliers to disclose information about their products.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Briefing text, section on information along the value chain","recipient":"Brand or importer in the EU","sender":"Chemical supplier, mill and garment factory outside the EU","sourceDate":"2024-09-17","sourceId":"src-23cf2e8d","threshold":null,"timing":null,"verificationMethod":"Fetched EEA web page."},{"claim":"The EU Waste Framework Directive (WFD), as amended in 2018, required Member States to set up separate collection of textiles by 1 January 2025. The duty names a material category only. Nothing about the item's materials or chemistry has to accompany it, so the jacket can enter a textile collection point carrying only its sewn-in label.","claimType":"legal","conditions":"Addressed to Member States, not to owners or producers. Subject to Article 10(2) and (3) of Directive 2008/98/EC (derogations not reviewed here).","confidence":"high","contrary":null,"decisionSupported":"Put the jacket into separate textile collection rather than mixed household waste","documentRef":"Directive 2008/98/EC, Article 11(1), as amended by Directive (EU) 2018/851","exemptions":"Article 10(2) and (3) of Directive 2008/98/EC (not reviewed)","fields":["component"],"handovers":["h5"],"id":"LIFE-01","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"This is the amending act, not the consolidated WFD. It does not show how France organises collection; the French textile scheme existed before this duty. It creates a collection route, not an information transfer.","materialStatus":"waste","note":null,"passage":"Subject to Article 10(2) and (3), Member States shall set up separate collection at least for paper, metal, plastic and glass, and, by 1 January 2025, for textiles.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Directive 2008/98/EC, Article 11(1), as amended by Directive (EU) 2018/851","recipient":"Textile collector (France)","sender":"Owner of the used jacket","sourceDate":"2018-05-30","sourceId":"src-a6e2692f","threshold":null,"timing":"By 1 January 2025","verificationMethod":"Fetched the official text of the amending act from the Publications Office (CELEX 32018L0851). The EUR-Lex consolidated WFD could not be fetched because of a web firewall."},{"claim":"The 2025 textile amendment to the Waste Framework Directive (WFD) requires producer responsibility organisations (PROs) under extended producer responsibility (EPR) to collect used textiles 'regardless of their nature, material composition, condition, name, brand, trademark or origin'. Collection is designed so that the person handing over the jacket has to supply no information.","claimType":"legal","conditions":"Applies to products listed in Annex IVc, which includes all codes in Combined Nomenclature (CN) chapters 61 and 62 (knitted and woven apparel), and so covers an adult rain jacket. Applies in the Member State where producers first make the products available.","confidence":"high","contrary":null,"decisionSupported":"Accept the jacket into collection without checking composition, brand or condition","documentRef":"Directive 2008/98/EC, Article 22c(8), inserted by Directive (EU) 2025/1892","exemptions":null,"fields":["component","record"],"handovers":["h5"],"id":"LIFE-02","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"future","limitations":"France already runs a textile EPR scheme through Refashion. How France will transpose Article 22c is not yet known. 'Regardless of material composition' governs acceptance at collection, not later sorting.","materialStatus":"waste","note":null,"passage":"Member States shall ensure that the producer responsibility organisations establish a separate collection system for used and waste textile, textile-related and footwear products listed in Annex IVc, regardless of their nature, material composition, condition, name, brand, trademark or origin, in the territory of a Member State where they make those products available on the market for the first time.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 22c(8), first subparagraph; Annex IVc Part I (CN chapters 61 and 62)","recipient":"Collection point in the PRO's collection system","sender":"Owner of the used jacket","sourceDate":"2025-09-10","sourceId":"src-aa88b6cc","threshold":null,"timing":"Directive in force from 16 October 2025. Transposition by 17 June 2027 (Article 2(1)). EPR schemes established by 17 April 2028 (Article 22a(14)).","verificationMethod":"Fetched the official Official Journal text from the Publications Office (CELEX 32025L1892, ELI http://data.europa.eu/eli/dir/2025/1892/oj)"},{"claim":"Under the 2025 amendment to the Waste Framework Directive (WFD), separately collected used textiles are 'considered to be waste upon collection'. The exception is an item handed over directly by the end user and professionally assessed as fit for re-use at the collection point by a re-use operator or social economy entity. At H5, the jacket's legal status turns on a trained person's inspection, not on any record that travels with it.","claimType":"legal","conditions":"The derogation needs both direct handover by the end user and direct professional assessment at the collection point. Recital 48 says the decision is 'not left to the end user but to the persons receiving the used products at the collection point who are provided with trainings or guidelines'.","confidence":"high","contrary":"Waste status can end after sorting if end-of-waste criteria under Article 6 are met (Article 22d(5)(d)). Recital 49 says the Commission will propose textile end-of-waste criteria 'based on the ongoing work of the Joint Research Centre'. These were still under development at the snapshot.","decisionSupported":"Classify the jacket as waste or as a used product fit for re-use at the moment of handover","documentRef":"Directive 2008/98/EC, Article 22d(2) and (3), inserted by Directive (EU) 2025/1892; recital 48","exemptions":"Article 22d(3) derogation for items directly assessed as fit for re-use at the collection point","fields":["record"],"handovers":["h5"],"id":"LIFE-03","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"future","limitations":"Not yet transposed in France at the snapshot. The provision does not say what information the assessor uses. A jacket left in an unattended collection bank would be waste on collection under this rule.","materialStatus":"waste","note":null,"passage":"2. Member States shall ensure that used and waste textile, textile-related and footwear products that are separately collected, including in accordance with Article 22c(8) and (11), are considered to be waste upon collection. [...] 3. By way of derogation from paragraph 2, used textile, textile-related and footwear products that are directly handed over by end users and directly professionally assessed as fit for re-use at the collection point by the re-use operator or social economy entities shall not be considered to be waste upon collection.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 22d(2), first sentence, and Article 22d(3); recital 48","recipient":"Collector, re-use operator or social economy entity at the collection point","sender":"Owner of the used jacket","sourceDate":"2025-09-10","sourceId":"src-aa88b6cc","threshold":null,"timing":"Transposition by 17 June 2027","verificationMethod":"Fetched the official Official Journal text from the Publications Office (CELEX 32025L1892)"},{"claim":"The operative text of the 2025 textile amendment to the Waste Framework Directive (WFD) mentions substances once, in a duty to screen collected textiles 'to identify and remove non-target items or materials or substances that are potential sources of contamination'. A search of the operative articles found no use of 'chemical' or 'hazardous', and no duty for producers to pass chemical information to collectors or sorters. The recitals leave the tracking of substances of concern to the Ecodesign for Sustainable Products Regulation (ESPR).","claimType":"interpretation","conditions":"Applies to separately collected used and waste textiles","confidence":"high","contrary":"Recital 39: Regulation (EU) 2024/1781 'regulates the presence of substances of concern to allow their minimisation and tracking with a view to reducing waste generation and improving recycling'. Recital 31 has producers finance research 'for the eco-design of textiles that do not contain substances of concern'.","decisionSupported":"Remove contaminating items or substances during screening. Inspection supports this; no supplied information does.","documentRef":"Directive 2008/98/EC, Article 22d(1), inserted by Directive (EU) 2025/1892; recitals 31 and 39","exemptions":null,"fields":["chemical","handling"],"handovers":["h5","h6"],"id":"LIFE-04","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"future","limitations":"This Directive's silence does not mean the information is absent in practice. Other law still applies: REACH Article 33, the WFD's SCIP database provision (Article 9) and future ESPR delegated acts. 'Contamination' in Article 22d(1) is not defined as chemical contamination.","materialStatus":"waste","note":null,"passage":"Separately collected used and waste textile shall be subject to a professional screening at the separate collection point or the sorting facility to identify and remove non-target items or materials or substances that are potential sources of contamination.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 22d(1), last sentence; compare recital 39","recipient":"Separate collection point or sorting facility","sender":null,"sourceDate":"2025-09-10","sourceId":"src-aa88b6cc","threshold":null,"timing":"Transposition by 17 June 2027","verificationMethod":"Fetched the official Official Journal text (CELEX 32025L1892). Searched the operative part, from 'HAVE ADOPTED THIS DIRECTIVE' to the end, for 'substance', 'chemical', 'hazardous', 'composition' and 'digital product passport'."},{"claim":"Once the 2025 amendment to the Waste Framework Directive (WFD) is transposed, sorters must separate items fit for direct re-use 'item-to-item', using 'up-to-date sorting criteria relevant to the receiving market'. Items not suitable for re-use go to remanufacturing and recycling, including fibre-to-fibre recycling 'where technological progress allows'. The criteria named are market criteria. Neither route has a chemical criterion.","claimType":"legal","conditions":"Applies to separately collected used and waste textiles listed in Annex IVc","confidence":"high","contrary":"Article 22d(5)(d) requires re-use output to meet end-of-waste criteria under Article 6. Those criteria may add conditions once adopted.","decisionSupported":"Send the jacket to re-use, or to remanufacturing and recycling","documentRef":"Directive 2008/98/EC, Article 22d(5)(b) and (c), inserted by Directive (EU) 2025/1892","exemptions":null,"fields":["component"],"handovers":["h6"],"id":"LIFE-05","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"future","limitations":"The Directive does not say how sorters identify fibre composition, layers or finishes. Fibre-to-fibre recycling depends on technological progress. Recital 48 calls re-use 'the main objective of the sorting operations followed by sorting for recycling'.","materialStatus":"waste","note":null,"passage":"(b) the sorting-for-re-use operations sort textile, textile-related and footwear products at an appropriate level of granularity, allowing for item-to-item sorting which separates fractions that are fit for direct re-use from those that are to be subject to further preparing for re-use operations, and target a specific re-use market applying up-to-date sorting criteria relevant to the receiving market; (c) items that are assessed as not suitable for re-use are sorted for remanufacturing and recycling including, where technological progress allows, fibre-to-fibre recycling, with a view to prioritising remanufacturing over recycling;","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 22d(5)(b) and (c)","recipient":"Sorting operator","sender":"Collector","sourceDate":"2025-09-10","sourceId":"src-aa88b6cc","threshold":null,"timing":"Transposition by 17 June 2027","verificationMethod":"Fetched the official Official Journal text (CELEX 32025L1892)"},{"claim":"France's textile extended producer responsibility (EPR) scheme, called REP TLC (textiles, chaussures, linge de maison) and run by the producer responsibility organisation Refashion, must ensure traceability of used textile waste to final treatment. Its standard contract with sorters must set out the traceability evidence that proves effective final re-use or recovery. Information about where sorted textiles go therefore travels back up the chain. The provisions say nothing about chemical content.","claimType":"legal","conditions":"Binds the approved eco-organisme, and sorters through the standard contract (contrat-type)","confidence":"high","contrary":"Refashion's 2025 indicators report 2.3 million euros paid as support for traceability of re-use (see LIFE-09), so the mechanism is funded.","decisionSupported":"Pay sorting support only for tonnage shown to have been re-used or recovered","documentRef":"Arrêté du 23 novembre 2022 (NOR TREP2233003A), annexed cahier des charges, sections 1 and 3.4.1","exemptions":null,"fields":["record"],"handovers":["h5","h6"],"id":"LIFE-06","jurisdiction":"France","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"Traceability here concerns tonnage and destination, not product-level chemistry. The contrat-type itself was not obtained, so its exact traceability fields are not established.","materialStatus":"waste","note":null,"passage":"L'éco-organisme s'assure de la traçabilité des déchets de TLC usagés jusqu'à leur traitement final, conformément au III de l'article L. 541-10-6 . [...] Ce contrat-type précise également les éléments de traçabilité à fournir pour justifier de la valorisation ou de la réutilisation effective finale des TLC triés.","passageLanguage":"fr","passageTranslation":"The eco-organisation ensures the traceability of used TLC waste up to its final treatment, in accordance with III of Article L. 541-10-6. [...] This standard contract also specifies the traceability elements to be provided to justify the effective final recovery or re-use of the sorted TLC.","pinpoint":"Cahier des charges, section 1 (general provisions) and section 3.4.1 (contract with sorting operators)","recipient":"Refashion (approved eco-organisme)","sender":"Contracted sorting operator","sourceDate":"2026-08-24","sourceId":"src-6bd0cba3","threshold":null,"timing":"In force. Consolidated text as amended up to the arrêté of 24 August 2026.","verificationMethod":"Fetched the consolidated text on AIDA (INERIS). Légifrance refused automated access (HTTP 403)."},{"claim":"The fee adjustments (eco-modulations) in France's textile extended producer responsibility scheme (REP TLC) reward durability, recycled content and certification by named environmental labels, including Oeko-tex Made in Green, Bluesign, the EU Ecolabel and the Global Organic Textile Standard (GOTS). From 1 September 2026 a durability penalty of 12 euros per coat or jacket, rising to 19.50 euros from 2030, applies where the product's 'score D' is 0.8 or less. The consolidated text has no criterion on hazardous substances, per- and polyfluoroalkyl substances (PFAS) or finishes, and none of these adjustments produces information for sorters.","claimType":"legal","conditions":"Label bonus applies to products certified by the listed labels. Jacket penalty applies where D = 0,67 + (1,45 − 0,67) ∗ (0,5 × G + 0,5 × R) is 0.8 or below. G is the width of the product range and R is the incentive to repair, weighted 50% each.","confidence":"high","contrary":"Article 22c(5)(a) of the 2025 WFD amendment will require fees to be modulated on ESPR ecodesign requirements. Those could include substances of concern once a textiles delegated act exists.","decisionSupported":"Set the producer's eco-contribution for the jacket. No decision at H5 or H6 is informed.","documentRef":"Cahier des charges, section 2.2.2 and section 2.2.3.1 (inserted by arrêté du 24 août 2026, article 1er et annexe)","exemptions":null,"fields":["chemical","record"],"handovers":["h3","h5"],"id":"LIFE-07","jurisdiction":"France","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"Several of the listed labels have their own chemical criteria, so chemistry can affect the fee indirectly through the label bonus. That signal goes to the fee, not to the sorter. The ministry note on calculating the penalty was not fetched.","materialStatus":"article","note":null,"passage":"La prime relative à la certification du produit est octroyée pour les labels environnementaux suivants : Ecocert® Textile, Oeko-tex® Made in Green, Bluesign®, Fairtrade®, Ecolabel Européen, Demeter ®, GOTS et Bioré®. [...] « A compter du 1er septembre 2026, les contributions financières versées par les producteurs à l'éco-organisme sont modulées selon les pénalités associées à la durabilité liée aux pratiques industrielles et commerciales selon les montants définis dans le tableau suivant : « Condition d'application Produit dont le score D est inférieur ou égal à 0,8 [...] Manteau/Veste 12 14,50 17,00 19,50","passageLanguage":"fr","passageTranslation":"The bonus for product certification is granted for the following environmental labels: Ecocert Textile, Oeko-tex Made in Green, Bluesign, Fairtrade, EU Ecolabel, Demeter, GOTS and Bioré. [...] From 1 September 2026, the financial contributions paid by producers to the eco-organisation are modulated according to penalties associated with durability linked to industrial and commercial practices, in the amounts set out in the following table: Condition of application: product whose D score is less than or equal to 0.8 [...] Coat/Jacket 12 14.50 17.00 19.50","pinpoint":"Cahier des charges, section 2.2.2 (label bonus) and section 2.2.3.1 'Pratiques industrielles et commerciales', penalty table, row 'Manteau/Veste'","recipient":"Refashion","sender":"Producer placing the jacket on the French market","sourceDate":"2026-08-24","sourceId":"src-6bd0cba3","threshold":"Produit dont le score D est inférieur ou égal à 0,8","timing":"Durability, label and recycled-content modulations from 1 January 2023. Jacket penalty from 1 September 2026: 12 € (2026 and 2027), 14,50 € (2028), 17,00 € (2029), 19,50 € (from 2030).","verificationMethod":"Fetched the consolidated text on AIDA (INERIS). Searched the full consolidated text for 'substance', 'dangereu', 'PFAS', 'fluor' and 'chimi' and found no matches."},{"claim":"France's textile extended producer responsibility (EPR) rules set a recycling target for used textiles made of at least 90% synthetic plastic material: 50% from 2025 and 90% from 2028 of the quantity collected, sorted and not re-used. The rules also required a study, due by 1 January 2025, on synthetic products that combine different polymers. If no recycling solution is found, an 'eco-design penalty' for non-recyclability may be proposed. A polyester jacket with a laminated membrane may be such a multi-polymer product, depending on what the membrane is made of.","claimType":"legal","conditions":"Target binds the eco-organisme, not individual sorters. Measured as mass entering a recycling installation after control, sorting and preliminary operations.","confidence":"high","contrary":"The ministry page (updated 31 August 2026) gives the 90% target as '90% en 2027'. The legal text says 2028.","decisionSupported":"Accept an item of at least 90% synthetic content into a synthetic recycling stream","documentRef":"Cahier des charges, section 3.2.2","exemptions":null,"fields":["component"],"handovers":["h6"],"id":"LIFE-08","jurisdiction":"France","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"The study's results and any resulting penalty were not found. Applying the target needs fibre composition to be known at sorting, which in practice usually means the label or near-infrared (NIR) scanning.","materialStatus":"waste","note":null,"passage":"Objectifs de recyclage Année concernée (à compter de) 2025 2028 Pourcentage minimal de recyclage des quantités intégrant au moins 90 % de fibre synthétique plastique collectées et triées mais non réutilisées ou réemployées 50 % 90 % D'ici le 1er janvier 2025, l'éco-organisme réalise une étude pour déterminer les solutions techniques de recyclage existantes ou à développer pour les TLC composés de matière synthétique plastique associant différents polymères. Dans le cas où il n'identifie pas de solution de recyclage pour ces produits et si les objectifs précités ne peuvent pas être atteints en conséquence, il propose au ministre chargé de l'environnement une modification des objectifs de recyclage précités associée à une pénalité d'éco-conception tenant compte de la non recyclabilité de ces produits.","passageLanguage":"fr","passageTranslation":"Recycling targets. Year concerned (from): 2025, 2028. Minimum recycling percentage of quantities containing at least 90% synthetic plastic fibre that are collected and sorted but not re-used: 50%, 90%. By 1 January 2025, the eco-organisation carries out a study to determine existing or yet-to-be-developed technical recycling solutions for TLC made of synthetic plastic material combining different polymers. If it does not identify a recycling solution for these products and the above targets cannot be met as a result, it proposes to the minister responsible for the environment a change to those targets together with an eco-design penalty that takes account of the non-recyclability of these products.","pinpoint":"Cahier des charges, section 3.2.2 'Objectif de recyclage des TLC intégrant de la matière synthétique plastique'","recipient":"Recycler","sender":"Sorting operator","sourceDate":"2026-08-24","sourceId":"src-6bd0cba3","threshold":"TLC composés d'au moins 90 % de matière synthétique plastique","timing":"50% from 2025; 90% from 2028; study due by 1 January 2025","verificationMethod":"Fetched the consolidated text on AIDA (INERIS); table cells read in row order"},{"claim":"Refashion's 2025 key indicators report 272,479 tonnes of used textiles collected and 216,264 tonnes sorted (84% in France) by 74 contracted sorting centres that reported, 56 of them in France. Of the sorted tonnage, 54.47% went to re-use, 25.31% to materials for recycling, 11.03% to wiping rags and 8.4% to solid recovered fuel (combustible solide de récupération, CSR).","claimType":"reported-practice","conditions":"Covers sorting centres under contract with Refashion, including some outside France","confidence":"high","contrary":null,"decisionSupported":"Aggregate reporting of how sorted textiles were routed (not an item-level decision)","documentRef":"Refashion KPI 2025, sections 'Collecte des TLC usagés' and 'Tri et destination des matières triées'","exemptions":null,"fields":["record"],"handovers":["h5","h6"],"id":"LIFE-09","jurisdiction":"France","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Aggregate tonnage only. It says nothing about any individual jacket or about chemical content. 'Réutilisation' includes re-use outside France, and the sheet does not split it by destination. The PDF has no publication date.","materialStatus":"waste","note":null,"passage":"Collecte (Tonnes) 272 479 | Nombre de centres de tri conventionnés déclarants / dont France 74/56 | Tonnages triés (Tonnes) / dont France (%) 216 264/84 | Réutilisation (%) 54,47 | Matières à recycler (%) 25,31 | Chiffons d’essuyage (%) 11,03 | Combustibles Solides de Récupération (%) 8,4 | Montant des soutiens versés à la traçabilité pour le réemploi (M€) 2,3","passageLanguage":"fr","passageTranslation":"Collection (tonnes) 272,479 | Number of contracted sorting centres reporting / of which in France 74/56 | Tonnes sorted / of which in France (%) 216,264/84 | Re-use (%) 54.47 | Materials to be recycled (%) 25.31 | Wiping rags (%) 11.03 | Solid recovered fuel (%) 8.4 | Support paid for re-use traceability (million euros) 2.3","pinpoint":"Single-page KPI sheet, 'Collecte des TLC usagés' and 'Tri et destination des matières triées' panels","recipient":"Refashion","sender":"Contracted sorting centres","sourceDate":"2026","sourceId":"src-a3f303a2","threshold":null,"timing":"Calendar year 2025","verificationMethod":"Fetched the official PDF. Values transcribed cell by cell from the table, because the text layer interleaves columns."},{"claim":"In December 2022 Refashion, the French textile producer responsibility organisation, told its members that no clothing, household linen or footwear product could lawfully carry a 'recyclable' claim under Code de l'environnement Article R.541-221 VI. One reason is that the criteria require 'the absence of elements or substances disrupting sorting, recycling or limiting the use of the recycled material'. Refashion concluded that the environmental product sheet should carry no recyclability information.","claimType":"interpretation","conditions":"Recyclability claims must meet all five criteria in R.541-221 VI (introduced by décret 2022-748)","confidence":"medium","contrary":"The same note says re-use, 'proche de 60% des déchets collectés' (close to 60% of collected waste), is roughly double the recycling rate, which is consistent with a system oriented to re-use.","decisionSupported":"Tell the owner and collector whether the jacket is recyclable. Not supported: no claim is made.","documentRef":"Refashion information note quoting Code de l'environnement Article R.541-221 VI","exemptions":null,"fields":["component","chemical"],"handovers":["h4","h5"],"id":"LIFE-10","jurisdiction":"France","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"This is the eco-organisme's 2022 reading. It was not re-checked against later versions of R.541-221 or newer Refashion guidance. The absence of a recyclability claim says nothing about the jacket's chemistry.","materialStatus":"article","note":null,"passage":"3° L’absence d’éléments ou substances perturbant le tri, le recyclage ou limitant l’utilisation de la matière recyclée ; [...] Refashion considère qu’il n’y a donc aucune information relative à la recyclabilité à faire figurer au sein de la fiche intitulée « fiche produit relative aux qualités et caractéristiques environnementales » concernant les produits textiles d’habillement, linge de maison et chaussures.","passageLanguage":"fr","passageTranslation":"3° The absence of elements or substances disrupting sorting or recycling or limiting the use of the recycled material; [...] Refashion therefore considers that no information on recyclability is to be included in the sheet entitled 'product sheet on environmental qualities and characteristics' for clothing textiles, household linen and footwear.","pinpoint":"Note, pages 1 to 2 (quotation of R.541-221 VI criteria; conclusion addressed to members)","recipient":"Consumer and, indirectly, the collector","sender":"Producer, through the environmental product sheet","sourceDate":"2022-12-08","sourceId":"src-fd6dabd0","threshold":"Criterion 4°: recycled material produced represents more than 50% by mass of the collected waste (as quoted in the note)","timing":"Note dated 8 December 2022","verificationMethod":"Fetched the official PDF from Refashion's professional site. The Code de l'environnement article was not fetched from Légifrance (HTTP 403)."},{"claim":"A 2025 study for the European Commission's Joint Research Centre (JRC), based on sorters in Italy, Czechia and Romania, found 'no fixed criteria list' for deciding whether a garment is fit for re-use. Sorters follow facility manuals and judge usability, trend, colour, brand and visible damage. The re-use decision rests on what a trained person can see.","claimType":"reported-practice","conditions":"Interviews and sampling at sorting facilities in three Member States, November 2023 to June 2024","confidence":"high","contrary":"Article 22d(5)(b) of the 2025 WFD amendment will require 'up-to-date sorting criteria relevant to the receiving market', and end-of-waste criteria may later standardise re-use grading.","decisionSupported":"Send the jacket to re-use or to recycling","documentRef":"JRC141441, doi:10.2760/3332076, section 2.3.2.1","exemptions":null,"fields":["component"],"handovers":["h6"],"id":"LIFE-11","jurisdiction":"EU (Italy, Czechia, Romania)","lastVerified":"2026-10-23","legalStatus":null,"limitations":"No French sorters were sampled. The report is an external study and does not necessarily reflect the Commission's position.","materialStatus":"waste","note":null,"passage":"It is important to understand that there is no fixed criteria list defining whether a garment is fit for re-use. Common business practice involves facilities having sorting manuals or guidelines and training staff diligently to recognise these criteria efficiently. Staff are often rewarded for excellent productivity or particular skill in identifying high-value products. This means that reusability and market fit, which ultimately dictate the price, are based on the subjective decisions of the sorter. They must consider the facility manual, usability, trend, color, brand, and visible damages.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Section 2.3.2.1 'Methods', printed pp. 23 to 24 (PDF pp. 27 to 28); footnote markers omitted","recipient":"Sorter grading for re-use","sender":null,"sourceDate":"2025","sourceId":"src-72ee813d","threshold":null,"timing":null,"verificationMethod":"Fetched the full report PDF from a mirror (Assoambiente). Same JRC number and DOI as the official publication; the Publications Office copy was not fetched."},{"claim":"A 2026 study for the Joint Research Centre (JRC) on digital product passport (DPP) content for apparel finds that, at end of life, sorters and recyclers 'may rely on the information in physical labels' for garment composition, 'when they are not removed or faded'. It also finds that reading labels is slow, and that wear and removal compromise their accuracy and availability. The care label is the main composition record that reaches the sorter, and only if it survives.","claimType":"reported-practice","conditions":"Depends on the label being present and legible","confidence":"high","contrary":"Fibersort's 2018 manual sort (Circle Economy, Interreg North-West Europe) had 'a separate team label checked each item to determine fibre content', excluded 'items without labels' from calculations, and noted 'it is rumored in the industry that the actual fibre content in garments rarely match the labels' (https://vb.nweurope.eu/media/3453/fibersort_manual-sort-pct_jan2018.pdf, PDF pp. 5 to 6).","decisionSupported":"Sort for recycling by fibre composition and pre-treat accordingly","documentRef":"Section 2 (current practice) and section 6.1.4 'Data exchange at the end-of-life'","exemptions":null,"fields":["component"],"handovers":["h5","h6"],"id":"LIFE-12","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":null,"limitations":"The Textile Labelling Regulation label gives fibre composition only. It carries no finish chemistry and no component-level detail for a laminated membrane. External study, not a Commission position.","materialStatus":"waste","note":null,"passage":"At the end-of-life, recyclers and sorters may rely on the information in physical labels to identify the garment composition, and sort and pre-treat accordingly, when they are not removed or faded. [...] Regarding sorting for recycling, it can be manually performed based on fibre composition information provided on labels, as required by the Textile Labelling Regulation. However, reading labels is often time consuming and their accuracy and availability are compromised due to removal or damage from wear over time (Cura et al., 2021).","passageLanguage":"en","passageTranslation":null,"pinpoint":"Printed p. 29 (PDF p. 32) and section 6.1.4, printed pp. 37 to 38 (PDF p. 40)","recipient":"Sorter and recycler","sender":"Garment (sewn-in label required by the Textile Labelling Regulation)","sourceDate":"2026-05-13","sourceId":"src-b9cc3aff","threshold":null,"timing":null,"verificationMethod":"Fetched the official PDF from the JRC Product Bureau site"},{"claim":"Refashion's July 2026 review of sorting technology states that near-infrared (NIR) spectroscopy, the main automated method for identifying fibres, reads only the visible surface. Multilayered items and surface treatments 'such as coatings, finishes, dyes, waterproofing' are problematic because 'the technology cannot detect the underlying materials'. A coated face fabric over a laminated membrane falls squarely in this limitation.","claimType":"technical","conditions":"Limits confirmed in interviews with equipment suppliers and developers","confidence":"high","contrary":"The same review reports work, for example by PL S'TRI and IRIS, on other spectral ranges and geometries 'paving the way for more precise recognition of thick, coated or multilayered materials'.","decisionSupported":"Identify face fabric and membrane composition to route the jacket to a recycling stream","documentRef":"Section 1.1, 'Limitations of NIR technology'; Table 1 'Digital identifiers solutions'","exemptions":null,"fields":["component","chemical"],"handovers":["h6"],"id":"LIFE-13","jurisdiction":"EU (survey of European equipment suppliers)","lastVerified":"2026-10-23","legalStatus":null,"limitations":"NIR identifies polymers, not finish chemistry. It cannot tell a fluorinated finish from a fluorine-free one. Table 1 on page 8 describes the printed product information label as 'Simple but often missing or illegible after many washes' (table cell read from an interleaved text layer).","materialStatus":"waste","note":null,"passage":"Surface analysis: spectroscopy remains a surface-detection technology and only measures the light reflected or transmitted by the visible surface of the sample. Non-homogeneous surfaces, such as gimped yarns, double-sided fabrics, multilayered items, surface treatments (coatings, finishes, dyes, waterproofing, etc.), are therefore problematic, as the technology cannot detect the underlying materials;","passageLanguage":"en","passageTranslation":null,"pinpoint":"Pages 7 to 8 of 60, 'Limitations of NIR technology', first bullet","recipient":"Sorter using automated NIR sorting","sender":null,"sourceDate":"2026-07","sourceId":"src-8e9ced1d","threshold":"Elastane often below 5% is hard to detect (same list)","timing":null,"verificationMethod":"Fetched the official PDF (60 pages) linked from Refashion's news page dated 14 August 2026"},{"claim":"Refashion's 2026 environmental assessment of the French scheme reports that automated secondary sorting (sur-tri automatisé) was applied to only 0.1% of the material leaving sorting in 2025. Almost all routing decisions in the French system are therefore made by people reading labels and looking at garments.","claimType":"reported-practice","conditions":"Life-cycle assessment of the French TLC scheme for 2025","confidence":"medium","contrary":"Refashion's 2026 technology review lists French suppliers (PELLENC ST, CETIA, 3U Vision) and pilots, so capacity is growing.","decisionSupported":"Route sorted output to recycling streams by composition (mostly done by hand)","documentRef":"Synthèse, section on sorting ('Tri moyen')","exemptions":null,"fields":["component"],"handovers":["h6"],"id":"LIFE-14","jurisdiction":"France","lastVerified":"2026-10-23","legalStatus":null,"limitations":"This is a passing remark in a life-cycle assessment, not a technology census. 'Sur-tri' means secondary sorting of outputs, so automated tools used at other points are not measured.","materialStatus":"waste","note":null,"passage":"Ces impacts prennent également en compte le sur-tri automatisé. Cette pratique n’étant effectuée que sur 0,1 % des gisements en sortie de tri, ils ne sont pas significatifs dans les résultats.","passageLanguage":"fr","passageTranslation":"These impacts also take into account automated secondary sorting. As this practice is carried out on only 0.1% of the streams leaving sorting, they are not significant in the results.","pinpoint":"Page 10, sorting section","recipient":"French sorting centres","sender":null,"sourceDate":"2026-07","sourceId":"src-7cc60873","threshold":null,"timing":"Year 2025","verificationMethod":"Fetched the official PDF (15 pages). The page has a multi-column layout; the passage was reconstructed in reading order from the column text."},{"claim":"The Joint Research Centre (JRC) textile waste study treated multilayered items as non-recyclable because 'there is no business case for their disassembly in Europe'. Multilayered items such as jackets and coats were 5.2% of its sample, and 'most of them were managed as reusable garments exported outside the EU'. Removing a membrane before recycling is not current practice. A laminated rain jacket that is not re-used in Europe most likely goes to export for re-use.","claimType":"reported-practice","conditions":"Sample of textiles intended for re-use and recycling at sorters in three Member States","confidence":"high","contrary":"Refashion's 2026 technology review describes delamination and cutting pilots for multilayered textiles, none yet shown at industrial scale for garments.","decisionSupported":"Remove the membrane before processing, or send the jacket to re-use (export)","documentRef":"JRC141441, doi:10.2760/3332076, section 2.4.1.4 'Layers'","exemptions":null,"fields":["component"],"handovers":["h6"],"id":"LIFE-15","jurisdiction":"EU (Italy, Czechia, Romania)","lastVerified":"2026-10-23","legalStatus":null,"limitations":"France was not sampled. The study does not name export destinations or what happens to the jackets after export.","materialStatus":"waste","note":null,"passage":"Multi-layered items can be disassembled manually or automatically before being sorted based on their composition, but there is no business case for their disassembly in Europe so the multi-layered items are considered non-recyclable and have been excluded from all the results. In total 5.2% of the aggregated sample consisted of multi-layered items like jackets and coats and most of them were managed as reusable garments exported outside the EU.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Section 2.4.1.4, printed p. 27 (PDF p. 31)","recipient":"Recycler or re-use buyer outside the EU","sender":"Sorter","sourceDate":"2025","sourceId":"src-72ee813d","threshold":null,"timing":null,"verificationMethod":"Fetched the full report PDF from a mirror (Assoambiente); same JRC number and DOI as the official publication"},{"claim":"The Joint Research Centre (JRC) textile waste study states that its list of recycling disruptors 'lacks more detailed information (such as chemical composition) on various coatings, repellents, laminates or prints'. These probably occurred in the sample but 'were not identified in the data collection process'. Water repellents and laminates reach sorting as unidentified chemistry.","claimType":"technical","conditions":null,"confidence":"high","contrary":null,"decisionSupported":"Identify the repellent finish or laminate chemistry before accepting the item into recycling. Not supported.","documentRef":"JRC141441, doi:10.2760/3332076, section 2.4.1.2","exemptions":null,"fields":["chemical"],"handovers":["h6"],"id":"LIFE-16","jurisdiction":"EU (Italy, Czechia, Romania)","lastVerified":"2026-10-23","legalStatus":null,"limitations":"This describes the study's data collection, which used sorters' visual classification and NIR. It does not measure how often finishes are fluorinated.","materialStatus":"waste","note":null,"passage":"While this is an extensive list, it lacks more detailed information (such as chemical composition) on various coatings, repellents, laminates or prints that most likely occurred in the sample, but were not identified in the data collection process.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Section 2.4.1.2, printed p. 27 (PDF p. 31); footnote marker omitted","recipient":"Sorter and recycler","sender":null,"sourceDate":"2025","sourceId":"src-72ee813d","threshold":null,"timing":null,"verificationMethod":"Fetched the full report PDF from a mirror (Assoambiente)"},{"claim":"The Joint Research Centre (JRC) textile waste study recommends focusing sorting for recycling on items of little second-hand value made of one layer, or several layers of the same material, and 'not covered in waterproof treatment, coating or excessive accessories'. A laminated rain jacket with a water-repellent finish fails these criteria on its defining features, before any chemical question is asked.","claimType":"technical","conditions":"Study recommendation on sorting steps, not a legal requirement","confidence":"high","contrary":"Refashion's April 2025 summary of its disruptors study lists 'finishes' among 'internal disruptors' and favours 'single-material, single-layer and monochrome textiles' (https://pro.refashion.fr/en/disruptors-and-facilitators-clothing-household-linen-and-footwear-chf-current-situation). This agrees with the JRC recommendation from the French scheme's side.","decisionSupported":"Accept or exclude the jacket from recycling feedstock","documentRef":"JRC141441, doi:10.2760/3332076, Executive summary","exemptions":null,"fields":["component"],"handovers":["h6"],"id":"LIFE-17","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Recommendation only. Waterproof treatment is something sorters can often see or feel, but the recommendation does not distinguish fluorinated from fluorine-free finishes.","materialStatus":"waste","note":null,"passage":"Sorting for recycling ought to be focused on items that represent limited value on the second-hand market, are made of one layer of material, or multiple layers of the same material, are not covered in waterproof treatment, coating or excessive accessories. Such process should focus on classifying materials aligned to material and fibre composition and colour.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Executive summary (PDF p. 10)","recipient":"Recycler","sender":"Sorter","sourceDate":"2025","sourceId":"src-72ee813d","threshold":null,"timing":null,"verificationMethod":"Fetched the full report PDF from a mirror (Assoambiente)"},{"claim":"In the Joint Research Centre (JRC) textile waste study, even garments judged ready for closed-loop mechanical recycling still need 'the care labels' removed before recycling. Near-infrared (NIR) scanning will not recognise elastane below 5% of a blend. The sewn-in label, the record designed to stay with the garment, becomes a disruptor and is cut off at this point.","claimType":"technical","conditions":"Applies to the 8.2% of garments in the aggregated sample judged readily available for closed-loop mechanical recycling","confidence":"high","contrary":null,"decisionSupported":"Prepare feedstock for recycling (remove labels, confirm elastane)","documentRef":"JRC141441, doi:10.2760/3332076, section 2.4.3.1","exemptions":null,"fields":["component","record"],"handovers":["h6"],"id":"LIFE-18","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Some chemical recycling routes tolerate labels. The same study notes 'Some chemical recyclers report not having the current capacity for disruptor removal at their facilities, relying solely on sorters and third parties' (PDF p. 38).","materialStatus":"waste","note":null,"passage":"In the aggregated sample, on average only 8.2% of garments are readily available for closed-loop mechanical recycling, without any further processing (Table 6). [...] From these garments, the care labels would still have to be removed before recycling and the presence of elastane within each garment would have to be detected by the sorter or recycler, as the NIR technology used in this study will not recognise <5% of elastane in the blend.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Section 2.4.3.1, printed p. 29 (PDF p. 33)","recipient":"Mechanical recycler","sender":"Sorter or pre-processor","sourceDate":"2025","sourceId":"src-72ee813d","threshold":"NIR 'will not recognise <5% of elastane in the blend'","timing":null,"verificationMethod":"Fetched the full report PDF from a mirror (Assoambiente)"},{"claim":"In a 2023 evaluation for the Swedish Chemicals Agency (KemI), the textile recycler Re:newcell said it may be offered deliveries, such as face masks, that it cannot accept 'since they cannot ensure its content'. Recyclers interviewed said they benefit from knowing chemical content 'at both item and material level', and one textile recycler accepts only flows labelled with the Nordic Swan Ecolabel. Without content information, recyclers fall back on refusing material or restricting intake to certified flows.","claimType":"reported-practice","conditions":"Interviews with Swedish waste operators and recyclers; survey response rate 30%","confidence":"high","contrary":"The same report records a textile recycler using the AFIRM Restricted Substances List 'to create requirements towards suppliers', with risk assessment and chemical analysis, which is a working information channel based on contracts.","decisionSupported":"Accept a delivery into recycling","documentRef":"KemI PM 1/23, section 'Results'","exemptions":null,"fields":["chemical","record"],"handovers":["h6"],"id":"LIFE-19","jurisdiction":"Sweden","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Swedish, mainly cellulose recyclers, 2022 to 2023 interviews. Re:newcell's circumstances have since changed. Not specific to polyester or PFAS. 'SVHC' means substances of very high concern under REACH.","materialStatus":"waste","note":null,"passage":"Re:newcell mention in the interview that they may be offered deliveries of e.g., face masks which they are not able to accept since they cannot ensure its content. [...] The third textile recycler is of the opinion that there´s no risk for SVHC in the textiles they are working with since they only work with certain textile flows, such as those labelled with e.g. The Nordic Swan Ecolabel. Recyclers believe that they benefit from knowing the chemical content at both item and material level.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Printed pp. 18 to 19 (PDF pp. 20 to 21)","recipient":"Textile recycler","sender":"Sorter or collector offering feedstock","sourceDate":"2023","sourceId":"src-5520e6d3","threshold":null,"timing":null,"verificationMethod":"Fetched the official PDF from kemi.se"},{"claim":"The European Recycling Industries' Confederation (EuRIC), the trade body for Europe's recyclers, states that 'Recyclers cannot be held responsible for unknown chemical content in post-consumer textiles'. It cites 'the challenges of tracking thousands of substances in post-consumer textiles', and holds that trained sorting operators are best placed to judge reusability. This is an industry position, not a finding.","claimType":"reported-practice","conditions":"Statement on the Joint Research Centre's work on textile end-of-waste criteria","confidence":"high","contrary":null,"decisionSupported":"Accept post-consumer textiles and certify recycled output for end-of-waste status while chemical content is unknown","documentRef":"EuRIC press release and statement","exemptions":null,"fields":["chemical"],"handovers":["h6"],"id":"LIFE-20","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Advocacy position. It confirms that recyclers regard chemical content as unknown. It does not establish what information exists.","materialStatus":"waste","note":null,"passage":"Recyclers cannot be held responsible for unknown chemical content in post-consumer textiles, and red tape must be avoided. An approach should be found that ensures compliance with the chemicals legislation without harming the textiles circular economy, and by considering the challenges of tracking thousands of substances in post-consumer textiles.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Statement, paragraph on the point at which end-of-waste status is granted","recipient":"Textile recycler","sender":null,"sourceDate":"2025-04-29","sourceId":"src-f11fa577","threshold":null,"timing":null,"verificationMethod":"Fetched the statement page on euric.org"},{"claim":"The European Environment Agency (EEA) finds that when textiles reach end of life, 'any available information on PFAS content has usually been lost'. PFAS means per- and polyfluoroalkyl substances. Chemical analysis is 'expensive and generally not feasible', and identifying PFAS-containing textiles by visual inspection is 'very challenging'. The EEA calls for sorting and recycling investment that ensures PFAS-containing textiles are not recycled, and says current practice cannot trace PFAS at the waste stage.","claimType":"technical","conditions":null,"confidence":"high","contrary":"The same briefing sees 'semi-automatic or fully automated sorting based on digital information solutions on the presence of PFAS (such as the DPP and the digital label…) or based on X-ray fluorescence (XRF) machines' as more viable, at 'a high cost'. Its conclusions call for 'ensuring that the PFAS containing textiles are not recycled' and state 'Current practices are not sufficient to trace PFAS content in the after-use and waste stages.'","decisionSupported":"Keep a PFAS-treated jacket out of a recycling stream. Not supported by information currently available at end of life.","documentRef":"EEA Briefing, section 'Identifying, separating and sorting PFAS after use or at end of life'","exemptions":null,"fields":["chemical","result"],"handovers":["h5","h6"],"id":"LIFE-21","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Water resistance is not evidence of PFAS. Visual cues identify a water-repellent garment, not its chemistry. The briefing does not quantify how often information is lost.","materialStatus":"waste","note":null,"passage":"When textiles reach the end-of-life stage, any available information on PFAS content has usually been lost. Performing chemical analyses to identify the textile waste containing PFAS is expensive and generally not feasible. Another option is to establish procedures for the visual identification and sorting of textiles that are likely to contain PFAS. Whilst this does not require significant investments in equipment, it does require resources for manual inspections. It is also highly uncertain if the results would be effective since it is very challenging to identify textiles containing PFAS by visual inspection.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Section 'Identifying, separating and sorting PFAS after use or at end of life', first paragraph","recipient":"Collector, sorter and recycler","sender":null,"sourceDate":"2024-09-17","sourceId":"src-23cf2e8d","threshold":null,"timing":null,"verificationMethod":"Fetched the official EEA web briefing"},{"claim":"Stakeholders interviewed for the Joint Research Centre (JRC) study on digital product passport (DPP) content 'consistently indicated that substance-level concentration and location data are not reported'. They said such data are 'unavailable in a form that could be disclosed reliably and proportionately'. Chemical verification such as OEKO-TEX Standard 100 works 'on a binary pass/fail basis'. The concentration and location fields that a downstream sorter would need are not generated upstream.","claimType":"reported-practice","conditions":"Stakeholder interviews for the ESPR textiles preparatory work","confidence":"high","contrary":"The same passage notes that retailers 'rely on declarations by suppliers, binding contractual terms and third-party certification' for compliance claims, so pass/fail evidence does exist upstream.","decisionSupported":"Any end-of-life decision that depends on which substance is where, and at what concentration","documentRef":"Section on current industry practice (sustainability claims and chemical standards)","exemptions":null,"fields":["result","chemical","record"],"handovers":["h3","h6"],"id":"LIFE-22","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Covers reporting practice, not the existence of test data held privately. The study's data-point table appears to rate readiness of substance-of-concern name data as low ('Not current practice'), but the table's text layer is interleaved, so this is a reading rather than a clean quotation.","materialStatus":"article","note":null,"passage":"OEKO-TEX Standard 100 is cited by stakeholders as the most prevalent mechanism for chemical verification across the sector. It provides trusted verification against regulatory thresholds but operate on a binary pass/fail basis. Stakeholders consistently indicated that substance-level concentration and location data are not reported, and noted that such information is unavailable in a form that could be disclosed reliably and proportionately.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Printed p. 30 (PDF p. 33); footnote marker omitted","recipient":"Downstream actors, including sorters and recyclers","sender":"Brands and retailers placing apparel on the EU market","sourceDate":"2026-05-13","sourceId":"src-b9cc3aff","threshold":null,"timing":null,"verificationMethod":"Fetched the official PDF from the JRC Product Bureau site"},{"claim":"Since 2021 the Waste Framework Directive (WFD) has required suppliers of articles to notify the European Chemicals Agency (ECHA) of the information they must give under REACH Article 33(1). In practice this means Candidate List substances of very high concern (SVHCs) above 0.1% weight by weight. ECHA must give 'waste treatment operators' access to the resulting SCIP database (Substances of Concern In articles as such or in complex objects (Products)). This is the one EU channel built to carry chemical information to the waste stage.","claimType":"legal","conditions":"Covers only substances on the REACH Candidate List present above 0.1% w/w in an article. Notifications are per product, not per waste stream.","confidence":"high","contrary":"Recital 38 of Directive (EU) 2018/851 states the aim: to 'ensure that the information about the presence of substances of very high concern is available throughout the whole life cycle of products and materials, including at the waste stage'.","decisionSupported":"Identify whether an incoming item may contain a Candidate List substance before treatment","documentRef":"Directive 2008/98/EC, Article 9(1)(i) and 9(2), as amended by Directive (EU) 2018/851","exemptions":null,"fields":["chemical","result","handling"],"handovers":["h6"],"id":"LIFE-23","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"PFAS as a group are not on the Candidate List, so SCIP is not a PFAS register. Fluorine-free status cannot be inferred from the absence of a SCIP entry. Access is a legal grant, not proof of use.","materialStatus":"article","note":null,"passage":"2. The European Chemicals Agency shall establish a database for the data to be submitted to it pursuant to point (i) of paragraph 1 by 5 January 2020 and maintain it. The European Chemicals Agency shall provide access to that database to waste treatment operators. It shall also provide access to that database to consumers upon request.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Directive 2008/98/EC, Article 9(2); see Article 9(1)(i) and recital 38 of Directive (EU) 2018/851","recipient":"Waste treatment operators, including sorters and recyclers","sender":"Supplier placing the article on the EU market, via ECHA","sourceDate":"2018-05-30","sourceId":"src-a6e2692f","threshold":"REACH Article 33(1): Candidate List substance in a concentration above 0.1% weight by weight","timing":"Supplier notifications from 5 January 2021. WATCH: the Commission has proposed ending them (see LIFE-25).","verificationMethod":"Fetched the official text of the amending act from the Publications Office (CELEX 32018L0851). The SCIP threshold comes from REACH Article 33(1), which is referenced here but was not re-fetched."},{"claim":"A 2023 evaluation for the Swedish Chemicals Agency (KemI) found that none of 10 interviewed recyclers used the SCIP database (Substances of Concern In articles as such or in complex objects (Products)) regularly: 4 were aware of it and 2 had used it once. The textile recycler Renewcell searched it for substances of very high concern (SVHCs), but the results 'were however not useful' because it could not filter by material. The legal access route exists, but it was not demonstrated to support a textile recycler's decision.","claimType":"reported-practice","conditions":"Recyclers from eight recycling sectors (including textiles) were in scope; 10 were interviewed; survey response rate 30%","confidence":"high","contrary":"One recycler in the report thought SCIP 'could be useful for innovation and development of material sorting system' if linked to automated identification (p. 19).","decisionSupported":"Identify SVHC content in incoming textile waste feedstock","documentRef":"KemI PM 1/23, Table 1 and accompanying text","exemptions":null,"fields":["chemical","record"],"handovers":["h6"],"id":"LIFE-24","jurisdiction":"Sweden","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Small Swedish sample from 2022 to 2023, not France. The report also notes 'When handling large volumes of waste, it is simply not possible to research the content of individual waste items if this is not done automatically' (p. 18).","materialStatus":"waste","note":null,"passage":"Four of the ten interviewed stakeholders state that they have limited knowledge of SCIP but none of them regularly uses it, see Table 1. The textile recycler Renewcell has tried to search SCIP in order to identify SVHC content in the textile waste, primarily cotton or cellulose based, that is being recycled in their process. The results were however not useful to them as it was not possible to filter out information based on relevant materials in reported products. [...] Table 1. Distribution of responses regarding knowledge and use of SCIP amongst interviewed recyclers. Number of stakeholders interviewed 10 Awareness of SCIP 4 Has used SCIP at least once 2 Uses SCIP regularly 0","passageLanguage":"en","passageTranslation":null,"pinpoint":"Printed pp. 16 to 17 (PDF p. 18), including Table 1; footnote marker after 'Renewcell' omitted","recipient":"Textile recycler","sender":"European Chemicals Agency (SCIP)","sourceDate":"2023","sourceId":"src-5520e6d3","threshold":null,"timing":null,"verificationMethod":"Fetched the official PDF from kemi.se"},{"claim":"The Commission's December 2025 'Environmental Omnibus' proposal, COM(2025) 986, would end suppliers' duty to notify the SCIP database (Substances of Concern In articles as such or in complex objects (Products)) and leave the European Chemicals Agency (ECHA) only to 'maintain' data already submitted. The proposed new wording of Article 9(2) drops the sentence that grants waste treatment operators access. On 23 October 2026 the European Parliament's file showed the proposal awaiting committee decision, with an indicative plenary date of 14 December 2026.","claimType":"proposal","conditions":"Ordinary legislative procedure 2025/0394(COD); text may change in Parliament and Council","confidence":"high","contrary":"FEAD, the European Waste Management Association, (19 April 2026) calls SCIP 'overly complex, difficult to use in practice and not sufficiently adapted to the operational needs of waste management companies' yet 'does not support the complete deletion of SCIP', because it 'remains one of the only EU-wide tools providing structured information on the presence of SVHCs in products at end-of-life' (https://fead.be/position/fead-position-on-the-discontinuation-of-scip-database-under-the-environmental-omnibus/).","decisionSupported":"Identify Candidate List substances of very high concern in waste items","documentRef":"COM(2025) 986 final, 2025/0394(COD), recital 5 and Article 1(2)(b)","exemptions":null,"fields":["chemical","record"],"handovers":["h6"],"id":"LIFE-25","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"proposal","limitations":"Proposal only. Status was read through a summarising fetch tool, so check the Legislative Observatory directly before publication. The explanatory memorandum expects digital product passports and 'more comprehensive product labels' to take over SCIP's role.","materialStatus":"article","note":null,"passage":"it is estimated that the database in its current form is not fulfilling its intended objectives. Hence, the obligation for suppliers to submit data to the database should not be continued. Data that has already been reported should continue to be maintained by the European Chemicals Agency. [...] (b)paragraph 2 is replaced by the following: ‘2. The European Chemicals Agency shall maintain the data submitted to it pursuant to paragraph 1, point (ia).’","passageLanguage":"en","passageTranslation":null,"pinpoint":"Recital 5; Article 1, point 2(b) (replacement of WFD Article 9(2))","recipient":"Waste treatment operators","sender":"Supplier of articles, via ECHA","sourceDate":"2025-12-10","sourceId":"src-65da5292","threshold":null,"timing":"Proposed 10 December 2025. Supplier duty would run 'until [date of entry into force of this Directive]'. WATCH: Parliament committee vote possible before 20 November 2026; indicative plenary 14 December 2026.","verificationMethod":"Fetched the official proposal text from the Publications Office (CELEX 52025PC0986, English act). Procedure status read from the European Parliament Legislative Observatory page for 2025/0394(COD) via a summarising fetch."},{"claim":"The Ecodesign for Sustainable Products Regulation (ESPR) requires product-specific delegated acts to make substances of concern traceable 'throughout the life cycle', including their name, 'location … within the product', concentration and information for recycling at end of life. That information must be on the product or reachable through a data carrier on it. 'Substance of concern' includes any substance that 'negatively affects the reuse and recycling of materials'. This is the first EU duty designed to carry finish chemistry to sorters. It applies only once a textiles delegated act is adopted, and none had been adopted at the snapshot.","claimType":"legal","conditions":"Applies only through a delegated act for the product group. Article 2(27)(d) brings in substances that negatively affect reuse and recycling. Article 7(6)(b) allows justified exemptions, but not for Article 2(27)(a) substances above 0.1% w/w.","confidence":"high","contrary":"The Commission's Environmental Omnibus proposal relies on digital product passports to replace SCIP (LIFE-25). If the textiles act is delayed, the waste stage could lose SCIP before gaining ESPR tracking.","decisionSupported":"Locate a substance of concern (for example in the membrane or finish) and decide whether to remove the component or exclude the item from a recycling stream","documentRef":"Regulation (EU) 2024/1781, Articles 2(27)(d), 7(5) and 7(7)","exemptions":"Article 7(6)(b): 'duly justified exemptions ... based on the technical feasibility or relevance of tracking substances of concern, the existence of analytical methods to detect and quantify them, the need to protect confidential business information or in other duly justified cases'","fields":["chemical","component","result","handling"],"handovers":["h3","h6"],"id":"LIFE-26","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"future","limitations":"A future information duty does not prove future transfer. Sorters would need the data carrier to survive, scanning equipment and access rights. Status of the textiles act rests on secondary sources and the JRC's 'tentatively in 2027'.","materialStatus":"article","note":null,"passage":"5. Unless otherwise provided for under paragraph 6, point (b), the information requirements shall make it possible to track the substances of concern, throughout the life cycle of the products concerned, [...] and shall include at least the following: (a) the name or numerical code of the substances of concern present in the product, [...] (b) the location of the substances of concern within the product; (c) the concentration, maximum concentration or concentration range of the substances of concern, at the level of the product, its relevant components, or spare parts; [...] (e) information relevant for disassembly, preparation for reuse, reuse, recycling and the environmentally sound management of the product at end-of-life. [...] Information that makes it possible to track substances of concern pursuant to paragraph 5 shall be given either on the product or be accessible through a data carrier included on the product.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 7(5)(a) to (e) and Article 7(7), last subparagraph; Article 2(27)(d)","recipient":"Treatment facilities, sorters and recyclers (through the digital product passport or label)","sender":"Manufacturer or importer placing the product on the EU market","sourceDate":"2024-06-13","sourceId":"src-de1b4c35","threshold":"'The Commission may, where appropriate for the product group concerned, set thresholds for when the information requirement regarding substances of concern is to apply' (Article 7(5)). No exemption for Article 2(27)(a) substances 'in a concentration above 0,1 % weight by weight' (Article 7(6)(b)).","timing":"Regulation applies; textiles delegated act not adopted at 23 October 2026. The JRC DPP study gives it as 'tentatively in 2027'.","verificationMethod":"Fetched the official Official Journal text (CELEX 32024R1781). Delegated act status checked by web search: no adopted textiles act found, and secondary sources give 2027 or later."},{"claim":"The Joint Research Centre (JRC) study on digital product passport (DPP) content for apparel defines a use case, 'Data exchange to facilitate sorting', whose primary actor is the end-of-life textile sorter and whose required data are 'Product composition and purity' and 'Substances of concern'. In its proposed access levels, substances of concern are public, but their location in the product is limited to those with a 'Legitimate interest'. It warns that benefits depend on a data carrier 'available and permanently attached to garments'.","claimType":"proposal","conditions":"Recommendation for the future ESPR textiles delegated act; requires validation and impact assessment","confidence":"medium","contrary":null,"decisionSupported":"Categorise and sort each garment using DPP data on composition and substances of concern","documentRef":"Section 6.1.4; Annex 1 use case UC13; access-rights table","exemptions":"The study's data-point table appears to suggest exempting substances that are not intentionally added and not present in the final product. The table's text layer is interleaved, so the wording is not quoted here.","fields":["chemical","component","record"],"handovers":["h6"],"id":"LIFE-27","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":null,"limitations":"JRC recommendation, not a Commission proposal or law. 'Legitimate interest' access could exclude sorters unless they qualify. Location is the field a sorter needs to remove a membrane.","materialStatus":"article","note":null,"passage":"However, achieving these benefits effectively requires that the information in the DPP is really accurate so that the sorters can rely on it. Moreover, it requires that the data carrier is available and permanently attached to garments. [...] UC13. Data exchange to facilitate sorting Primary actor: End-of-Life textile sorter Secondary actors: Recycling Facility [...] Data Required [...] • Product composition and purity [...] • Substances of concern [...] Substances of Concern (SoC) Public Location of the SoC Legitimate interest","passageLanguage":"en","passageTranslation":null,"pinpoint":"Section 6.1.4, printed pp. 37 to 38 (PDF p. 40); UC13, printed pp. 88 to 89 (PDF p. 91); access-rights table, printed p. 68 (PDF p. 70)","recipient":"End-of-life textile sorter (primary actor) and recycling facility (secondary actor)","sender":"Manufacturer or importer, through the DPP","sourceDate":"2026-05-13","sourceId":"src-b9cc3aff","threshold":null,"timing":"Delegated act expected 'tentatively in 2027'","verificationMethod":"Fetched the official PDF from the JRC Product Bureau site. Use-case and access-table cells read from the PDF text layer."},{"claim":"A draft Joint Research Centre (JRC) working document for the ESPR (Ecodesign for Sustainable Products Regulation) textiles study says that if REACH adopts a broad restriction on per- and polyfluoroalkyl substances (PFAS), including in textiles, PFAS 'would, most likely, qualify as' substances of concern under Article 2(27)(d), the category for substances that hinder reuse and recycling. That would bring PFAS into the tracking duty that could carry finish chemistry to sorters.","claimType":"proposal","conditions":"Conditional on a universal PFAS restriction under REACH and on the content of the textiles delegated act","confidence":"medium","contrary":null,"decisionSupported":"Exclude PFAS-bearing components or items from recycling streams","documentRef":"3rd milestone working document, lines 7096 to 7101","exemptions":null,"fields":["chemical"],"handovers":["h6"],"id":"LIFE-28","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":null,"limitations":"The document states it 'has not been adopted or endorsed by the European Commission'. The status of the universal PFAS restriction was not verified in this work package.","materialStatus":"article","note":null,"passage":"Following a possible Commission Regulation issued under REACH defining a broad restriction for PFAS, including in textiles, such substances would, most likely, qualify as SoC (d) due to regulatory limitations.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Lines 7096 to 7099, printed p. 252 (PDF p. 255); line numbers and footnote omitted","recipient":"Sorters and recyclers (through future ESPR information requirements)","sender":null,"sourceDate":"2025-12-12","sourceId":"src-d65ce558","threshold":null,"timing":"Draft dated 12 December 2025, posted 15 December 2025","verificationMethod":"Fetched the official draft PDF from the JRC Product Bureau site"},{"claim":"France's PFAS law bans from 1 January 2026 the manufacture, import, export and placing on the market of consumer clothing containing per- and polyfluoroalkyl substances (PFAS). Its implementing decree defines placing on the market as supply to a third party 'pour la première fois' (for the first time). Reselling a used jacket within France therefore appears to fall outside the ban, but the separate ban on 'exportation' is not limited to first supply. Whether a sorter may export a used PFAS-treated jacket for re-use is not resolved by the text.","claimType":"legal","conditions":"Consumer clothing containing PFAS above the residual values in D.525-4. The decree contains no mention of 'occasion', 'seconde main', 'réemploi' or 'réutilisation'.","confidence":"medium","contrary":"The 'first time' definition suggests the law targets new products. Exports of sorted used clothing are a long-standing trade, and no enforcement against them was found.","decisionSupported":"Sell or export a used jacket that may carry a fluorinated finish","documentRef":"Code de l'environnement, Article L.524-1 I 3° (Loi 2025-188, Article 1) and Article D.525-1 (Décret 2025-1376)","exemptions":"Protective equipment (D.525-2 1° and 2°); clothing with at least 20% post-consumer recycled material, for the recycled fraction (D.525-2 3°, see LIFE-30)","fields":["chemical","result"],"handovers":["h6"],"id":"LIFE-29","jurisdiction":"France","lastVerified":"2026-10-23","legalStatus":"unresolved","limitations":"Applicability unresolved. No official guidance on second-hand goods or on exporting used goods was found. Whether a used jacket classed as waste is a 'produit' under L.524-1 is also unresolved. A sorter has no information channel for knowing whether a finish is fluorinated (LIFE-21).","materialStatus":"article","note":null,"passage":"« Art. L. 524-1. I. Sont interdites, à compter du 1er janvier 2026, la fabrication, l'importation, l'exportation et la mise sur le marché à titre onéreux ou gratuit de : [...] « 3° Tout produit textile d'habillement, toute chaussure et tous agents imperméabilisants de produits textiles d'habillement et de chaussures destinés aux consommateurs contenant des substances perfluoroalkylées et polyfluoroalkylées [...] « “Mise sur le marché” : le fait de fournir un produit ou de le mettre à la disposition d'un tiers pour la première fois, à titre onéreux ou non. Toute importation est assimilée à une mise sur le marché.","passageLanguage":"fr","passageTranslation":"Art. L. 524-1. I. From 1 January 2026, the manufacture, import, export and placing on the market, for payment or free of charge, of the following are prohibited: [...] 3° Any clothing textile product, any footwear and any waterproofing agents for clothing textiles and footwear intended for consumers containing perfluoroalkyl and polyfluoroalkyl substances [...] 'Placing on the market': supplying a product or making it available to a third party for the first time, for payment or not. Any import is treated as placing on the market.","pinpoint":"Code de l'environnement L.524-1 I 3°; D.525-1 (definition); D.525-4 (residual values); Décret 2025-1376, Article 2 (sell-through)","recipient":"Re-use buyer in France or abroad","sender":"Sorter or re-use wholesaler","sourceDate":"2025-12-28","sourceId":"src-9b70ac55","threshold":"D.525-4: 25 ppb for any PFAS measured by targeted analysis (excluding polymers); 250 ppb for the sum of PFAS; 50 ppm for PFAS including polymers; proof of origin of fluorine required on request if total fluorine exceeds 50 mg F/kg","timing":"Ban from 1 January 2026. Products made before 1 January 2026 may be placed on the market or exported for up to 12 months, after which 'toute mise sur le marché ou exportation de ces produits est interdite' (from 1 January 2027). WATCH: sell-through ends 31 December 2026.","verificationMethod":"Fetched the consolidated law and decree on AIDA (INERIS). Légifrance refused automated access (HTTP 403)."},{"claim":"France's PFAS decree exempts from the clothing ban garments that contain at least 20% recycled material from post-consumer waste, but per- and polyfluoroalkyl substances (PFAS) are allowed only in that recycled fraction, in proportion to it. French law therefore expects that recycled textile feedstock may carry PFAS and lets recycled content bring some back into new garments.","claimType":"legal","conditions":"Garment incorporates at least 20% post-consumer recycled material","confidence":"high","contrary":"The EU restriction on undecafluorohexanoic acid (PFHxA) has no equivalent recycled-content exemption (LIFE-31).","decisionSupported":"Accept recycled fibre of unknown PFAS status into a new garment for the French market","documentRef":"Code de l'environnement, Article D.525-2 3°","exemptions":"This is itself an exemption (D.525-2 3°), repeated for the 2030 all-textiles ban in D.525-3 3°","fields":["chemical","result"],"handovers":["h6"],"id":"LIFE-30","jurisdiction":"France","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"The decree gives no method for showing that PFAS come from the recycled fraction. It does not tell recyclers how to detect PFAS in feedstock.","materialStatus":"article","note":null,"passage":"« 3° Les textiles d'habillement et chaussures incorporant au moins vingt pour cent (20 %) de matière recyclée issue de déchets post-consommation. La présence de substances perfluoroalkylées et polyfluoroalkylées dans le produit fini est limitée à la fraction de matière recyclée, de sorte que la quantité de PFAS résiduelle admissible dans le produit fini est proportionnelle à la proportion de matière recyclée incorporée.","passageLanguage":"fr","passageTranslation":"3° Clothing textiles and footwear incorporating at least twenty per cent (20%) recycled material from post-consumer waste. The presence of perfluoroalkyl and polyfluoroalkyl substances in the finished product is limited to the recycled fraction, so that the permissible residual quantity of PFAS in the finished product is proportional to the share of recycled material incorporated.","pinpoint":"Article D.525-2 3°","recipient":"Brand or importer placing new garments on the French market","sender":"Recycler supplying recycled fibre","sourceDate":"2025-12-28","sourceId":"src-9b70ac55","threshold":"'au moins vingt pour cent (20 %) de matière recyclée issue de déchets post-consommation'; residual PFAS proportional to the recycled share","timing":"From 1 January 2026","verificationMethod":"Fetched the consolidated decree on AIDA (INERIS). Légifrance refused automated access (HTTP 403)."},{"claim":"The EU restriction on undecafluorohexanoic acid (PFHxA), its salts and related substances under REACH Annex XVII has applied since 10 October 2026 to clothing textiles for the general public, at 25 ppb (PFHxA and salts) or 1,000 ppb (related substances). It does not apply to articles 'placed on the market before 10 October 2026'. The entry says nothing about second-hand goods, waste or recycled material, and its recitals name 'outdoor clothing like rain jackets'.","claimType":"legal","conditions":"Measured in homogeneous material. Articles placed on the market before 10 October 2026 are excluded from paragraph 1.","confidence":"high","contrary":"See LIFE-32 on how this entry differs from the nonylphenol ethoxylate (NPE) restriction, which explicitly exempts second-hand and recycled textiles.","decisionSupported":"Place a jacket, new or with recycled content, on the EU market","documentRef":"REACH Annex XVII, entry 79, paragraphs 1(a) and 7; recital 15","exemptions":"Paragraph 7: articles and mixtures placed on the market before 10 October 2026","fields":["chemical","result"],"handovers":["h6"],"id":"LIFE-31","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"duty","limitations":"Covers one PFAS subgroup, not all PFAS. A restriction is not an information duty: nothing here requires the PFHxA status to be passed to sorters.","materialStatus":"article","note":null,"passage":"1. Shall not, from 10 October 2026 be placed on the market, or used, in a concentration equal to or greater than 25 ppb for the sum of PFHxA and its salts, or 1 000 ppb for the sum of PFHxA-related substances, measured in homogeneous material, in the following: (a) textiles, leather, furs and hides in clothing and related accessories for the general public; [...] 7. By way of derogation from paragraph 1, that paragraph shall not apply to articles and mixtures which were placed on the market before 10 October 2026.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Annex, entry 79, paragraphs 1(a) and 7","recipient":"Market surveillance authorities and downstream buyers","sender":"Supplier placing a jacket or recycled-content garment on the EU market","sourceDate":"2024-09-19","sourceId":"src-3abba0ad","threshold":"25 ppb for the sum of PFHxA and its salts, or 1 000 ppb for the sum of PFHxA-related substances, measured in homogeneous material","timing":"Applies from 10 October 2026","verificationMethod":"Fetched the official Official Journal text (CELEX 32024R2462). Searched the full text for 'second-hand', 'recycl' and 'waste' and found no matches."},{"claim":"The EU restriction on nonylphenol ethoxylates (NPE) in textiles states expressly that it does not apply to 'second-hand textile articles' or to new articles made 'exclusively from recycled textiles' without NPE. The undecafluorohexanoic acid (PFHxA) restriction has no such clause. REACH defines placing on the market as any supply to a third party, not only first supply. Whether the PFHxA limits apply when a jacket first sold before 10 October 2026 is resold, or when recycled fibre goes into new clothing, is therefore not settled by the text.","claimType":"interpretation","conditions":"REACH Article 3(12): 'Placing on the market: means supplying or making available, whether in return for payment or free of charge, to a third party.'","confidence":"medium","contrary":"The NPE reasoning relies on washing removing NPE. PFAS side-chain polymers are designed to resist washing, which may explain why no parallel exemption was given, but the Regulation does not state this.","decisionSupported":"Resell a used jacket, or accept recycled polyester into new clothing, under EU PFAS restrictions","documentRef":"REACH Annex XVII, entry 46a, paragraph 2; recital 11","exemptions":"NPE entry 46a(2): second-hand textile articles; new articles made without NPE exclusively from recycled textiles","fields":["chemical","result"],"handovers":["h6"],"id":"LIFE-32","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"unresolved","limitations":"Interpretation by comparing texts. No European Chemicals Agency or Commission guidance on second-hand articles under entry 79 was consulted. Paragraph 7 may be read as covering resale of a jacket first placed on the market before 10 October 2026, but the text does not say so.","materialStatus":"article","note":null,"passage":"2. Paragraph 1 shall not apply to the placing on the market of second-hand textile articles or of new textile articles produced, without the use of NPE, exclusively from recycled textiles.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Annex XVII entry 46a(2); recital 11 gives the reason (second-hand textiles 'will usually have been washed several times')","recipient":"Re-use buyer or brand using recycled fibre","sender":"Re-use seller or recycler","sourceDate":"2016-01-13","sourceId":"src-c585a5d5","threshold":"NPE: 0,01 % by weight (entry 46a(1))","timing":"NPE restriction from 3 February 2021; PFHxA from 10 October 2026","verificationMethod":"Fetched the official Official Journal texts of Regulation (EU) 2016/26 (CELEX 32016R0026) and of REACH (original OJ L 396, 30.12.2006, Article 3(12))"},{"claim":"Once the 2025 Waste Framework Directive (WFD) amendment is transposed, each bale of used textiles shipped as fit for re-use must carry a record, fixed to the packaging, describing the items 'such as type of clothes, size, colour, gender, material composition', and naming the company that did the final sorting. A copy of every bale record must go with the consignment. This is a new information channel from sorter to re-use buyer. It describes bale contents at sorting granularity and has no chemical field.","claimType":"legal","conditions":"Applies to shipments of used textiles assessed as fit for re-use. Article 22d(8) also requires an invoice and contract stating the items are fit for direct re-use, a protocol, and a declaration that none of the material is waste.","confidence":"high","contrary":null,"decisionSupported":"Accept the bale as used goods fit for re-use rather than waste, and target the right re-use market","documentRef":"Directive 2008/98/EC, Article 22d(8) and (9), inserted by Directive (EU) 2025/1892","exemptions":null,"fields":["component","record"],"handovers":["h6"],"id":"LIFE-33","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"future","limitations":"Bale-level, not item-level. 'Material composition' at bale level will come from labels and visual sorting. The record is 'not permanently' fixed and stops at the bale buyer. Recital 50 notes that exports are 'the greatest share of the re-use market'.","materialStatus":"article","note":null,"passage":"(a) the record of the sorting, the direct professional assessment as fit for re-use or the preparing for re-use operations is fixed securely but not permanently on the packaging; (b) the record contains the following information: (i) a description of the item or items present in the bale reflecting the most detailed sorting granularity that the textile items have undergone during the sorting or preparing for re-use operations such as type of clothes, size, colour, gender, material composition, and any other relevant characteristics that contribute to efficient re-use; (ii) the name and address of the company responsible for the final sorting or preparing for re-use.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 22d(9)(a) and (b); see Article 22d(8)(a) to (c)","recipient":"Re-use buyer, carrier and inspection authorities, in the EU or abroad","sender":"Sorting or preparing-for-re-use operator","sourceDate":"2025-09-10","sourceId":"src-aa88b6cc","threshold":null,"timing":"Transposition by 17 June 2027","verificationMethod":"Fetched the official Official Journal text (CELEX 32025L1892)"},{"claim":"The European Environment Agency (EEA) reports that EU exports of used textiles reached almost 1.7 million tonnes in 2019: 46% went to Africa and 41% to Asia. The 'fate of used textiles exported from the EU is highly uncertain'. The customs codes used, Combined Nomenclature (CN) 6309 and 6310, include 'no code for textile waste export', and 'classification does not necessarily describe the true state of what is exported'. Trade records do not record whether an item is waste, let alone its chemistry.","claimType":"reported-practice","conditions":"Trade data based on national reporting; the EEA says 'all numbers should be understood as indicative'","confidence":"high","contrary":"The EEA notes that imported used textiles in Africa 'primarily go towards local reuse as there is a demand for cheap, used clothes from Europe'.","decisionSupported":"Classify an export consignment as used goods or as waste","documentRef":"EEA Briefing, Key messages and Box 1","exemptions":null,"fields":["record"],"handovers":["h6"],"id":"LIFE-34","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Data are from 2019 and EU-wide, not French. The JRC textile waste study adds that 'Databases such as EU Comext and UN Comtrade only report first export destinations' (JRC141441, PDF p. 38). Destination shares say nothing about any one jacket.","materialStatus":"article","note":null,"passage":"The amounts of used textiles exported from the EU has tripled over the last two decades from slightly over 550,000 tonnes in 2000 to almost 1.7 million tonnes in 2019. [...] The fate of used textiles exported from the EU is highly uncertain. [...] In 2019, 46% of used textiles ended up in Africa. [...] In 2019, 41% of used textiles ended up in Asia. [...] There is no code for textile waste export. [...] In other words, classification does not necessarily describe the true state of what is exported.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Key messages; Box 1 (CN codes 6309 and 6310)","recipient":"Re-use buyer outside the EU; customs authorities","sender":"EU exporter of used textiles","sourceDate":"2023-02-27","sourceId":"src-01a4ac17","threshold":null,"timing":"2019 data","verificationMethod":"Fetched the official EEA web briefing"},{"claim":"France's environment ministry states that only about 35% of used textiles are collected, the rest going to household waste for incineration or landfill. It also states that the French scheme 'dépend de l'exportation' (depends on export) for both re-use and recycling of used textiles. A jacket that leaves France for re-use or recycling follows the scheme's normal route.","claimType":"reported-practice","conditions":null,"confidence":"high","contrary":"The same page lists a target of 15% re-use within 1,500 km of the collection point by 2027.","decisionSupported":"Route sorted textiles to re-use or recycling outlets in France or abroad","documentRef":"Ministry policy page on the textile EPR scheme","exemptions":null,"fields":["record"],"handovers":["h5","h6"],"id":"LIFE-35","jurisdiction":"France","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Gives no export volumes or destinations. The 35% figure has no stated base year. The same page cites 2021 figures (244,500 tonnes collected; 58% re-use, 33% recycling, 9% solid recovered fuel).","materialStatus":"waste","note":null,"passage":"Cependant, la collecte des textiles usagés reste insuffisante : elle atteint environ 35 %, le reste des textiles usagés rejoignant les ordures ménagères pour être incinéré ou enfoui. En outre, la filière dépend de l’exportation pour la réutilisation et le recyclage des textiles usagés.","passageLanguage":"fr","passageTranslation":"However, collection of used textiles remains insufficient: it reaches about 35%, with the rest of used textiles going into household waste to be incinerated or landfilled. In addition, the scheme depends on export for the re-use and recycling of used textiles.","pinpoint":"Section 'Spécificités'","recipient":"Re-use buyers and recyclers outside France","sender":"French sorters","sourceDate":"2026-08-31","sourceId":"src-28d07f14","threshold":null,"timing":"Page updated 31 August 2026","verificationMethod":"Fetched the official ministry web page"},{"claim":"The Global Framework on Chemicals (GFC) was established at the fifth International Conference on Chemicals Management (ICCM5) in Bonn in September 2023 and adopted by resolution V/1 as a voluntary framework. None of its targets, including the one on information in products, creates a binding duty on any actor at any handover.","claimType":"legal","conditions":"Applies as a voluntary framework to governments and other stakeholders that choose to implement it.","confidence":"high","contrary":null,"decisionSupported":null,"documentRef":"ICCM5 resolution V/1","exemptions":null,"fields":["component","chemical","result","handling","record"],"handovers":["h1","h2","h3","h4","h5","h6"],"id":"GFC-01","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"The page gives the conference dates, not the exact day of adoption. Voluntary status means the GFC does not itself require anyone to pass information; any duty at a handover comes from national or EU law (R1, R2).","materialStatus":"n/a","note":null,"passage":"The Global Framework on Chemicals – For a Planet free of Harm from Chemicals and Waste was formally established at the fifth International Conference on Chemicals Management (ICCM5) in Bonn, Germany, held from 25-29 September 2023. [...] The Global Framework on Chemicals – For a Planet Free of Harm from Chemicals and Waste was adopted by the Conference with resolution V/1 as a new voluntary global framework in the field of international chemicals and waste management.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Overview and 'Text of the Framework' sections of the page (page marked 'Last updated: 05 Mar 2026')","recipient":null,"sender":null,"sourceDate":"2026-03-05","sourceId":"src-c87f8ebf","threshold":null,"timing":"Adopted at ICCM5, Bonn, 25 to 29 September 2023.","verificationMethod":"Fetched archived copy of official UNEP page (Wayback capture 20261013113552); live unep.org blocked automated requests (HTTP 403)"},{"claim":"GFC Target B2 reads in full: 'By 2030, stakeholders make available, to the extent possible, reliable information on chemicals in materials and products throughout the value chain.' It names no information fields, no sender and no recipient, and it is qualified by 'to the extent possible'.","claimType":"legal","conditions":"'to the extent possible'","confidence":"high","contrary":null,"decisionSupported":null,"documentRef":"Global Framework on Chemicals, section V.B, Target B2","exemptions":null,"fields":["chemical","component"],"handovers":["h1","h2","h3","h4","h5","h6"],"id":"GFC-02","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"A target, not a duty. 'Reliable' is not defined. Target B3 (by 2035) separately covers generating and publishing data on the use of chemicals in materials and products. The handover measures in this piece are Foresight's own and are not GFC indicators. sourceDate is the month of ICCM5; the exact adoption day was not confirmed from the page fetched.","materialStatus":"article","note":null,"passage":"By 2030, stakeholders make available, to the extent possible, reliable information on chemicals in materials and products throughout the value chain.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Section V (Strategic objectives and targets), part B (Targets), Target B2","recipient":"Actors 'throughout the value chain' (not specified)","sender":"Stakeholders (not specified)","sourceDate":"2023-09","sourceId":"src-c7c71604","threshold":null,"timing":"By 2030","verificationMethod":"Fetched archived copy of official UNEP text page (Wayback capture 20261016105408; live site blocked automated requests); wording matches the target as restated in UNEP/GFC/IC.1/4, annex I"},{"claim":"The GFC's scope covers the life cycle of chemicals 'including products and waste', and its Strategic Objective B aims for information that is 'accessible to all to enable informed decisions and actions'. On its own terms the framework therefore reaches the collector, sorter and recycler at H5 and H6, not only the factory.","claimType":"interpretation","conditions":null,"confidence":"high","contrary":null,"decisionSupported":null,"documentRef":"Global Framework on Chemicals, paragraph 8 and Strategic objective B","exemptions":null,"fields":["chemical","handling"],"handovers":["h5","h6"],"id":"GFC-03","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"Scope language creates no access right for a sorter or recycler and does not say what they need to know.","materialStatus":"waste","note":null,"passage":"8. The scope of the Framework covers the life cycle of chemicals, including products and waste. [...] B. Comprehensive and sufficient knowledge, data and information are generated, available and accessible to all to enable informed decisions and actions.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Section III (Scope), paragraph 8; section V.A, Strategic objective B","recipient":"Collectors, sorters and recyclers (by scope, not by named duty)","sender":null,"sourceDate":"2023-09","sourceId":"src-c7c71604","threshold":null,"timing":null,"verificationMethod":"Fetched archived copy of official UNEP text page (Wayback capture 20261016105408)"},{"claim":"The GFC's hooks for finishing-mill workers at H1 are Target B6 (all governments implement the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) by 2030), Target D7 (effective occupational health and safety 'throughout the supply chain') and paragraph 43, which asks industry to conduct due diligence so that International Labour Organization (ILO) health and safety standards apply 'throughout their value chains'.","claimType":"legal","conditions":"Paragraph 43 is expressed as 'should'.","confidence":"high","contrary":"Paragraph 46 calls for 'the ratification and implementation of relevant International Labour Organization standards', yet neither Viet Nam nor France has ratified Convention No. 170 (GFC-34).","decisionSupported":null,"documentRef":"Global Framework on Chemicals, Targets B6 and D7; paragraph 43","exemptions":null,"fields":["handling","chemical"],"handovers":["h1"],"id":"GFC-04","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"None of these texts says what information a worker receives or in what language. ILO Convention No. 170 and Recommendation No. 177 do (GFC-32 to GFC-35). Whether Vietnamese law requires GHS labels and safety data sheets for the finishing agent is for R2.","materialStatus":"mixture","note":null,"passage":"By 2030, all Governments have implemented the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) in all relevant sectors as appropriate for their national circumstances. [...] By 2030, stakeholders implement measures and strive to ensure effective occupational health and safety practices as well as environmental protection measures in all relevant sectors and throughout the supply chain. [...] 43. Industry and the private sector should conduct due diligence to ensure that international standards, including International Labour Organization standards, on health and safety in the management of chemicals and waste are put in place throughout their value chains in order to protect health and respect human rights.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Section V.B, Targets B6 and D7; section VI, paragraph 43","recipient":"Finishing-mill workers","sender":"Chemical supplier and employer (finishing mill)","sourceDate":"2023-09","sourceId":"src-c7c71604","threshold":null,"timing":"Targets B6 and D7: by 2030","verificationMethod":"Fetched archived copy of official UNEP text page (Wayback capture 20261016105408)"},{"claim":"The GFC treats skills as part of the work: Target B5 calls for training and public awareness programmes on chemical safety and safer alternatives by 2030, and paragraph 57 says 'All stakeholders should be equipped with the necessary skills, knowledge and resources to implement the Framework.' The framework itself does not assume that available information is usable information.","claimType":"legal","conditions":null,"confidence":"high","contrary":null,"decisionSupported":null,"documentRef":"Global Framework on Chemicals, Target B5; paragraph 57","exemptions":null,"fields":["handling"],"handovers":["h1","h2","h5","h6"],"id":"GFC-05","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"Does not specify who trains whom or what a handler at any handover must be able to read. The proposed training indicator for B5 (B5.2 in UNEP/GFC/IC.1/4) is marked in that document as having divergent views.","materialStatus":"n/a","note":null,"passage":"By 2030, educational, training and public awareness programmes on chemical safety, sustainability, safer alternatives and the benefits of reducing chemicals and waste risks have been developed and implemented, taking into consideration a gender-responsive approach. [...] All stakeholders should be equipped with the necessary skills, knowledge and resources to implement the Framework.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Section V.B, Target B5; section VIII (Capacity-building), paragraph 57","recipient":"All stakeholders, including workers, sorters and recyclers","sender":null,"sourceDate":"2023-09","sourceId":"src-c7c71604","threshold":null,"timing":"Target B5: by 2030","verificationMethod":"Fetched archived copy of official UNEP text page (Wayback capture 20261016105408)"},{"claim":"Alongside information, the GFC sets substitution and sector targets: Target D4 asks stakeholders to prioritise 'safer alternatives to harmful substances in products and mixtures, including in consumer products', and Target D6 calls for sector strategies that identify priority chemicals of concern and reduce 'their input along the value chain'. Information under Target B2 can inform these decisions but does not replace them.","claimType":"legal","conditions":null,"confidence":"high","contrary":null,"decisionSupported":"Whether to substitute a chemistry or set a sector restriction","documentRef":"Global Framework on Chemicals, Targets D4 and D6","exemptions":null,"fields":["chemical"],"handovers":["h1","h2","h3"],"id":"GFC-06","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"Neither target names textiles or per- and polyfluoroalkyl substances (PFAS). Whether a fluorine-free finish is a safer alternative in a given case needs a substitution assessment this source does not make.","materialStatus":"mixture","note":null,"passage":"By 2030, relevant stakeholders give priority to sustainable solutions and safer alternatives to harmful substances in products and mixtures, including in consumer products, in their research and innovation programmes. [...] By 2030, sustainable chemical and waste management strategies have been developed and implemented for major economic and industry sectors that identify priority chemicals of concern and standards and measures, such as the chemical footprint approach, to reduce their impact and, where feasible, their input along the value chain.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Section V.B, Targets D4 and D6","recipient":"Chemical suppliers, mills and brands (as decision-makers)","sender":null,"sourceDate":"2023-09","sourceId":"src-c7c71604","threshold":null,"timing":"Targets D4 and D6: by 2030","verificationMethod":"Fetched archived copy of official UNEP text page (Wayback capture 20261016105408)"},{"claim":"The first session of the International Conference of the GFC (IC1) runs from 16 to 20 November 2026 at the Geneva International Conference Centre, hosted by Switzerland. Under agenda item 4(c) it may consider a draft resolution and proposed indicators for possible adoption.","claimType":"proposal","conditions":null,"confidence":"high","contrary":null,"decisionSupported":null,"documentRef":"UNEP/GFC/IC.1/INF/1","exemptions":null,"fields":[],"handovers":[],"id":"GFC-07","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"proposal","limitations":"A scenario note sets expectations; it does not record decisions. Outcomes will not be known until the session ends on 20 November 2026.","materialStatus":"n/a","note":null,"passage":"2. The first session of the International Conference of the Global Framework on Chemicals will be held at the Geneva International Conference Centre from 10 a.m. on Monday, 16 November 2026 to 6 p.m. on Friday, 20 November 2026 and will be hosted by the Government of Switzerland. [...] (a) Agenda item 4 (c): Measurability structure and indicators. Pursuant to resolution V/9 and informed by the work of the open-ended ad hoc group on measurability and indicators, the International Conference may consider a draft resolution and proposed indicators for possible adoption, as set out in document UNEP/GFC/IC.1/4;","passageLanguage":"en","passageTranslation":null,"pinpoint":"Paragraphs 2 and 8(a)","recipient":null,"sender":null,"sourceDate":"2026-09-10","sourceId":"src-4180a7ee","threshold":null,"timing":"16 to 20 November 2026; regional and constituency discussions on Sunday 15 November","verificationMethod":"Fetched official PDF via the UN Official Document System (documents.un.org; the symbol lookup returned an HTML stub, so the job-number link was used)"},{"claim":"Pre-session document UNEP/GFC/IC.1/4 proposes three new indicators for Target B2, each with '[globally]' still in square brackets: countries with measures on harmonised digital products and materials information systems (B2.1), stakeholders using a harmonised standard, tool or platform to share information about chemicals in materials and products 'along the full value chain' (B2.2), and countries making harmonised data publicly accessible (B2.3). They are drafts for possible adoption at IC1, not adopted indicators.","claimType":"proposal","conditions":"Bracketed text is not agreed. The draft resolution would adopt only the indicators in annex I, section A.","confidence":"high","contrary":null,"decisionSupported":null,"documentRef":"UNEP/GFC/IC.1/4, annex I, section A, Target B2; paragraph 14","exemptions":null,"fields":["chemical","component"],"handovers":["h1","h2","h3","h4","h5","h6"],"id":"GFC-08","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"proposal","limitations":"The proposed indicators count countries and stakeholders that have systems. None measures whether a named field reaches a named recipient at a handover, which is this piece's unit of analysis. The piece's measures must not be presented as GFC indicators.","materialStatus":"n/a","note":null,"passage":"B2.1 Number of countries with measures on [globally] harmonized digital products and materials information systems across sectors [new indicator] [...] B2.2 Number of stakeholders, including in industry and the private sector, that use/implement a [globally] harmonized standard/tool/platform for sharing information about chemicals in [...] materials and products along the full value chain (e.g. digital products and materials information system) [new indicator] [...] B2.3 | B3.4 Number of countries that make [globally] harmonized data on chemicals in materials and products publicly accessible [new indicator] [...] 14. It should be noted that the draft indicators forwarded by the open-ended ad hoc group to the International Conference do not necessarily constitute approval of the indicators and/or their formulation by all members of the group.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Annex I, section A, Target B2 (indicators B2.1 to B2.3); paragraph 14","recipient":null,"sender":null,"sourceDate":"2026-08-27","sourceId":"src-652055b2","threshold":null,"timing":"For possible adoption at IC1, 16 to 20 November 2026. The draft resolution asks the secretariat to report progress 'in 2027 and annually thereafter'.","verificationMethod":"Fetched official PDF via the UN Official Document System (documents.un.org); table text extracted in reading order"},{"claim":"The secretariat's indicative overview for IC1 finds that practices to provide information on chemicals in products 'are emerging' but that there is 'still a lack of effective systems and mechanisms to collect and share this information along the value chain'. For Target B2 it counts 48 countries with measures on harmonised digital information systems and 38 countries and 211 companies using a harmonised standard or platform, and says the data do not allow a robust assessment of the reliability of the information shared.","claimType":"reported-practice","conditions":null,"confidence":"high","contrary":"The same overview reports '13,000 supplier facilities and > 350 signatories' in the Zero Discharge of Hazardous Chemicals (ZDHC) textiles programme under Target D6, evidence of sector infrastructure for chemical information at production stages.","decisionSupported":null,"documentRef":"UNEP/GFC/IC.1/3, paragraphs 2 and 9; annex scorecard, Target B2","exemptions":null,"fields":["chemical","record"],"handovers":["h1","h2","h3","h4","h5","h6"],"id":"GFC-09","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Indicative only and not sector-specific. Counts of countries and companies with systems say nothing about whether textile finish chemistry reaches sorters or recyclers.","materialStatus":"n/a","note":null,"passage":"the present assessment is indicative only. [...] Practices are emerging to provide information on chemicals in products and materials but there is still a lack of effective systems and mechanisms to collect and share this information along the value chain. [...] 48 countries have measures on harmonized digital products and materials information systems across [...] 38 countries and 211 companies use a globally harmonized standard, tool or platform (e.g. SCIP and GHS) for sharing information about chemicals in materials and products along the value chain [...] Available data do not enable a robust assessment of the reliability","passageLanguage":"en","passageTranslation":null,"pinpoint":"Paragraphs 2 and 9; annex, strategic objective B table, Target B2 row","recipient":null,"sender":null,"sourceDate":"2026-08-26","sourceId":"src-2df579f6","threshold":null,"timing":null,"verificationMethod":"Fetched official PDF via the UN Official Document System (documents.un.org); annex table cells are interleaved in the PDF text layer, so the scorecard quotes are given as separate fragments"},{"claim":"The IC1 document on issues of concern keeps 'chemicals in products' and 'managing perfluorinated chemicals and the transition to safer alternatives' on the list. It says that outside sectors with mandatory ingredient labelling, information exchange 'relies primarily on voluntary initiatives by individual sectors or companies', credits textile-sector systems and tools with progress, and says gaps remain in transparency, access to information and uptake.","claimType":"reported-practice","conditions":"The note proposes handling chemicals in products under implementation programmes 1 and 2; IC1 decides.","confidence":"high","contrary":"Paragraph 8 also notes 'mandatory communication of chemicals used in products' through full ingredient lists in sectors such as cosmetics, showing that product-level disclosure exists where law requires it.","decisionSupported":null,"documentRef":"UNEP/GFC/IC.1/5, paragraphs 1 and 8","exemptions":null,"fields":["chemical"],"handovers":["h1","h2","h3","h4"],"id":"GFC-10","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"proposal","limitations":"A secretariat assessment, not a finding about any specific product or route. It does not say which textile systems it means.","materialStatus":"article","note":null,"passage":"(a) Chemicals in products; [...] (g) Managing perfluorinated chemicals [...] and the transition to safer alternatives; [...] In other sectors, however, such legal requirements are more limited, and information exchange relies primarily on voluntary initiatives by individual sectors or companies. [...] been made through the development of information systems, guidance, tools and projects based on sectors and value chains, such as those for textiles, toys, electronics, and buildings and construction. [...] Nevertheless, gaps remain in transparency, in access to information and uptake across sectors and regions, and in assessing and reducing the exposure of humans and the environment to harmful chemicals in products.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Paragraph 1(a) and (g); paragraph 8","recipient":null,"sender":null,"sourceDate":"2026-08-25","sourceId":"src-8554ec22","threshold":null,"timing":"Decision expected at IC1, 16 to 20 November 2026","verificationMethod":"Fetched official PDF via the UN Official Document System (documents.un.org)"},{"claim":"IC1 is asked to confirm industry sector programmes for four high-impact sectors, including textiles, and a thematic workstream on 'Transparency, traceability and disclosure along value chains (target B2)'. The draft workplan gives the textiles programme 2027 to 2028 for mapping initiatives, knowledge-sharing, raising awareness and piloting, convened by UNEP.","claimType":"proposal","conditions":"Subject to IC1 decision on implementation arrangements","confidence":"high","contrary":null,"decisionSupported":null,"documentRef":"UNEP/GFC/IC.1/6, paragraphs 16 and 17(b); workplan activity 12","exemptions":null,"fields":["chemical","record"],"handovers":["h1","h2","h3"],"id":"GFC-11","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"proposal","limitations":"Draft arrangements. The workplan table (activity 5) labels the same workstream '(target B1)' with the United Nations Institute for Training and Research (UNITAR) as convenor, while paragraph 17(b) says target B2. Treat the target link as unsettled until IC1 decides.","materialStatus":"n/a","note":null,"passage":"Under implementation programme 2, industry sector programmes are established for high-impact sectors, currently construction, electronics, healthcare and textiles. [...] (b) Transparency, traceability and disclosure along value chains (target B2); [...] Advancing industry sector programmes – textiles a • Mapping of stakeholder initiatives, knowledge-sharing, raising industry awareness and piloting innovative approaches","passageLanguage":"en","passageTranslation":null,"pinpoint":"Paragraphs 16 and 17(b); workplan table, activity 12 (textiles)","recipient":null,"sender":null,"sourceDate":"2026-08-24","sourceId":"src-80ab7eb7","threshold":null,"timing":"Textiles sector programme activities 2027 to 2028; workstream landscape analyses from 2027","verificationMethod":"Fetched official PDF via the UN Official Document System (documents.un.org)"},{"claim":"IC1's programme includes sector exchanges on textiles covering 'data transparency, traceability and disclosure', a 'Fashion for the future' evening event on 16 November, and a high-level conversation titled 'Transparency without overload'. That title names the tension this piece examines: more data is not the same as usable information at each handover.","claimType":"interpretation","conditions":null,"confidence":"high","contrary":null,"decisionSupported":null,"documentRef":"UNEP/GFC/IC.1/INF/1, paragraphs 14 to 16","exemptions":null,"fields":[],"handovers":[],"id":"GFC-12","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"The second sentence of the claim is Foresight's reading of the session title; the scenario note does not describe the conversation's content.","materialStatus":"n/a","note":null,"passage":"There will be opportunities for hybrid exchanges on the construction, electronics, healthcare and textiles sectors, in addition to discussions on cross-cutting issues. These issues include labour, green and sustainable chemistry, priority chemicals of concern, data transparency, traceability and disclosure, chemical footprinting and reporting standards, [...] A “Fashion for the future” event will take place on the evening of Monday, 16 November. [...] The conversations are entitled “Transparency without overload”; “Green and sustainable chemistry: solution or pipe dream?”; and “De-risking the future: investing beyond hazardous chemicals”.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Paragraphs 14, 15 and 16","recipient":null,"sender":null,"sourceDate":"2026-09-10","sourceId":"src-4180a7ee","threshold":null,"timing":"16 to 20 November 2026","verificationMethod":"Fetched official PDF via the UN Official Document System (documents.un.org)"},{"claim":"UNEP's 2011 Chemicals in Products (CiP) textile case study found that 'except for fiber content essentially no information system exists for transmitting data on what chemicals are contained in individual products.' Fibre content, which the sewn-in label still carries, was the one field it found travelling with the garment.","claimType":"reported-practice","conditions":null,"confidence":"high","contrary":"The same summary found 'one or two companies' requiring full disclosure of chemicals entering production and in final products, 'encouraging in that full disclosure can be part of a viable manufacturing' model. IC.1/5 (2026) also credits textile information systems with progress (GFC-10).","decisionSupported":null,"documentRef":"CiP textile case study, summary","exemptions":null,"fields":["component","chemical"],"handovers":["h2","h3","h4"],"id":"GFC-13","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"Fifteen years old. It predates the ZDHC Gateway, the OEKO-TEX ECO PASSPORT disclosure model and the EU digital product passport. Evidence of practice in 2011, not now.","materialStatus":"article","note":null,"passage":"With respect to current methods of exchanging information on chemicals in textile products, this study found that except for fiber content essentially no information system exists for transmitting data on what chemicals are contained in individual products.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Summary (PDF page 5)","recipient":"Downstream buyers and consumers","sender":"Garment makers and brands","sourceDate":"2011-01","sourceId":"src-4c7026d2","threshold":null,"timing":null,"verificationMethod":"Fetched archived copy of official UNEP PDF (Wayback capture 20241209025509); live wedocs.unep.org blocked automated requests"},{"claim":"The same study separates restricted substance list (RSL) compliance from content disclosure: under an RSL programme the 'negative content' information (what is not in the product) 'does not accompany the product itself', whereas ecolabels attached to the finished article do carry it. A 'PFAS-free' statement is negative-content information in this sense.","claimType":"reported-practice","conditions":null,"confidence":"high","contrary":null,"decisionSupported":"Whether the product meets a restriction or claim","documentRef":"CiP textile case study, summary","exemptions":null,"fields":["chemical","record"],"handovers":["h3","h4"],"id":"GFC-14","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"The last sentence of the claim is Foresight's application of the study's distinction. Negative-content information does not identify the finish chemistry that is present.","materialStatus":"article","note":null,"passage":"It is notable that under an RSL program the information on what chemicals are not in the product – that is the product’s “negative content” information – does not accompany the product itself, but is often made available through other channels (e.g. the company’s web site). [...] As ecolabels are generally attached to the finished article, the negative-content information does accompany the product.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Summary (PDF page 6)","recipient":"Consumer and downstream actors","sender":"Brand running an RSL programme, or ecolabel owner","sourceDate":"2011-01","sourceId":"src-4c7026d2","threshold":null,"timing":null,"verificationMethod":"Fetched archived copy of official UNEP PDF (Wayback capture 20241209025509)"},{"claim":"UNEP's 2015 CiP guidance says information passed within supply chains should cover selected chemicals above a reporting threshold, include hazards and safe handling instructions where required, and 'should be supplied in the appropriate language for the recipients.'","claimType":"voluntary-standard","conditions":"Selected chemicals (for example regulated chemicals) present above a reporting threshold","confidence":"high","contrary":null,"decisionSupported":"Safe handling and chemicals management","documentRef":"CiP guidance, paragraph 24","exemptions":null,"fields":["chemical","handling"],"handovers":["h1","h2"],"id":"GFC-15","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"Voluntary guidance under the predecessor of the GFC. It does not show that any supplier does this.","materialStatus":"mixture","note":null,"passage":"24. The information exchange would be for selected chemicals (for example, regulated chemicals) that are present above a reporting threshold. The information should also include identification of the hazards and safe handling instructions, if required. This information should be supplied in the appropriate language for the recipients.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Paragraph 24 (PDF page 9)","recipient":"Next actor in the supply chain","sender":"Chemical supplier or upstream supplier","sourceDate":"2015-10","sourceId":"src-3733e0c0","threshold":"'present above a reporting threshold' (threshold not specified)","timing":null,"verificationMethod":"Fetched archived copy of official UNEP PDF (Wayback capture 20220119113452); live wedocs.unep.org blocked automated requests"},{"claim":"The CiP guidance states the structural break at H5 directly: 'Recyclers are outside the business-to-business information exchange because their connection to the data is interrupted by consumers.' It lists what waste managers need: hazardous chemicals and their location, how to prevent exposure, and product composition so materials can be sorted and processed.","claimType":"voluntary-standard","conditions":null,"confidence":"high","contrary":null,"decisionSupported":"Safe handling, sorting and choice of treatment or recycling route","documentRef":"CiP guidance, paragraph 26 and table 4","exemptions":null,"fields":["component","chemical","handling"],"handovers":["h4","h5","h6"],"id":"GFC-16","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"States a need, not what sorters in France actually receive (R4).","materialStatus":"waste","note":null,"passage":"26. Recyclers are outside the business-to-business information exchange because their connection to the data is interrupted by consumers. Therefore, recyclers and manufacturers using recycled material will need to work with relevant stakeholders to access sufficient information. [...] Waste managers need information for safe handling, relevant to the treatment method, which may include listing the hazardous chemicals in a product and their location, and describing how to prevent exposures. They may also need information on product composition so that materials can be properly sorted and processed, including information on the base material and additives.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Paragraph 26 (PDF page 9); table 4, 'Waste management actors' row (PDF page 14)","recipient":"Collectors, sorters, recyclers and waste managers","sender":null,"sourceDate":"2015-10","sourceId":"src-3733e0c0","threshold":null,"timing":null,"verificationMethod":"Fetched archived copy of official UNEP PDF (Wayback capture 20220119113452)"},{"claim":"The CiP guidance defines relevant information by the recipient's decision ('the information that the recipient needs to take an informed purchase or chemicals-management decision or action') and requires it to be 'accessible, clear and understandable'. For disclosure outside the supply chain it asks for attention to language and technical background and says the date the information was produced 'would also be useful to provide'.","claimType":"voluntary-standard","conditions":null,"confidence":"high","contrary":null,"decisionSupported":"Purchase, use, handling and end-of-life decisions","documentRef":"CiP guidance, paragraph 33 and table 3","exemptions":null,"fields":["record","handling"],"handovers":["h4","h5","h6"],"id":"GFC-17","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"Supports the piece's 'decision usefulness' dimension as a criterion. It does not test any real disclosure against it.","materialStatus":"article","note":null,"passage":"33. For the purposes of the Chemicals in Products Programme, “relevant information” is defined broadly as “the information that the recipient needs to take an informed purchase or chemicals-management decision or action”. For information to be relevant it must be pertinent (the recipient can use the information to inform actions) and it must be in a usable format (i.e. it must be accessible, clear and understandable). [...] Particular attention should be given to the language and terms used in such disclosures, especially in circumstances in which a technical background may be absent or limited and language barriers may inhibit effective communication. The date that the disclosed information was produced would also be useful to provide.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Paragraph 33 (PDF page 10); table 3, comments on objective 2 (PDF page 13)","recipient":"Stakeholders outside the supply chain (consumers, waste managers)","sender":null,"sourceDate":"2015-10","sourceId":"src-3733e0c0","threshold":null,"timing":null,"verificationMethod":"Fetched archived copy of official UNEP PDF (Wayback capture 20220119113452)"},{"claim":"UNEP's 2020 global stocktake of the textile value chain says large-scale textile recycling is 'hampered by a lack of traceability, insufficient or absent fibre labelling legislation and mixed materials', and will stay at low levels unless recyclers 'can be confident regarding the source, composition and chemical content of their feedstock'.","claimType":"reported-practice","conditions":null,"confidence":"medium","contrary":null,"decisionSupported":"Whether a feedstock can be accepted for recycling","documentRef":"Global Stocktaking, section on end-of-life and recycling","exemptions":null,"fields":["component","chemical"],"handovers":["h5","h6"],"id":"GFC-18","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"A global synthesis citing secondary research (Roos et al., 2019), not a French sorting study. The page number is read from the text layer and should be checked against the PDF before print.","materialStatus":"waste","note":null,"passage":"High-value recycling opportunities thus remain unattainable because of the need for expensive technologies to remove toxics. To be viable, large-scale textile recycling facilities require consistent feedstock material, and this is currently hampered by a lack of traceability, insufficient or absent fibre labelling legislation and mixed materials (with many fabrics and yarns being blends of natural and synthetic fibres, and the latter blends of different polymers) (Roos et al., 2019). Textile recycling will thus remain at its current low levels unless actions are taken to ensure recyclers can be confident regarding the source, composition and chemical content of their feedstock.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Printed page 59 (right-hand column)","recipient":"Recyclers","sender":null,"sourceDate":"2020","sourceId":"src-97eb435e","threshold":null,"timing":null,"verificationMethod":"Fetched archived copy of official UNEP PDF (Wayback capture 20210627030316); passage read from the PDF text layer, two-column layout"},{"claim":"UN General Assembly resolution 92(I) of 7 December 1946 recommends that member states prevent use of the United Nations name, emblem and initials without the Secretary-General's authorisation, 'in particular for commercial purposes by means of trade marks or commercial labels'. Foresight is a commercial company, so the piece should carry no UN, UNEP or GFC logo and no wording that implies endorsement.","claimType":"legal","conditions":"A recommendation to member states; effect depends on national implementing law.","confidence":"medium","contrary":null,"decisionSupported":null,"documentRef":"A/RES/92(I), paragraph 2(a)","exemptions":"Use authorised by the Secretary-General","fields":[],"handovers":[],"id":"GFC-19","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"unresolved","limitations":"Covers the UN name and emblem, not the GFC by name. No GFC-specific logo or name-use policy was found. The UN Procurement Division restates the restriction for vendors in its bulletin 'Use of the UN Name and Emblem' (2 July 2012). Factual reference to the GFC and IC1 in text is a separate question; this source does not address it.","materialStatus":"n/a","note":null,"passage":"2. Considers that it is necessary to protect the name of the Organization and its distinctive emblem and official seal; Recommends therefore: (a) That Members of the United Nations should take such legislative or other appropriate measures as are necessary to prevent the use, without authorization by the Secretary-General of the United Nations, and in particular for commercial purposes by means of trade marks or commercial labels, of the emblem, the official seal and the name of the United Nations, and of abbreviations of that name through the use of its initial letters;","passageLanguage":"en","passageTranslation":null,"pinpoint":"Paragraph 2(a)","recipient":null,"sender":null,"sourceDate":"1946-12-07","sourceId":"src-c6c1a9bd","threshold":null,"timing":null,"verificationMethod":"Fetched official scanned PDF via the UN Official Document System (documents.un.org); English text corrected for OCR errors in the 1946 scan"},{"claim":"UNECE Recommendation No. 46, from the UN Centre for Trade Facilitation and Electronic Business (UN/CEFACT), recommends that governments support 'harmonized collection and transmission of data for tracking and tracing materials, products, and processes across an entire value chain' in garments and footwear. It was agreed at UN/CEFACT's twenty-seventh session in April 2021 and is a recommendation to governments, not a duty on companies.","claimType":"voluntary-standard","conditions":"Addressed to governments","confidence":"high","contrary":null,"decisionSupported":"Risk-informed decisions and accountability for sustainability claims","documentRef":"ECE/TRADE/C/CEFACT/2021/10, summary and paragraph 28","exemptions":null,"fields":["component","chemical","record"],"handovers":["h1","h2","h3","h4","h5","h6"],"id":"GFC-20","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"The document is the pre-session text dated 8 February 2021; approval is recorded in the session report (ECE/TRADE/C/CEFACT/2021/2), checked earlier in this research. The supporting business requirement specifications on unece.org could not be fetched. Hazardous chemicals appear in the guidelines only as one sustainability topic, not as a defined data field.","materialStatus":"article","note":null,"passage":"It does so by providing industry actors with a set of internationally agreed practices for the harmonized collection and transmission of data for tracking and tracing materials, products, and processes across an entire value chain, including all involved facilities and intermediaries, and includes related information about the sustainability performance of these value chain participants. [...] 28. The United Nations Centre for Trade Facilitation and Electronic Business (UN/CEFACT) of the United Nations Economic Commission for Europe (UNECE), at its twenty-seventh session, agreed to recommend that governments take the actions listed under the areas shown below.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Summary; paragraph 28","recipient":"Governments, industry partners, consumers and other stakeholders","sender":"Value-chain actors","sourceDate":"2021-02-08","sourceId":"src-dda75e16","threshold":null,"timing":"Twenty-seventh session, Geneva, 19 to 20 April 2021","verificationMethod":"Fetched official PDF via the UN Official Document System (documents.un.org); unece.org blocked automated requests"},{"claim":"Recommendation No. 46 identifies the post-consumer stage as the hardest: closing the circle after sale is 'particularly challenging' because of missing collection infrastructure, 'missing or inaccurate information about the composition of goods' and technical barriers to post-consumer traceability.","claimType":"reported-practice","conditions":null,"confidence":"high","contrary":null,"decisionSupported":null,"documentRef":"ECE/TRADE/C/CEFACT/2021/10, paragraph 23","exemptions":null,"fields":["component","chemical"],"handovers":["h4","h5","h6"],"id":"GFC-21","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":null,"limitations":"A general statement from 2021, not a measurement of French sorting.","materialStatus":"waste","note":null,"passage":"23. Closing the circle after sale to the consumer to achieve circular economy goals is particularly challenging. This is due to a current lack of infrastructure for collecting and processing post-consumer textiles and leather; missing or inaccurate information about the composition of goods; limited life-cycle analysis information; and technical barriers to creating post-consumer traceability for enough products, in large enough volumes, to make traceability useful.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Paragraph 23 (section E, Challenges)","recipient":"Collectors, sorters and recyclers","sender":null,"sourceDate":"2021-02-08","sourceId":"src-dda75e16","threshold":null,"timing":null,"verificationMethod":"Fetched official PDF via the UN Official Document System (documents.un.org)"},{"claim":"Recommendation No. 46 asks governments to define 'the minimum data that need to be collected in order to show due diligence and transparency in support of claims regarding the origin, composition and other characteristics' of products. A 'PFAS-free' or 'fluorine-free' finish claim is one such composition claim, and no minimum data set for it is defined in the recommendation.","claimType":"voluntary-standard","conditions":"Addressed to governments","confidence":"high","contrary":null,"decisionSupported":"Whether a composition claim is supported","documentRef":"ECE/TRADE/C/CEFACT/2021/10, paragraph 28(b) and (d)","exemptions":null,"fields":["chemical","record"],"handovers":["h2","h3","h4"],"id":"GFC-22","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"Whether the UN/CEFACT business requirement specifications define chemical composition fields could not be checked; unece.org was not reachable. The application to PFAS claims is Foresight's.","materialStatus":"article","note":null,"passage":"(b) Define minimum levels of traceability across garment and footwear value chains (from raw materials sourcing to consumption and post-consumption activities) and the minimum data that need to be collected in order to show due diligence and transparency in support of claims regarding the origin, composition and other characteristics, including the sustainability performance of products, processes and facilities. [...] (d) Reduce the implementation burden on businesses and support SMEs by promoting the use of international standards, such as the UN/CEFACT standards for traceability and transparency of sustainable value chains in garment and footwear","passageLanguage":"en","passageTranslation":null,"pinpoint":"Paragraph 28(b) and (d)","recipient":"Buyer, authority or consumer relying on the claim","sender":"Supplier or brand making a claim","sourceDate":"2021-02-08","sourceId":"src-dda75e16","threshold":null,"timing":null,"verificationMethod":"Fetched official PDF via the UN Official Document System (documents.un.org)"},{"claim":"UN/CEFACT records the capability barriers for smaller actors: traceability technologies 'may be difficult due to geographical and language barriers as well as costs', and the most important impediments are 'often cost and access, followed by language and a lack of available training'. Its guidelines say tool design should consider 'the language of users'.","claimType":"reported-practice","conditions":null,"confidence":"high","contrary":null,"decisionSupported":null,"documentRef":"ECE/TRADE/C/CEFACT/2021/10, paragraphs 26, 140 and 141","exemptions":null,"fields":["record"],"handovers":["h1","h2"],"id":"GFC-23","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"General to the garment sector; not specific to Vietnam or to chemical data.","materialStatus":"n/a","note":null,"passage":"Technologies such as blockchain and distributed ledger technologies, bar codes and RFID tags offer an opportunity, but mastering these technologies may be difficult due to geographical and language barriers as well as costs, available infrastructure, and environmental impacts. [...] 140. From the outset, it is critical to consider several potential impediments to the use of technology, keeping in mind that the most important are often cost and access, followed by language and a lack of available training. 141. Some actions that can, at least partially, address these concerns include making available low-cost devices and user-friendly data collection tools to ensure that smaller actors (at the farm and factory levels) in producing countries can provide the required information. To have efficient and effective tools, their design should take into consideration the language of users, communication channels and the provision of content.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Paragraphs 26, 140 and 141","recipient":"Traceability systems and downstream buyers","sender":"Farm- and factory-level actors in producing countries","sourceDate":"2021-02-08","sourceId":"src-dda75e16","threshold":null,"timing":null,"verificationMethod":"Fetched official PDF via the UN Official Document System (documents.un.org)"},{"claim":"Electronics shows a mature model: IEC 62474 sets the procedure, content and form of material declarations passed from suppliers to downstream manufacturers, in two types (declaration for compliance and composition declaration). It excludes process chemicals, so even a mature product declaration describes what is in the product, not what was used to make it.","claimType":"voluntary-standard","conditions":"Electrotechnical products only","confidence":"medium","contrary":null,"decisionSupported":"Assessing products against substance restriction compliance requirements","documentRef":"IEC 62474:2018+AMD1:2020, edition 2.1 (publisher's abstract)","exemptions":"Process chemicals and emissions during product use are out of scope","fields":["component","chemical","result"],"handovers":["h2","h3"],"id":"GFC-24","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"An electronics analogue; no textile use was established. The claim rests on the publisher's abstract, not the standard's text.","materialStatus":"article","note":null,"passage":"IEC 62474:2018+A1:2020 specifies the procedure, content, and form relating to material declarations for products of companies operating in and supplying the electrotechnical industry. Process chemicals and emissions during product use are not in the scope of this International Standard. It provides data to downstream manufacturers that: - allows them to assess products against substance restriction compliance requirements; [...] Two types of material declarations, declaration for compliance and composition declaration, and their requirements are defined.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Publisher's abstract on the IEC webstore page","recipient":"Downstream manufacturers","sender":"Suppliers in the electrotechnical industry","sourceDate":"2020-12-07","sourceId":"src-5b06fb3e","threshold":null,"timing":null,"verificationMethod":"Fetched official IEC webstore page; full standard is paywalled and was not read; the IEC 62474 database site (std.iec.ch) blocked automated requests"},{"claim":"The IPC-175x family from IPC, the electronics industry association, 'establishes a standard reporting format for data exchange between supply chain participants'. IPC-1752A, named in the brief, has been followed by IPC-1752B (July 2020), built to match the EU SCIP database for Substances of Concern In articles as such or in complex objects (Products), and by IPC-1752C (June 2026), the current version.","claimType":"voluntary-standard","conditions":null,"confidence":"high","contrary":"IPC says IPC-1752B is 'applicable to products across all industry sectors', so the format is not confined to electronics.","decisionSupported":"Collecting supply-chain data for compliance reporting, including SCIP notifications","documentRef":"IPC-1752A, IPC-1752B, IPC-1752C","exemptions":null,"fields":["component","chemical","result"],"handovers":["h2","h3"],"id":"GFC-25","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"The page itself is undated; sourceDate is the latest version date it gives. The page describes the format, not uptake in textiles.","materialStatus":"article","note":null,"passage":"The IPC-175x family of standards establishes a standard reporting format for data exchange between supply chain participants. [...] Current Version: 1752C (June 2026) [...] To help companies collect the necessary SCIP information from their supply chains, on 1 July 2020 IPC published the new IPC-1752B supply chain data exchange standard. The IPC-1752B materials declaration standard is applicable to products across all industry sectors and helps companies who want to collect data from their supply chains in a format matching the data requirements of the SCIP database.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Page introduction; IPC-1752C and IPC-1752B sections","recipient":"Customers in the supply chain","sender":"Suppliers","sourceDate":"2026-06","sourceId":"src-0b13cdc6","threshold":null,"timing":"IPC-1752B published 1 July 2020; IPC-1752C current version June 2026","verificationMethod":"Fetched official IPC web page; standard texts not read"},{"claim":"Where an EU Ecodesign for Sustainable Products Regulation (ESPR) delegated act sets information requirements on substances of concern, they must make those substances trackable through the life cycle and include at least: the substance name or code, its location in the product, its concentration (or maximum or range) at product, component or spare-part level, instructions for safe use, and end-of-life information. That covers four of this piece's five fields; the list does not include the type or date of the underlying evidence.","claimType":"legal","conditions":"Applies only once a delegated act for the product group sets information requirements under Article 7. Substance of concern includes, under Article 2(27)(d), a substance that 'negatively affects the reuse and recycling of materials in the product in which it is present'.","confidence":"high","contrary":null,"decisionSupported":"Safe use, reuse, recycling and end-of-life management","documentRef":"Regulation (EU) 2024/1781, Article 7(5) and 7(6)(b); Article 2(27)","exemptions":"Article 7(6)(b): 'duly justified exemptions' based on technical feasibility or relevance of tracking, existence of analytical methods, 'the need to protect confidential business information or in other duly justified cases'","fields":["chemical","component","result","handling"],"handovers":["h3","h4","h5","h6"],"id":"GFC-26","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"future","limitations":"Not yet a duty for textiles. Which PFAS, if any, would count as substances of concern depends on Article 2(27) criteria and the delegated act. A legal duty to provide information does not prove that it reaches the recipient.","materialStatus":"article","note":null,"passage":"5. Unless otherwise provided for under paragraph 6, point (b), the information requirements shall make it possible to track the substances of concern, throughout the life cycle of the products concerned, unless such tracking is already possible pursuant to information requirements laid down in another delegated act adopted pursuant to Article 4 covering the products concerned, and shall include at least the following: (a) the name or numerical code of the substances of concern present in the product [...] (b) the location of the substances of concern within the product; (c) the concentration, maximum concentration or concentration range of the substances of concern, at the level of the product, its relevant components, or spare parts; (d) relevant instructions for the safe use of the product; (e) information relevant for disassembly, preparation for reuse, reuse, recycling and the environmentally sound management of the product at end-of-life.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 7(5)(a) to (e); Article 7(6)(b); Article 2(27)","recipient":"Actors along the value chain, including customers and recyclers","sender":"Manufacturer or other economic operator placing the product on the EU market","sourceDate":"2024-06-13","sourceId":"src-a7d681a5","threshold":"The Commission may set thresholds per product group. Article 7(6)(b): substances under Article 2(27)(a) 'shall not be exempted if they are present in products, their relevant components or spare parts in a concentration above 0,1 % weight by weight'.","timing":"Dates of application set in each delegated act. No textile delegated act was found at the snapshot (see GFC-29; R1 holds the legal detail).","verificationMethod":"Fetched official Official Journal text through the EU Publications Office Cellar endpoint (EUR-Lex web pages returned a bot challenge); consolidated amendments not checked"},{"claim":"ESPR requires substances-of-concern information to be 'given either on the product or be accessible through a data carrier included on the product', in a language easily understood by customers as decided by the member state. For a jacket that points to the label or a carrier attached to it, but the regulation does not by itself ensure that a consumer or sorter can interpret a chemical name.","claimType":"legal","conditions":"Only where a delegated act sets substances-of-concern information requirements","confidence":"high","contrary":null,"decisionSupported":null,"documentRef":"Regulation (EU) 2024/1781, Article 7(7) and 7(8)","exemptions":null,"fields":["chemical","handling"],"handovers":["h4","h5","h6"],"id":"GFC-27","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"future","limitations":"The second sentence of the claim is Foresight's reading. Whether a data carrier survives wear and laundering to H5 is a technical question this source does not answer (R4).","materialStatus":"article","note":null,"passage":"Information that makes it possible to track substances of concern pursuant to paragraph 5 shall be given either on the product or be accessible through a data carrier included on the product. 8. The information to be supplied pursuant to information requirements shall be provided in a language which can be easily understood by customers, as determined by the Member State on whose market the product is to be made available or in which it is to be put into service.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 7(7), second subparagraph; Article 7(8)","recipient":"Customer, and anyone later holding the product","sender":"Economic operator placing the product on the EU market","sourceDate":"2024-06-13","sourceId":"src-a7d681a5","threshold":null,"timing":"Set in each delegated act","verificationMethod":"Fetched official Official Journal text through the EU Publications Office Cellar endpoint"},{"claim":"ESPR lists who should have free, easy access to the digital product passport (DPP), including recyclers, professional repairers, refurbishers, trade unions, civil society organisations and authorities, 'based on their respective access rights set out in the applicable delegated act'. Which actor sees which data is left to each product-group delegated act.","claimType":"legal","conditions":"Access tiers are defined per product group under Article 9(2)(f) and Article 10(1)(g)","confidence":"high","contrary":null,"decisionSupported":null,"documentRef":"Regulation (EU) 2024/1781, Articles 9(2)(f), 9(3)(a) and 11(b)","exemptions":null,"fields":["chemical","result","handling"],"handovers":["h4","h5","h6"],"id":"GFC-28","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"future","limitations":"Collectors and sorters are not named separately; they fall under 'recyclers' or 'other relevant actors' only if the delegated act says so. The list does not include workers at Vietnamese mills except through 'trade unions'.","materialStatus":"article","note":null,"passage":"the actors that are to have access to data in the digital product passport and to what data they are to have access; [...] (a) ensure that actors along the value chain can easily access and understand product information relevant to them; [...] (b) customers, manufacturers, importers, distributors, dealers, professional repairers, independent operators, refurbishers, remanufacturers, recyclers, market surveillance authorities and customs authorities, civil society organisations, trade unions and other relevant actors shall have free of charge and easy access to the digital product passport based on their respective access rights set out in the applicable delegated act adopted pursuant to Article 4;","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 9(2)(f); Article 9(3)(a); Article 11(b)","recipient":"Customers, repairers, refurbishers, recyclers, authorities, civil society organisations, trade unions and other relevant actors","sender":"Economic operator responsible for the DPP","sourceDate":"2024-06-13","sourceId":"src-a7d681a5","threshold":null,"timing":"Set in each delegated act","verificationMethod":"Fetched official Official Journal text through the EU Publications Office Cellar endpoint"},{"claim":"The Commission's first ESPR working plan (16 April 2025) ranks textiles and apparel first among new product groups, with 2027 as the indicative timeline for adoption, and says information requirements 'will work in synergy with the Textile Labelling Regulation, currently under review'. At the snapshot a textile DPP is planned, not in force.","claimType":"proposal","conditions":"Depends on adoption and content of a textile delegated act","confidence":"medium","contrary":null,"decisionSupported":null,"documentRef":"COM(2025) 187 final, section 2.2.1","exemptions":null,"fields":["component","chemical"],"handovers":["h3","h4","h5","h6"],"id":"GFC-29","jurisdiction":"EU","lastVerified":"2026-10-23","legalStatus":"unresolved","limitations":"The working plan is indicative. That no textile delegated act had been adopted by 23 October 2026 rests on the absence of one in sources checked, not on an official status page; R1 should confirm.","materialStatus":"article","note":null,"passage":"Information requirements under the ESPR will work in synergy with the Textile Labelling Regulation, currently under review.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Section 2.2.1, table of new products, row 'Textiles/Apparel' (JRC ranking 1st; indicative timeline for adoption 2027)","recipient":null,"sender":null,"sourceDate":"2025-04-16","sourceId":"src-d1181e6b","threshold":null,"timing":"Indicative adoption 2027","verificationMethod":"Fetched official text through the EU Publications Office Cellar endpoint"},{"claim":"OEKO-TEX ECO PASSPORT lets producers of textile chemicals prove their products 'can be used in an ecologically sustainable production'. The supplier discloses the formulation to OEKO-TEX or its testing institute, which holds it 'strictly confidential' and never passes it to third parties, so the finishing mill at H1 receives a certificate, not the formulation.","claimType":"voluntary-standard","conditions":"Voluntary certification; first three verification stages obligatory for a certificate","confidence":"high","contrary":null,"decisionSupported":"Whether to buy and use a certified chemical product","documentRef":"ECO PASSPORT Standard, sections 3.1 and 4.3.1","exemptions":null,"fields":["chemical","record"],"handovers":["h1"],"id":"GFC-30","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"A certificate attests screening and testing against OEKO-TEX criteria; it does not give the mill the substance identity. Where a certificate is issued with restrictions, the exceeding parameters are listed on the certificate and 'must be checked on the treated fabric' (section 4.7.1), so some parameter-level information does reach the mill. This claim does not assess the standard's limits for perfluorinated substances (R2 covers them). OEKO-TEX's web page says certified products can be listed in the OEKO-TEX Buying Guide and on the ZDHC Gateway, and certificates run for one year.","materialStatus":"mixture","note":null,"passage":"ECO PASSPORT is a system by which producers and suppliers of textile and leather chemicals, colourants and auxiliary agents can prove that their products can be used in an ecologically sustainable production. [...] The ECO PASSPORT trademark is not a quality label. [...] The client can disclose the composition of their products in the certification application to varying degrees to OEKO‑TEX® or the relevant testing institute. The details given here are handled strictly confidential and are not given to third parties under any circumstances. They are only intended for the implementation of the CAS number Screening and the optimisation of the Analytical Verification.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Section 3.1 (PDF page 4); section 4.3.1 (PDF page 7)","recipient":"OEKO-TEX or testing institute (formulation); finishing mill (certificate)","sender":"Chemical supplier (to OEKO-TEX); OEKO-TEX (certificate, to market)","sourceDate":"2026-08-21","sourceId":"src-33740c8a","threshold":null,"timing":null,"verificationMethod":"Fetched official OEKO-TEX PDF"},{"claim":"The ZDHC Gateway's Chemical Module calls itself 'the world’s first verified database of safer chemistry for the apparel and footwear industry'. It generates a ChemCheck Report, 'an individual product passport', for chemical products conformant with the ZDHC Manufacturing Restricted Substances List (MRSL), and InCheck reports show the MRSL conformance of a facility's chemical inventory.","claimType":"voluntary-standard","conditions":"Participation in ZDHC programmes","confidence":"high","contrary":null,"decisionSupported":"Whether a chemical product or facility inventory conforms to the ZDHC MRSL","documentRef":"ZDHC Gateway home page, Modules and CheckTools sections","exemptions":null,"fields":["chemical","record"],"handovers":["h1","h2"],"id":"GFC-31","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"MRSL conformance is negative-content information about a chemical product used in manufacture. It does not travel with the fabric roll and does not state what remains in the finished jacket. Who can view which report was not established from the public page.","materialStatus":"mixture","note":null,"passage":"Chemical Module The world’s first verified database of safer chemistry for the apparel and footwear industry. [...] ZDHC Performance InCheck is an easy-to-read performance report that demonstrates the ZDHC MRSL conformance of a facility’s chemical inventory. ChemCheck ZDHC ChemCheck Report is an individual product passport, which can be generated for published ZDHC MRSL conformant products on the ZDHC Gateway.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Home page, 'Modules' and 'CheckTools' sections","recipient":"Facilities and brands using the Gateway","sender":"Chemical supplier (product listing); facility (inventory)","sourceDate":null,"sourceId":"src-c498baa5","threshold":null,"timing":null,"verificationMethod":"Fetched official ZDHC Gateway web page (undated)"},{"claim":"ILO Chemicals Convention No. 170 (1990) requires hazardous chemicals to be labelled 'in a way easily understandable to the workers' and safety data sheets with identity, hazards, precautions and emergency procedures to be provided to employers. It does not apply to articles that will not expose workers under normal or reasonably foreseeable use, so it reaches the mixture at H1 but generally not the fabric roll at H2.","claimType":"legal","conditions":"Binding only on states that ratify it; neither Viet Nam nor France has (GFC-34). Domestic law sets the actual duty (R1, R2).","confidence":"high","contrary":null,"decisionSupported":"How to handle the finishing agent safely","documentRef":"ILO Convention No. 170, Articles 1(3), 7(2) and 8(1)","exemptions":"Article 1(3): articles which will not expose workers to a hazardous chemical under normal or reasonably foreseeable conditions of use","fields":["chemical","handling"],"handovers":["h1","h2"],"id":"GFC-32","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"unresolved","limitations":"Whether a DWR-finished fabric could expose workers at the garment factory is a technical question (R3); the Convention's article exclusion is conditional, not absolute.","materialStatus":"mixture","note":null,"passage":"3. This Convention does not apply to articles which will not expose workers to a hazardous chemical under normal or reasonably foreseeable conditions of use. [...] 2. Hazardous chemicals shall in addition be labelled, in a way easily understandable to the workers, so as to provide essential information regarding their classification, the hazards they present and the safety precautions to be observed. [...] 1. For hazardous chemicals, chemical safety data sheets containing detailed essential information regarding their identity, supplier, classification, hazards, safety precautions and emergency procedures shall be provided to employers.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 1(3); Article 7(2); Article 8(1)","recipient":"Employer (finishing mill) and its workers","sender":"Chemical supplier","sourceDate":"1990-06-25","sourceId":"src-688107a0","threshold":null,"timing":"Adopted 25 June 1990; in force 4 November 1993","verificationMethod":"Fetched archived copy of official ILO NORMLEX page (Wayback capture 20260220224343); live normlex.ilo.org blocked automated requests"},{"claim":"Under Convention No. 170, workers and their representatives have the right to information on the identity of chemicals used at work, their hazards and precautions, label information and safety data sheets, and employers must instruct workers how to obtain and use that information. An employer may protect a mixture ingredient's specific identity from competitors in a manner approved by the competent authority.","claimType":"legal","conditions":"Binding only on ratifying states (GFC-34)","confidence":"high","contrary":null,"decisionSupported":"How to work safely with the finishing agent","documentRef":"ILO Convention No. 170, Articles 10(1), 15(b) and 18(3) to (4)","exemptions":"Article 18(4): specific identity of an ingredient may be protected where disclosure to a competitor would harm the employer's business","fields":["chemical","handling"],"handovers":["h1"],"id":"GFC-33","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"unresolved","limitations":"Sets rights for ratifying states. It does not show what any Vietnamese mill worker receives.","materialStatus":"mixture","note":null,"passage":"1. Employers shall ensure that all chemicals used at work are labelled or marked as required by Article 7 and that chemical safety data sheets have been provided as required by Article 8 and are made available to workers and their representatives. [...] (b) instruct the workers how to obtain and use the information provided on labels and chemical safety data sheets; [...] 3. Workers concerned and their representatives shall have the right to: (a) information on the identity of chemicals used at work, the hazardous properties of such chemicals, precautionary measures, education and training; (b) the information contained in labels and markings; (c) chemical safety data sheets; (d) any other information required to be kept by this Convention. 4. Where disclosure of the specific identity of an ingredient of a chemical mixture to a competitor would be liable to cause harm to the employer's business, the employer may, in providing the information required under paragraph 3 above, protect that identity in a manner approved by the competent authority under Article 1, paragraph 2 (b).","passageLanguage":"en","passageTranslation":null,"pinpoint":"Article 10(1); Article 15(b); Article 18(3) and (4)","recipient":"Workers and their representatives","sender":"Employer (finishing mill)","sourceDate":"1990-06-25","sourceId":"src-688107a0","threshold":null,"timing":null,"verificationMethod":"Fetched archived copy of official ILO NORMLEX page (Wayback capture 20260220224343)"},{"claim":"Convention No. 170 has 24 ratifications. Neither Viet Nam nor France is among them; China ratified in 1995. The GFC's proposed indicator D7.1 would count ratifications of up-to-date ILO conventions on chemical risks.","claimType":"legal","conditions":null,"confidence":"medium","contrary":null,"decisionSupported":null,"documentRef":"NORMLEX ratification list for C170; cross-checked against UNEP/GFC/IC.1/3, Target D7 row","exemptions":null,"fields":["handling"],"handovers":["h1"],"id":"GFC-34","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"unresolved","limitations":"Absence from a list cannot be quoted; it is read from the full table. The list is from May 2025; the August 2026 count of 24 matches it, but a live NORMLEX check is advisable before print. Non-ratification does not mean Vietnamese or French law lacks equivalent duties (R1, R2).","materialStatus":"n/a","note":null,"passage":"Date of entry into force: 04 Nov 1993 24 ratifications Denounced: 0 [...] China 11 Jan 1995 In Force","passageLanguage":"en","passageTranslation":null,"pinpoint":"Ratification table (full list: Belgium, Brazil, Burkina Faso, China, Colombia, Cyprus, Côte d'Ivoire, Dominican Republic, Finland, Germany, Italy, Lebanon, Luxembourg, Mexico, Netherlands, Norway, Poland, Republic of Korea, Sweden, Switzerland, Syrian Arab Republic, Ukraine, United Republic of Tanzania, Zimbabwe)","recipient":null,"sender":null,"sourceDate":"2025-05-19","sourceId":"src-1c1735a2","threshold":null,"timing":"In force 4 November 1993","verificationMethod":"Fetched archived copy of official ILO NORMLEX page (Wayback capture 20250519020643); live page blocked automated requests. Count confirmed by UNEP/GFC/IC.1/3 (26 August 2026): '24 countries have ratified the ILO Chemicals Convention, 1990 (No. 170)'"},{"claim":"ILO Recommendation No. 177 says workers should receive information on classification, labelling and safety data sheets 'in forms and languages which they easily understand', plus workplace-specific instruction and training. It is the clearest international statement that worker access depends on language and training, not only on a document existing.","claimType":"legal","conditions":"A recommendation; not open to ratification and not binding","confidence":"high","contrary":null,"decisionSupported":"How to work safely with the finishing agent","documentRef":"ILO Recommendation No. 177, paragraphs 8(3) and 26","exemptions":null,"fields":["chemical","handling"],"handovers":["h1"],"id":"GFC-35","jurisdiction":"International","lastVerified":"2026-10-23","legalStatus":"voluntary","limitations":"Non-binding. Says nothing about whether Vietnamese mill workers receive information in Vietnamese; that is for R2.","materialStatus":"mixture","note":null,"passage":"(3) The label should be easily understandable by workers. [...] 26. Workers should receive: (a) information on the classification and labelling of chemicals and on chemical safety data sheets in forms and languages which they easily understand; (b) information on the risks which may arise from the use of hazardous chemicals in the course of their work; (c) instruction, written or oral, based on the chemical safety data sheet and specific to the workplace if appropriate; (d) training and, where necessary, retraining in the methods which are available for the prevention and control of, and for protection against, such risks, including correct methods of storage, transport and waste disposal as well as emergency and first-aid measures.","passageLanguage":"en","passageTranslation":null,"pinpoint":"Paragraph 8(3); paragraph 26(a) to (d)","recipient":"Workers","sender":"Employer (finishing mill)","sourceDate":"1990-06-25","sourceId":"src-8b732b2b","threshold":null,"timing":"Adopted 25 June 1990","verificationMethod":"Fetched official ILO SafeWork copy of the text (page last updated 30 November 2004); NORMLEX blocked automated requests"}],"fields":[{"id":"component","label":"Component identity","short":"Component","description":"Which part, and what it is made of."},{"id":"chemical","label":"Chemical identity or group","short":"Finish chemistry","description":"The finish's chemistry, as a named substance or a defined group."},{"id":"result","label":"Concentration or test result","short":"Test result","description":"A measured value, with its method and reporting limit."},{"id":"handling","label":"Hazard and handling","short":"Handling","description":"What a person handling it should know and do."},{"id":"record","label":"Evidence type and date","short":"Record","description":"Who issued the record, what kind it is, and when."}],"handovers":[{"cells":[{"field":"component","legal":"duty","case":"practice","access":"demonstrated","use":"supports","channel":"Drum label","note":"The label must name the product and its composition, in Vietnamese. A ZDHC QR code, where printed, adds the product ID and status.","claims":["VN-01","VN-04","VN-22"]},{"field":"chemical","legal":"unresolved","case":"practice","access":"conditional","use":"insufficient","channel":"Safety data sheet","note":"A safety data sheet must name hazardous ingredients above cut-offs. A polymer that is not classified need not appear, and confidentiality can withhold the rest, so the sheet may not show whether the finish is fluorinated.","claims":["VN-02","VN-03","TECH-13","TECH-14","TECH-16","TECH-12"]},{"field":"result","legal":"voluntary","case":"practice","access":"conditional","use":"supports","channel":"ZDHC ChemCheck report","note":"ZDHC certifiers test the formulation against PFAS limits in parts per billion. The mill receives a conformance level. It answers whether the agent meets the buyer's list, but it is not a measured value.","claims":["VN-19","VN-20","VN-21"]},{"field":"handling","legal":"duty","case":"assumption","access":"demonstrated","use":"supports","channel":"Drum label and safety data sheet","note":"We assume the drum carries the hazard label the law requires. Training is required too, and warning signs for listed substances must be in the workers' language. Public evidence cannot show whether either happens at a given mill.","claims":["VN-04","VN-08","VN-09"]},{"field":"record","legal":"voluntary","case":"practice","access":"conditional","use":"supports","channel":"Certificate or QR code","note":"A ChemCheck report gives the certification body and certificate dates. Where the supplier uses OEKO-TEX's ECO PASSPORT, the agent is certified and the formulation stays confidential.","claims":["VN-21","VN-22","GFC-30"]}],"from":"supplier","id":"h1","question":"What is in this drum, and how should our workers handle it?","title":"Chemical supplier to finishing mill","to":"mill"},{"cells":[{"field":"component","legal":"none","case":"assumption","access":"conditional","use":"supports","channel":"Fabric specification","note":"We assume the factory buys to a written specification naming the face fabric and the membrane. The finish goes on the face fabric whichever membrane is used.","claims":["TECH-03"]},{"field":"chemical","legal":"voluntary","case":"practice","access":"conditional","use":"insufficient","channel":"Treatment notice","note":"AFIRM, a group of apparel and footwear brands, asks mills to say whether a material is water-repellent and by what type of treatment. A treatment type is not a chemical identity, and “no PFAS-based finish” cannot rule out a PFAS membrane.","claims":["VN-24","VN-32","VN-15"]},{"field":"result","legal":"voluntary","case":"practice","access":"conditional","use":"insufficient","channel":"Certificate","note":"Certified fabric has passed limits of 25 ppb for each PFAS and 50 mg of total fluorine per kg. The certificate states that it passed, not what was measured.","claims":["VN-30","VN-28","VN-31"]},{"field":"handling","legal":"unresolved","case":"not-established","access":"not-demonstrated","use":"not-assessed","channel":"None found","note":"Viet Nam's general duty to inform “users” about hazardous content may reach treated fabric. We found no guidance either way.","claims":["VN-07"]},{"field":"record","legal":"voluntary","case":"practice","access":"not-demonstrated","use":"insufficient","channel":"ZDHC InCheck, to the brand","note":"The mill's InCheck report covers its whole chemical inventory each month and goes to connected brands. The factory is not a recipient, and the report does not follow a roll.","claims":["VN-26"]}],"from":"mill","id":"h2","question":"What was this fabric finished with?","title":"Finishing mill to garment factory","to":"factory"},{"cells":[{"field":"component","legal":"duty","case":"assumption","access":"demonstrated","use":"supports","channel":"Sewn-in label","note":"The fibres and percentages of each main part, worked out without the finish. The brand writes the label and the factory sews it in.","claims":["LAW-01","LAW-02","LAW-03"]},{"field":"chemical","legal":"none","case":"practice","access":"conditional","use":"insufficient","channel":"Supplier declaration","note":"REACH binds suppliers in the EU, not the factory in Viet Nam. From the importer on, it requires the name of a listed substance above 0.1% by weight, far above a finish residue that breaks the French limit. Brands rely on declarations that a substance is absent.","claims":["LAW-08","LAW-12","LAW-34","VN-34"]},{"field":"result","legal":"voluntary","case":"practice","access":"conditional","use":"insufficient","channel":"Test report or certificate","note":"In one study, total fluorine was found in 87% of water-repellent textiles whose targeted PFAS were all below 165 ppb. A clean targeted test can sit beside a high total fluorine result.","claims":["TECH-25","TECH-22","VN-33","LAW-34"]},{"field":"handling","legal":"none","case":"assumption","access":"demonstrated","use":"not-assessed","channel":"Care symbols","note":"Our label carries care symbols because brands put them there. EU law does not require them, and France is not among the states reported to.","claims":["LAW-05","LAW-06"]},{"field":"record","legal":"voluntary","case":"practice","access":"conditional","use":"supports","channel":"Certificate","note":"A certificate number lets anyone check which criteria applied, and a certificate lasts a year. In France the date of manufacture now matters too: the sell-off for older stock ends on 31 December 2026.","claims":["VN-31","LAW-24"]}],"from":"factory","id":"h3","question":"Can we sell this jacket in France?","title":"Garment factory to brand","to":"brand"},{"cells":[{"field":"component","legal":"duty","case":"assumption","access":"demonstrated","use":"supports","channel":"Sewn-in label","note":"Fibres and percentages for each main part, in French, visible before purchase.","claims":["LAW-01","LAW-02","LAW-04"]},{"field":"chemical","legal":"duty","case":"practice","access":"conditional","use":"insufficient","channel":"On request, or the product sheet","note":"A substance is named only above 0.1%, and France's list adds no PFAS. In a survey of outdoor jackets on sale in 2015 and 2016, no care label named the finish.","claims":["LAW-09","LAW-26","LAW-27","TECH-28"]},{"field":"result","legal":"none","case":"not-established","access":"not-demonstrated","use":"not-assessed","channel":"None found","note":"No rule we found gives a buyer a test result. The French ban and the EU limit are enforced on the seller.","claims":["LAW-21","LAW-16"]},{"field":"handling","legal":"duty","case":"practice","access":"conditional","use":"supports","channel":"Care symbols and product sheet","note":"Care symbols are voluntary in France. Larger producers' product sheets must say that a mostly synthetic garment releases microfibres when washed.","claims":["LAW-05","LAW-29","LAW-25"]},{"field":"record","legal":"duty","case":"assumption","access":"demonstrated","use":"insufficient","channel":"Batch number and importer","note":"The batch number and importer's address lead back to the business that holds the records. On their own, they say nothing about the finish.","claims":["LAW-35"]}],"from":"brand","id":"h4","question":"What is this jacket made of, and how should I look after it?","title":"Brand to owner","to":"owner"},{"cells":[{"field":"component","legal":"none","case":"practice","access":"demonstrated","use":"insufficient","channel":"Sewn-in label, if it survives","note":"Sorters use the label “when they are not removed or faded”. In a study of nearly 11,000 used garments, 24% had no label, and 59% of readable labels matched the fibres found.","claims":["LIFE-12","TECH-29","TECH-30","LIFE-02"]},{"field":"chemical","legal":"none","case":"practice","access":"not-demonstrated","use":"not-assessed","channel":"None found","note":"Collection rules name no substance information and leave tracking to future ecodesign acts. The re-use decision is made by eye.","claims":["LIFE-04","LIFE-21","LIFE-11"]},{"field":"result","legal":"none","case":"practice","access":"not-demonstrated","use":"not-assessed","channel":"None found","note":"Testing a used textile for PFAS is “expensive and generally not feasible”. Water repellency is visible, but it is not evidence of PFAS.","claims":["LIFE-21","TECH-09"]},{"field":"handling","legal":"future","case":"not-established","access":"not-demonstrated","use":"not-assessed","channel":"None found","note":"Once transposed, collectors must screen out items and substances that could contaminate what they collect. Nothing on the jacket says what its finish is.","claims":["LIFE-04"]},{"field":"record","legal":"duty","case":"assumption","access":"demonstrated","use":"insufficient","channel":"Batch number, if the label survives","note":"If it is on the sewn-in label, the batch number could lead back to the importer's records. We found no route by which a sorter uses it.","claims":["LAW-35","TECH-29"]}],"from":"owner","id":"h5","question":"What is this jacket, and where should it go next?","title":"Owner to collector and sorter","to":"sorter"},{"cells":[{"field":"component","legal":"future","case":"practice","access":"conditional","use":"insufficient","channel":"Bale record and label","note":"Near-infrared scanners read only the surface and “cannot detect the underlying materials” under coatings or layers. The label is cut off before mechanical recycling.","claims":["LIFE-13","LIFE-18","LIFE-15","LIFE-33"]},{"field":"chemical","legal":"duty","case":"practice","access":"conditional","use":"insufficient","channel":"SCIP database","note":"The database holds listed substances above 0.1%, so it is not a PFAS register. None of 10 recyclers interviewed used it regularly, and the Commission has proposed ending new notifications.","claims":["LIFE-23","LIFE-24","LIFE-25"]},{"field":"result","legal":"none","case":"practice","access":"not-demonstrated","use":"insufficient","channel":"None found","note":"Mechanical recycling does not destroy PFAS. A result from manufacture would be years old. In four stored jackets, one PFAS fell to a fifth of its first level or less, while perfluorooctanoic acid (PFOA) rose.","claims":["LAW-20","LIFE-22","TECH-26"]},{"field":"handling","legal":"none","case":"practice","access":"not-demonstrated","use":"not-assessed","channel":"None found","note":"Europe's recyclers' trade body says they cannot be held responsible for “unknown chemical content”. One Swedish recycler said it cannot accept deliveries whose content it cannot ensure.","claims":["LIFE-19","LIFE-20"]},{"field":"record","legal":"future","case":"practice","access":"conditional","use":"insufficient","channel":"Bale record","note":"The bale record names the sorter and has no chemical field. 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