A restricted substances list (RSL) is a list of chemical substances that are restricted or banned in finished products, with a limit and a test method for each. Brands publish RSLs to make sure the products they sell meet the chemical laws of their markets, and often to set stricter internal requirements.
Where RSL requirements come from#
- Laws and regulations in the markets where products are sold. Examples include EU REACH restrictions, US consumer product safety rules for children's products, and state-level rules in the US.
- Industry lists, such as the AFIRM RSL, which many brands use as a base.
- Brand policies that go beyond legal requirements.
Laws change, so RSLs are updated regularly. Always use the buyer's current RSL.
Common substance groups#
These groups appear on most apparel RSLs. The specific substances, limits and methods differ by list:
| Group | Where it can come from |
|---|---|
| Azo dyes that release restricted amines | Some dyes |
| Formaldehyde | Resin finishes, some binders |
| Heavy metals (such as lead, cadmium, nickel release) | Metal trims, pigments, coatings |
| Phthalates | PVC and plastisol prints, some plastic trims |
| Alkylphenols and their ethoxylates (APs, APEOs) | Some detergents, auxiliaries |
| PFAS (per- and polyfluoroalkyl substances) | Water and oil repellent finishes |
| Chlorinated solvents | Spot cleaning |
| Disperse dyes classified as allergenic | Some polyester dyes |
| Organotin compounds | Some plastics and prints |
| pH (as a product property) | Wet processing residues |
How compliance is checked#
- Risk assessment: which materials and processes could introduce which substances?
- Supplier declarations and certificates, such as OEKO-TEX certificates for materials. See OEKO-TEX.
- Product testing in accredited labs, following the buyer's test plan and methods.
- Chemical input control at mills and factories, using an MRSL. See ZDHC.
RSL risk in a garment factory#
A cut-and-sew factory can introduce RSL substances through:
- Trims: zippers, buttons, snaps, rivets (heavy metals, nickel release).
- Prints and heat transfers (phthalates, formaldehyde).
- Spot-cleaning chemicals (solvents).
- Packaging materials, where the buyer's RSL covers them.
Control measures:
- Approved trim and print suppliers, with test reports.
- Approved chemicals list for spot cleaning and maintenance.
- Testing of new materials and high-risk components before bulk.
- Records linking test reports to styles and material lots.
RSL vs MRSL#
An RSL controls what is in the product. An MRSL controls what goes into the manufacturing process. A product can pass an RSL test while the process still used hazardous chemicals that were washed out into wastewater. That is why many brands require both.
Common mistakes#
- Using an outdated RSL version.
- Testing only the main fabric and forgetting prints and trims.
- Accepting supplier test reports that do not match the material or are too old for the buyer's rules.
- No control over chemicals brought in for spot cleaning.
Related: buyer compliance audits.
Related guides#
- Global Recycled Standard (GRS): recycled content certification with its own chemical rules.
- GOTS: organic certification with chemical input restrictions.
- Fabric testing standards and methods: where chemical tests sit in a full test program.
Frequently asked questions#
Does an OEKO-TEX certificate replace RSL testing? Some buyers accept it for certain materials; others still require their own tests. Ask the buyer.
How often should trims be retested? Follow the buyer's rules on report validity and retesting frequency, and retest when a supplier, material or process changes.