New Disposition of Chemical Restrictions 2

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Transcript of New Disposition of Chemical Restrictions 2

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H&M Implementation Toolkit for H&M Chemical Restrictions – 2(21) Apparel/Accessories/Footwear/Soft Products, 8 July 2013

CONTENTS

Introduction ....................................................................................................... 3

Description and Field of Application of the Restricted Substances ...................... 4

Communication along the Supply Chain ............................................................ 13

Chemical Testing .............................................................................................. 14

Supplier Chemical Testing and Testing according to Risk Assessment .......................14

Non Compliance.................................................................................................14

How to choose Labs for Chemical Tests ................................................................14

Guide for Chemical Testing .................................................................................15

Frequently Asked Questions ............................................................................. 16

H&M Chemical Restrictions ..................................................................................16

H&M Contacts ....................................................................................................17

Testing and Test Methods ...................................................................................18

Appendix 1. Safety Data Sheet (SDS) .............................................................. 19

Appendix 2. Labelling of Chemical Products .................................................... 20

Appendix 3. Compliance Certificate ................................................................. 21

H&M Implementation Toolkit for H&M Chemical Restrictions – 3(21) Apparel/Accessories/Footwear/Soft Products, 8 July 2013

INTRODUCTION H&M Implementation Toolkit for H&M Chemical Restrictions – Apparel/Accessories/ Footwear/Soft Products should be a help for suppliers to work proactively with fulfilling H&M Chemical Restrictions, Part 3: Apparel/Accessories/Footwear/Soft Products1. It contains information about restricted substances, chemical testing, frequently asked questions, documentation and test methods. The information in this document does not claim to be complete. The suppliers have the responsibility to make sure that all products supplied to H&M group fully comply with the latest version of H&M Chemical Restrictions. This is committed by accepting H&M Standard Purchase Conditions (SPC)1. See the table below to find your local contact for any issues regarding chemistry.

Country / City E-mail

Bangladesh / Dhaka [email protected]

China / Hong Kong [email protected]

China / Shanghai apparel /soft products

[email protected]

China / Shanghai accessories / footwear

[email protected]

India / New Delhi [email protected]

India / Bangalore [email protected]

Indonesia / Jakarta [email protected]

Korea / Seoul [email protected]

Pakistan / Karachi [email protected]

Romania / Bucharest [email protected]

Turkey / Istanbul [email protected]

If you have technical questions regarding H&M Chemical Restrictions, its future development, test methods or the background for the restrictions, please contact H&M Global Quality department. See below for contact information:

Country / City E-mail / Phone

Sweden / Stockholm [email protected] Phone: + 46 8 796 55 00

1 Download the document at H&M Group Supplier Portal.

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DESCRIPTION AND FIELD OF APPLICATION OF THE RESTRICTED SUBSTANCES Below table gives information about the field of application and description of the restricted substances. This information is of use in the proactive work on how to avoid restricted substances. The table below does not claim to be complete; there might be other fields of application for a substance than mentioned.

Restricted Substances

Description and Field of Application

Alkylphenol Ethoxylates/ Alkylphenols (APEO/AP)

Alkylphenolethoxylates (APEOs) is a group of non-ionic surfactants including: Nonylphenolethoxylates (NPEs), Nonylphenol (NP), Octylphenoletoxylates (OPEs) and Octylphenol (OP). NPEs and OPEs degrade to NP and OP respectively. APEOs can be used in for example: Detergents Scouring agents Wetting agents Softeners Emulsifier/dispersing agents Impregnating agents Degreasing agents for leather Finishing De-gumming for silk production Dyes and pigment preparations

Bisphenol-A (BPA) Bisphenol A (A=acetone) (BPA) occurs in its pure form as white flakes with a faint phenol-like smell. It is used in the production of epoxy resins and polycarbonate plastics. It can be used in production of flame retardants and in PVC production and processing.

Cationic Surfactants (DSDMAC, DTDMAC, DHTDMAC)

Distearyldimethyl ammouniumchloride (DSDMAC), Ditallowdimethylammonium (DTDMAC) and Di(hydrogenated tallow)dimethylammonium chloride (DHTDMAC) belongs to the group “quarternary ammonium salts” and is used as cationic surfactants. DSDMAC, DTDMAC, DHTDMAC are used in processes/products as: Levelling agents (Retarders) for Basic (cationic) dyes, that are mostly used for acrylic fibres Fixation of Direct dyes, that are mostly used for cotton, rayon (viscose), linen, silk and polyamide Surfactants Emulsifier Antistatic agents Softeners Water repellent agents

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Restricted Substances

Description and Field of Application

Chlorinated Bleaching Agents

Chlorinated Bleaching Agents are used for bleaching textiles, and paper etc. Textiles Chlorine dioxide (ClO2), sodium hypochlorite (NaClO) and calcium hypochlorite (Ca(ClO)2). Paper Chlorine gas (Cl2) and chlorine dioxide (ClO2).

Chlorinated Aromatic Hydrocarbons

Chlorinated aromatic hydrocarbons are used as carriers in the dyeing process of polyester or wool/polyester fibres. They can also be used as solvents.

Chloroparaffins Short chained (SCCPs)

Chloroparaffins are hydrocarbons with a straight carbon chain. They can be used as flame retardants or as fat liquoring of leather.

Chloroparaffins Medium chained (MCCPs) Chromium VI (Cr6+) Chromium is used in leather tanning and can be oxidised into

Cr6+. Free CrIII from the leather tanning shall be washed away as thorough as possible. To avoid oxidation of free CrIII into CrVI, e.g. during shipment, the finished product should have a reductive capacity. This could be accomplished by using products with reducing/buffering effect. An aging test must be performed before analysing CrVI on the leather. The aging test simulates transportation.

Dimethylformamide (DMF)

Dimethylformamide is a solvent used in plastics and in rubber. It has a strong smell also in the finished product. Water based PU does not contain Dimethylformamide and is therefore preferable.

Dimethylfumarate (DMFu)

Dimethylfumarate is an anti mould agent used in sachets in packaging.

Dyes

AZO Dyes and Pigments

Azo dyes and pigments are colorants which molecular structure include a so called azo-bond, which is two nitrogen atoms with a double bond between them (N=N). Some azo dyes can split of one or more of the aromatic amines listed in H&M Chemical Restrictions through cleavage of the azo bond (N=N).

Disperse Dyes Disperse dyes are molecules that can penetrate the fibre system of polyester. It is not chemically bonded to the polyester fibre but trapped inside the fibre by physical forces.

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Restricted Substances

Description and Field of Application

Other Azo Dyes Azo dyes are colorants which molecular structure include a so called azo-bond, which is two nitrogen atoms with a double bond between them (N=N). These azo dyes are regulated as dye compounds and not as aromatic amines (that are cleavage products).

Other Dyes For dyeing textiles and other materials.

Dye related compounds These compounds could be used when dyeing or occur as an impurity in the dye stuff.

Flame Retardants Flame retardants are used to decrease the flammability of the product, by for example lowering the energy (heat) of the flame.

Formaldehyde Formaldehyde is a volatile, colourless gas that is present in small amounts in the atmosphere, tobacco smoke, glue, air pollution etc. Due to its volatility, formaldehyde is “contagious”. If you place a garment with formaldehyde on top of a garment that does not contain formaldehyde, the other garment may become “infected”. Fabric samples for testing need to be packed separately in plastic bags. Formaldehyde/ formaldehyde releasing compounds can be applied for: Dimensional stability control (i.e. Pre-shrinkage) Easy-care Crinkle treatment Fixation or preservation of dyes and prints Adhesives for flock prints Binders for pigment prints Fluorescent dyes and pigments

Isocyanates Isocyanates are used in the production of polyurethane plastics and foams. When testing PU for Isocyanates it is important to follow the standard method, since certain conditions result in false positives.

Metals

Antimony (Sb) Antimony is a half-metal element. It can be present as a pure metal, as non-metal or as Antimony compounds e.g. salts. Antimony can be used as: Catalyst in polymerisation of polyester Flame retardants Fixing agents Pigments Alloys

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Restricted Substances

Description and Field of Application

Arsenic (As) Arsenic is a half-metal element. It can be present as a pure metal, as non-metal or as Arsenic compounds e.g. salts. Arsenic and its compounds can be used in some preservatives, pesticides and defoliants for cotton.

Cadmium (Cd) Cadmium is a metal element that can be present as a pure metal or as Cadmium compounds e.g. salts. Cadmium compounds can be used in some pigments and as stabiliser for PVC plastic. Cadmium compounds have been found in fertilisers and biocides. Cadmium metal can be used in alloys and for plating of other metals. Cadmium compounds can be used in paints, e.g. surface paints on zippers and buttons.

Chromium (Cr) Chromium is a metal element that can be present as a pure metal or as Chromium compounds e.g. salts. (See also Chromium VI). Chromium compounds can be used as: Dyeing additives Dye-fixing agents After-treatments to improve colour fastness Dyes for wool, silk and polyamide (especially dark shades) Tanning of leather Most Cr containing dyes can be put in one of the following categories: Metal complex dyes

• 1:1 metal complex • 2:1 metal complex

Mordant dyes

• Metachrome • After-chrome

Textile (except polyamide, polyamide blends & worsted wool)

• Never use dyes based on, or containing Cr. Never use Cr-fixation of dyes (Mordant dyes).

Polyamide, polyamide blends and worsted wool

• Most important for dark shades • Consult your dye stuff supplier to make sure the dye is

bound strongly enough and that you’re not using more Cr than needed

There are reactive dyes and acid dyes suitable for the critical fibres. Preferred dyes depend on the colour and the fibre.

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Restricted Substances

Description and Field of Application

Cobalt (Co) Cobalt is a metal element that can be present as a pure metal or as Cobalt compounds e.g. salts. Cobalt compounds can be used as pigments and in dyestuff. Cobalt metal can be used in alloys.

Copper (Cu) Copper is a metal element that can be present as a pure metal or as Copper compounds e.g. salts. Copper compounds can be used as pigments and in dyestuff. Copper metal can be used in alloys.

Lead (Pb) Lead is a metal element that can be present as a pure metal or as Lead compounds e.g. salts. Lead compounds can be used as stabilisers for plastics. Paints and surface coatings for plastic, leather, wood and metal could contain lead compounds. Examples of coated or painted products are zippers, beads and buttons. Pigments based on lead could be used in for example plastic buttons. Lead metal is used in solder alloys and can be present in other alloys. Soldering material free or low in lead is always preferable.

Mercury (Hg) Mercury is a metal element that can be present as a pure metal or as Mercury compounds e.g. salts. Mercury compounds can be present in pesticides and can be found as contamination in caustic soda (NaOH). Mercury compounds can be used in paints, e.g. surface paints on zippers and buttons.

Nickel (Ni) Nickel is a metal element that can be present as a pure metal or as Nickel compounds e.g. salts. Nickel metal is mainly used for plating of alloys, improving the corrosion resistance in alloys, improving the hardness of alloys and is a key element in the production of stainless steel. Certain dyestuffs contain complex-bound Nickel. Both Nickel metal and Nickel compounds can occur as an impurity in pigments and alloys.

Mineral Oil Mineral oil could be used as filling liquid for any products like compasses, snow globes etc.

N-Nitrosamines N-Nitrosamines can be found in rubber.

Octamethylcyclo-tetrasiloxane

Octamethylcyclotetrasiloxane can be used in textile softeners.

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Restricted Substances

Description and Field of Application

Organotin Compounds Organotin compounds are used as / in: Stabilisers in plastic/rubber Anti-bacterial agents in textiles Anti corrosion coatings in drums containing for example dyestuff. Catalysts in plastic and glue production Metallic glitter

Perfluorinated Compounds

Perfluorinated Compounds are a variety of compounds with the common property that the hydrogen on the carbon chain has been exchanged to fluorine. They might be fully or partially fluorinated. These compounds are known to be stable, not sensitive to heat and to reject water and oily compounds. In this group of substances you find among others; PFOS, PFOA, Fluorotelomers, the compounds in the C6 and C8 fluorine technology. In production they are used as water repellent agents, e.g. on jackets, shower curtains, etc.

Pesticides Compounds used for preventing growth of insects or fungi on plants, animals or materials. In textile industry they are mainly used in production and transportation of natural fibres (cotton, wool).

pH The pH-value represents the acidity/alkalinity. A low value shows an acidic media and a high value shows an alkaline media. Fabric samples for testing need to be packed separately in plastic bags. Various chemicals and processes in the textile- and garment production require certain pH-values, e.g. mercerisation and dyeing of cotton involves the use of chemicals with high pH-values. Garment washing and finishing will also affect the final pH-value.

Chlorinated Phenols Pentachlorophenol (PCP) and Tetrachlorophenol (TeCP) can be used to prevent mould and kill insects when growing cotton and when storing/transporting fabrics. They can be used for both textiles and leather. PCP/TeCP can also be used as a preservative in print pastes.

o-Phenylphenol (OPP) o-Phenylphenol (OPP) can be used for its preservative properties in leather or as a carrier in dyeing processes.

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Restricted Substances

Description and Field of Application

Phthalates Phthalates are sometimes used to facilitate moulding of plastic by decreasing its melting temperature. They are also commonly used as softeners in plastics. Phthalates can be found in: Print pastes Adhesives Plastic (not only PVC) Plastic buttons Plastic sleevings

Poly Aromatic Hydrocarbons (PAH)

Polyaromatic Hydrocarbons (PAHs) are natural components of crude oil and they are a common residue from oil refining. PAHs have a characteristic smell that reminds of the smell of car tires or asphalt. Oil residues containing PAHs are added in rubber and plastics as a softener or extender. Therefore, PAHs are risky in rubber, plastics, lacquers and coatings. Clean mineral oils should be used in the rubber to avoid PAHs.

Polychlorinated Biphenyles (PCBs)

PCBs and PCTs are large molecules containing many chlorine atoms. PCBs/PCTs are mainly used as pesticides but also as softeners, carriers and flame retardants.

Polychlorinated Triphenyles (PCTs) Polyvinylchloride (PVC) PVC is a plastic that can be soft or hard, transparent or

coloured. In the textile industry PVC is used to make plastic accessories such as badges, sequins and zip pullers, stickers or as coating on textiles for rainwear and prints. Fake leather bags and garments can also be made out of PVC. Various kinds of prints might be made out of PVC.

Triclosan Triclosan can be used as disinfectant and as an antibacterial agent in textiles.

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Additional Requirements

Description

Antibacterial treatment Chemicals added for their ability to kill bacteria. They might be added to the garment, often sportswear, to prevent smell. The chemicals can during use and laundry be released and have a negative environmental impact. Antibacterial treatments in the finished product for any brand in H&M group are banned.

Discolouration Some chemicals can react with light, oxygen or solvents and cause a discolouration of the product. Phenolic yellowing is when a material under special circumstances is turning yellow. Risky materials are: Polyamide and polyamide/elastane blends, Embroidery Polyester Cotton The main reason is the presence of Butylated HydroxyToluene, CAS no. 128-37-0. BHT is a chemical which is often present in plastic bags, elastane, polyurethane foam (e.g. in bras) etc. BHT is not yellow itself, but it could be converted by pollution (NOx) assisted by amino groups (e.g. of polyamide, elastane and softeners) and then become yellow. Polyamide/elastane blends are especially sensitive and should be protected by special anti-yellowing chemicals. If done properly, the fabric will not turn yellow, even if BHT is present. Heat setting such as moulding of bra cups at high temperature is a possible risk if the process it not controlled correctly and/or the fabric is not protected with anti-yellowing chemicals. Precautions to be taken

• Avoid mixing many different qualities within one garment.

• Keep the amount of BHT and similar chemicals at a minimum in packaging material, polyurethane foam, polyamide, elastane etc. Investigate the possibility to find BHT-free foam.

• Treat all parts with anti-yellowing chemical products to make them less sensitive to phenolic yellowing. Both white and light coloured fabric/trims shall be treated.

• Make sure to finish the fabric and all trims at a low pH value using a non-volatile acid, such as citric acid. Final pH shall be 4.0-5.5.

• All factories and storage facilities must be kept clean and well ventilated to avoid excess amounts of NOx (nitrogen oxide gases).

• Avoid leftovers of chlorine after bleaching

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Additional Requirements

Description

Mould Mould spores are present everywhere in nature. Infection of fabrics/yarn/accessories/garments combined with storage/transportation in a humid and/or dirty environment can create severe damage on the garments. Mould is contagious and could infect other goods hanging close to or lying next to the infected goods. Keeping storage rooms and production facilities clean is essential for preventing mould.

Odour Odour can for example derive from: Solvents If the product is not aired or rinsed thoroughly, solvents and/or spot removers might remain in the product and hence cause smell. To avoid the use of spot removers it is important to keep the production facilities clean. Print pastes White spirit, kerosene and MTO can be used in print pastes. It is preferred to use only water based print pastes. PEVA For PEVA (Poly Ethylene Vinyl Acetate) plastic, the commonly used cross linker/catalyst DCP (Dicumyl Peroxide, CAS: 80-43-3) can release the substance Acetophenon (CAS: 98-86-2) which could give a very strong smell to the final product. DCP should not be used. Alternatives are available.

REACH Regulation (EC) No 1907/2006 of the European Parliament and of the Council concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals. Check the ECHA website for the updated list2

2 http://echa.europa.eu/chem_data/authorisation_process/candidate_list_table_en.asp

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COMMUNICATION ALONG THE SUPPLY CHAIN

• Forward H&M Chemical Restrictions to all your subcontractors, accessory suppliers, dye mills, print mills, tanneries, chemical suppliers etc. and make sure that they have the latest updated version available (see the flow chart below).

• Insist that the chemical supplier provide Safety Data Sheets (SDS) for all dyes,

auxiliaries and other chemical products used. SDS shall contain certain specified information presented in a standardized way. Information about how a SDS should be structured and what it should contain can be found in Appendix 1. Study of the SDS can help to reveal whether the materials used are free from banned substances. However, the content of any banned substances in the chemical product always need to be verified in other ways, since SDS don’t have complete information about all ingredients in the chemical product.

• Use dyestuffs, pigments and textile auxiliaries from reputable manufacturers, for example ETAD members (www.etad.com).

• All chemical products should have properly labelled containers. Example of labelling requirements can be found in Appendix 2.

• Make sure dye mills, print mills, tanneries, wash units have certificates from their chemical suppliers stating that all their chemicals are in compliance with H&M Chemical Restrictions. An example of a certificate is to be found in Appendix 3.

• Check the H&M Group Supplier Portal for “Positive list”. This is a listing done by chemical suppliers pointing out which of their products that fulfil Zero Discharge of Hazardous Chemicals, ZDHC3.

3 “Zero Discharge of Hazardous Substances” is a cooperation between brands to eliminate or substitute hazardous chemicals in our supply chain. Please see http://www.roadmaptozero.com/ for more info.

H&M Chemical

Restrictions

SUPPLIER

SUB CONTRACTOR

DYER, PRINTER, TANNER

CHEMICAL MANUFACTURER

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CHEMICAL TESTING It is clearly stated in H&M Chemical Restrictions that the supplier has full responsibility for compliance between their products and H&M Chemical Restrictions. Compliance to the H&M Chemical Restrictions is investigated by H&M Group through chemical testing. Products to be tested and tests to be performed by H&M Group are decided by the local H&M lab or by H&M Global Quality Department. Testing is performed both randomly as well as based on risk assessment and past performance. H&M Group only performs tests on H&M Group’s own initiative. The supplier pays for H&M Group’s testing on placed orders. For development testing, H&M Group pays. Below is a clarification on the routines and responsibilities.

Supplier Chemical Testing and Testing according to Risk Assessment

Suppliers will for each style/order get a risk assessment form filled out by the local H&M lab. In the risk assessment, there are a number of check boxes for various restricted chemicals. Suppliers are requested to perform tests for the selected chemicals. If nothing else has been agreed, test reports should be submitted to H&M Group, together with the counter sample.

Non Compliance

Any problems to comply with H&M Chemical Restrictions must be reported to H&M Group immediately. Products that do not comply with H&M Chemical Restrictions will be rejected. For details, see Standard Purchase Conditions4.

How to choose Labs for Chemical Tests

Business decisions are based on test results. Therefore it is important that the data from the laboratories is reliable. Some examples of things to consider when choosing a laboratory are:

The lab must hold relevant certifications or accreditations. The lab must be able to perform the tests described in Appendix B.3 in H&M

Chemical Restrictions. The lab must regularly participate in round-robin or blind sample correlation

testing. The lab must have satisfactory runtimes. The lab should inform if any of their tests are subcontracted.

4 Download the document at H&M Group Supplier Portal.

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Guide for Chemical Testing

The different substances in H&M Chemical Restrictions are more likely to be found in certain types of materials than others. Below table gives an indication where the substances are more likely to occur if present. This table does not claim to be complete.

5 Formaldehyde is especially risky in pigment print, flock print and puff print. 6 N-Nitrosamines are especially risky in vulcanized material eg. rubber, latex and TPE/TPR. 7 Organotin compounds are especially risky in print and PU coated fabric. 8 PCP and TeCP are especially risky in fake suede. 9 Polyaromatic Hydrocarbons, PAHs, are especially risky in rubber.

Material

Chemicals

Textile

Leather

Plastic Rubber Paint

& Surface coating

Metal Paper

& Wood

Fusing Padding Feather

& Down Cellulosic

fibre Wool Silk Synthetic

fibre

Natural &

Synthetic blend

APEO ● ● ● ● ● ● ● ● Azo ● ● ● ● Bisphenol-A ● Cationic Surfactant ● ● Chloroparaffins ● Cr VI ● Disperse dyes ● ● Dimethylformamide ● Formaldehyde ● ● ● ● ● ●5 ● ● Metals, extractable

● ●

Metals, total ● ● ● ● ● Nickel release ● N-Nitrosamines ●6 Organotin Compounds

●7

pH ● ● Phenols ●8 ● ● ● Phthalates ● PAH ●9 PVC ●

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FREQUENTLY ASKED QUESTIONS Do not hesitate to contact H&M Group with any questions you might have. Below are answers to some of the most frequent questions.

H&M Chemical Restrictions

Why are substances restricted? First of all to make sure that H&M Group products are complying with all relevant legislations and regulations within the countries where H&M Group markets products. Secondly, H&M Group voluntarily bans or limits the use of some substances due to environmental and health concern. Will complying with H&M Chemical Restrictions make my products more expensive/less competitive? H&M Chemical Restrictions is a part of the contract between H&M Group and its suppliers. Every time H&M Group places an order, it is expected that the price includes compliance with H&M Chemical Restrictions. It is not interesting to compare prices between compliant and non-compliant products, since H&M Group does not wish to buy non-compliant products, no matter the price. Is H&M Group recommending alternative substances? Not generally. In some cases recommended alternatives are however available on request. If you fear you will not be able to comply with a certain restriction, always contact your local H&M Group office as early as possible. There might be a solution to your problem, but you should not rely on that. The best is always if the supplier is working directly with chemical suppliers to find the best combination of availability, performance and price. How can we ensure compliance? The fastest, cheapest and easiest way is to have total control over the substances used in the production of your products. H&M Chemical Restrictions must be handed over to your subcontractors like dye mills, print mills, tanneries etc. They should then demand their chemical suppliers to supply them only with chemical products that won’t cause difficulties with complying with H&M Chemical Restrictions. Good chemical suppliers are able to submit certificates stating that. Furthermore, tests could be carried out for substances that for some reason are difficult to have control over. Are there any restrictions for sulphur dyes? No, but experience show that sulphur dyed fabrics are likely to face problems with physical tests, e.g. dry rubbing. Why is it that H&M Group can get a fail test result when our button supplier guarantee Lead free? For Lead, H&M is testing the total amount. It might be that your button supplier tests the extractable amount which is a less strict test. For some eco labels, the requirement is extractable amount, but H&M’s requirement is for the total amount. Is it OK to use “ecological” PVC? No. All PVC is banned from all H&M products. The term ecological PVC generally refers to PVC which is free from heavy metals and/or other additives.

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May I use Cr-dyes for H&M Group products? There are generally two types of Cr-dyes; metal-complex and mordant dyes. Except for polyamide, polyamide blends and worsted wool, these dyes may not be used when producing H&M Group products. In the case of polyamide, polyamide blends and worsted wool, Cr-dyes may be used as long as H&M Group’s limit for extractable Chromium can be achieved. May I use fluorescent dyes and pigments? Yes, provided that the product can comply with H&M Chemical Restrictions (e.g. formaldehyde). The production also has to correspond to all H&M Group requirements and restrictions in all aspects. If you receive a quotation request and have doubts about this, always contact H&M Group directly. Are there additional requirements to be followed for organic cotton? All suppliers of organic cotton products must be certified by OE100 or GOTS and OE Blend. Contact your local H&M Group office or H&M’s Sustainability department in Stockholm for more information. Could soldering add to lead content in jewellery? Yes, soldering material often contain lead. Lead free soldering materials are available and recommended to use. Can I use AFIRM10 RSL Guidance instead of H&M Chemical Restrictions? AFIRM RSL Guidance compiles the RSLs (Restricted Substances Lists) of the AFIRM members. It often stipulates the strictest limit in any of the members RSL, but not always. No policy decisions like PFC ban or PVC ban are included. Also other parameters might be excluded. It only gives RSL guidance about apparel and footwear products and not of any other product types. All suppliers must comply with H&M Chemical Restrictions, which differs from AFIRM RSL Guidance. What is AFIRM Toolkit and where can I find it? AFIRM Toolkit has been developed by AFIRM to assist the suppliers to fulfil the RSL requirements. It contains a lot of information about restricted substances, how they can be eliminated, corrective actions, which substances that are risky in specific materials, etc. The Toolkit is available in English, Chinese and Vietnamese. You can find the Toolkit on AFIRM website (free to download): http://www.afirm-group.com/ What is the purpose of the MRSL and how does it differ from the RSL? The aim of the MRSL is to secure not only the final product but also the work environment and environment in the production country. What is the Zero Discharge of Hazardous Chemicals Programme? H&M cooperates with several other brands to drive positive change through eliminating the use and discharge of hazardous chemicals in the product life cycle. For more information please see: http://www.roadmaptozero.com/

H&M Contacts

Who do I contact at my local H&M Group office if I have questions? In the table in the beginning of this document you find contact e-mail addresses for all different POs for queries about restricted chemicals and tests.

10 AFIRM – Apparel and Footwear International RSL Management Group

H&M Implementation Toolkit for H&M Chemical Restrictions – 18(21) Apparel/Accessories/Footwear/Soft Products, 8 July 2013

Testing and Test Methods

What test methods are to be used? For each restricted substance in H&M Chemical Restrictions, a test method is defined in Appendix B.3 in H&M Chemical Restrictions. What testing is required by H&M Group? Suppliers will for each placed order get a risk assessment made by local H&M Group’s lab. On this risk assessment, there is a part consisting of a number of check boxes for various restricted chemicals. Suppliers are then requested to perform tests for the chemicals and materials for which boxes are ticked. If nothing else has been agreed on, test reports should be submitted to H&M Group together with the counter sample. Is H&M Group testing? H&M Group only performs tests on H&M Group’s own initiative. Products to be tested and tests to be performed by H&M Group are decided by the local H&M lab or by H&M Global Quality Department. Testing is performed both randomly as well as based on risk assessment and past performance. The supplier will also be required to carry out its own tests according to a risk assessment done by local H&M lab. Who pays for testing? The supplier pays for H&M Group’s testing on placed orders. For development testing, H&M Group pays. H&M Group’s testing will be focused on products and suppliers with a bad test record, which will also be discussed with each supplier. Consequently, suppliers with good past performance will have to pay very little, but for suppliers with bad test record, the test cost might be significant. What happens in the case of contradictory test results? H&M Group’s test result will prevail. Are fail test results negotiable? NO! Any product that fails in a chemical test will be treated as non-compliant, no matter how close to the limit the result is. Anything else could mean that it would be illegal for H&M Group to put that product on the market. No exceptions are made. What laboratories are used by H&M Group? H&M Group is only using laboratories that through inter laboratory correlation tests have shown to give similar and accurate test results. These laboratories are able to test according to required test methods and are aware of H&M Chemical Restrictions. What happens in the case of non compliance? Any product that is found to be in non compliance with H&M Chemical Restrictions will be rejected by H&M Group. The supplier will be claimed for the cost of the products and any extra costs caused by the non compliance. If we are Oeko-Tex Standard 100 certified, why do we have to comply with H&M Chemical Restrictions? The reason for this is that Oeko-Tex Standard 100 and H&M Chemical Restrictions are NOT the same. The two standards have significant differences. Some chemicals that are restricted by H&M Group are not included in Oeko-Tex Standard 100, and for other chemicals, the limits and/or test methods might differ.

H&M Implementation Toolkit for H&M Chemical Restrictions – 19(21) Apparel/Accessories/Footwear/Soft Products, 8 July 2013

APPENDIX 1. SAFETY DATA SHEET (SDS) The SDS for a chemical product should have a structure and content as specified in Article 31 of REACH Regulation (EC) No 1907/200611 or in GHS12. The classification given in the SDS shall be done according to GHS, Dangerous Preparations Directive13 (mandatory in EU until 1st June 2015) and/or CLP Regulation14 (mandatory in EU from 1st June 2015). It shall be dated and contain at least the below headings.

1) IDENTIFICATION OF THE SUBSTANCE/MIXTURE AND OF THE COMPANY/UNDERTAKING;

2) HAZARDS IDENTIFICATION;

3) COMPOSITION/INFORMATION ON INGREDIENTS;

4) FIRST-AID MEASURES;

5) FIRE-FIGHTING MEASURES;

6) ACCIDENTAL RELEASE MEASURES;

7) HANDLING AND STORAGE;

8) EXPOSURE CONTROLS/PERSONAL PROTECTION;

9) PHYSICAL AND CHEMICAL PROPERTIES;

10) STABILITY AND REACTIVITY;

11) TOXICOLOGICAL INFORMATION;

12) ECOLOGICAL INFORMATION;

13) DISPOSAL CONSIDERATIONS;

14) TRANSPORT INFORMATION;

15) REGULATORY INFORMATION;

16) OTHER INFORMATION (GHS – OTHER INFORMATION INCLUDING INFORMATION ON PREPARATION AND REVISION OF THE SDS)

11 REACH Regulation (EC) No 1907/2006 http://eur-lex.europa.eu/en/index.htm 12 Globally Harmonized System of Classification and Labelling of Chemicals (GHS)

http://www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html

A Guide to GHS http://www.osha.gov/dsg/hazcom/ghs.html 13 Dangerous Preparations Directive 1999/45/EC on classification, packaging and labeling of dangerous

preparations http://eur-lex.europa.eu/en/index.htm 14 CLP Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and

mixtures http://eur-lex.europa.eu/en/index.htm

H&M Implementation Toolkit for H&M Chemical Restrictions – 20(21) Apparel/Accessories/Footwear/Soft Products, 8 July 2013

APPENDIX 2. LABELLING OF CHEMICAL PRODUCTS Labelling requirements, which should be in conformity with national requirements, shall cover15:

• PRODUCT NAME / TRADE NAME

• IDENTITY OF THE CHEMICAL PRODUCT

• HAZARD PICTOGRAMS

• SIGNAL WORD

• HAZARD STATEMENT

• PRECAUTIONARY MEASURES & PICTOGRAMS

• FIRST AID STATEMENTS

• SUPPLEMENTAL INFORMATION

• NOMINAL QUANTITY

• IDENTIFICATION OF THE BATCH

• NAME, ADDRESS AND TELEPHONE NUMBER OF THE CHEMICAL SUPPLIER

Fig 1.Example of a label including required elements according to GHS.

15 In GHS (Globally Harmonized System of Classification and Labelling of Chemicals) and/or CLP Regulation No 1272/2008 there is more information about labelling of chemical products.

H&M Implementation Toolkit for H&M Chemical Restrictions – 21(21) Apparel/Accessories/Footwear/Soft Products, 8 July 2013

APPENDIX 3. COMPLIANCE CERTIFICATE Below is an example of a certificate for compliance that certifies that a specific chemical product complies with H&M Chemical Restrictions. Certificates from individual chemical suppliers can look different and have different wording depending of legal aspects and the nature of their business.

Date: xxxx

CERTIFICATE We herewith confirm that the following chemical product:

Name of chemical product Fulfils the requirements of the current valid “H&M Chemical Restrictions”, provided that the appropriate application and consideration of our recommendations are followed. Signature Name Title Company name and address Company Stamp