On October 29, 2026, the ZDHC Foundation officially released version 4.0 of its Manufacturing Restricted Substances List (MRSL), with the transition period commencing on November 1, 2026.
Building on V3.1, the new version tightens limits for multiple substances, adds new controlled substances, clarifies its position on PFAS, and updates test methods – placing higher compliance demands on chemical formulators, suppliers, and brands.
This article systematically outlines the core changes and transition arrangements in V4.0, helping companies plan ahead and achieve compliance steadily.
1. Timeline
November 1, 2026
Chemical formulators: Must re-review their own products and assess whether they meet MRSL V4.0 requirements.
February 1, 2027
ZDHC publishes the list of approved certification bodies for V4.0: Formulators may apply to designated certification bodies for MRSL V4.0 certification. Downstream buyers are encouraged to prioritize V4.0-compliant formulations.
November 1, 2027
Formulator transition period ends: All chemical formulations must be updated in the ZDHC Gateway system to achieve V4.0 compliance.
June 1, 2028
Supplier transition period ends: Supply chain suppliers must fully clear and consume all inventory of chemical formulations that do not comply with V4.0.
2. Scope of Application
- Chemical formulators: Must complete formulation gap analyses for their own products and submit V4.0 certification applications.
- Suppliers (wet processing, dyeing, auxiliaries users, etc.): Must take stock of existing inventory, prioritize procurement of V4.0-compliant formulations, and phase out non-compliant formulations within the deadline.
- Brands / Retailers: Must cascade V4.0 changes throughout the supply chain and update procurement and assessment specifications.
3. Overview of Key Changes
|
Area
|
Key Changes
|
|---|---|
|
Tightened limits for existing substances
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Limits lowered for APEOs, chlorinated paraffins, chlorobenzenes/chlorotoluenes, DMAC/DMFa/NEP/NMP, etc., with differentiated controls by application scenario (pigments, textiles, leather)
|
|
Newly added controlled substances
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Bisphenols, aldehydes/ketones, PCBs, UV absorbers, etc. added, with limits set by application scenario
|
|
PFAS position
|
PFAS defined as fluorinated substances containing a –CF₃ or –CF₂– group. Any formulation with intentional PFAS addition is non-compliant, including PTFE.
|
|
Updated test methods
|
Test methods updated for AP/APEOs, o-phenylphenol, permethrin, triclosan, chlorinated paraffins, halogenated solvents, organic solvents, phthalates, PAHs, etc.
|
|
List classification adjustments
|
Disperse Orange 61, free vinyl chloride monomer, and UV-P added to the candidate list; respirable crystalline silica and carbon trichloride moved to the archived list
|
4. Detailed Changes I – Tightened Limits for Existing Substances
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Substance
|
V3.1 Limit
|
V4.0 Limit
|
|---|---|---|
|
APEOs (NPEO, OPEO)
|
250 mg/kg
|
100 mg/kg
|
|
SCCP / MCCP
|
250 mg/kg
|
50 mg/kg (except leather)
|
|
1,2-Dichlorobenzene
|
500 mg/kg
|
20 mg/kg (200 mg/kg for pigments)
|
|
Chlorobenzenes/chlorotoluenes (sum of mono/di/tri)
|
500 mg/kg
|
20 mg/kg (excluding 1,2-dichlorobenzene)
|
|
Chlorophenols (sum of mono/di/tri)
|
50 mg/kg
|
25 mg/kg (except leather)
|
|
UV absorber (UV-328)
|
1000 mg/kg
|
100 mg/kg
|
|
HBCDD
|
250 mg/kg
|
75 mg/kg
|
|
DMAC / DMFa / NEP / NMP
|
1000 mg/kg
|
500 mg/kg
|
|
Cresols (sum of all isomers)
|
500 mg/kg
|
100 mg/kg (except leather biocides)
|
|
2-Methoxypropyl acetate (polymers)
|
/
|
50 mg/kg
|
|
2-Methoxypropanol (leather)
|
/
|
2500 mg/kg
|
|
PFAS (individual)
|
Varies by substance
|
25 µg/kg
|
|
PFAS (total)
|
Varies by substance
|
250 µg/kg
|
|
Naphthalene (leather)
|
Leather formulations: 200 mg/kg
|
Leather formulations: PAHs total 200 mg/kg
|
5. Detailed Changes II – Newly Added Restricted Substances
|
New Chemical Group
|
New Substances
|
Limit
|
|---|---|---|
|
Bisphenols
|
Bisphenol F
|
1000 mg/kg
|
|
|
Bisphenol S (BPS)
|
1000 mg/kg
|
|
|
Bisphenol B
|
1000 mg/kg
|
|
|
Bisphenol AF
|
25 µg/kg (classified as PFAS)
|
|
Aldehydes/ketones
|
Formaldehyde
|
Formaldehyde-based formulations 1000 mg/kg; non-formaldehyde-based 250 mg/kg
|
|
PCBs
|
Polychlorinated biphenyls
|
10 mg/kg (25 mg/kg for organic dyes/pigments; 50 mg/kg for silicone-based formulations)
|
|
Redox agents
|
Potassium permanganate and other permanganates
|
1000 mg/kg (textiles)
|
|
Other/Miscellaneous
|
Dicumyl peroxide
|
1000 mg/kg (polymers)
|
|
|
Triphenyl phosphate
|
1000 mg/kg
|
|
|
1,4-Dioxane
|
1000 mg/kg
|
|
|
Styrene (free monomer)
|
1000 mg/kg (polymers)
|
|
|
OBSH (blowing agent)
|
1000 mg/kg (polymers)
|
|
UV absorbers
|
UV-326
|
1000 mg/kg
|
|
|
UV-329
|
1000 mg/kg
|
|
Dyes
|
Solvent Green 1
|
250 mg/kg (textiles)
|
|
PFAS
|
Total fluorine
|
50 mg/kg
|
|
Total metals
|
Zinc (Zn)
|
Dyes 1500 mg/kg; pigments 1000 mg/kg
|
|
|
Iron (Fe)
|
Dyes 2500 mg/kg; not applicable to pigments
|
|
|
Manganese (Mn)
|
Dyes 1000 mg/kg; not applicable to pigments; denim fading agents 1000 mg/kg
|
6. Detailed Changes III - Updated PFAS Position
PFAS is defined as fluorinated substances containing a –CF₃ or –CF₂– group. Any formulation with intentional PFAS addition is non-compliant, including PTFE.
7. Detailed Changes IV - Updated Test Methods
In MRSL V4.0, test methods have been updated for multiple substances, including AP/APEOs, o-phenylphenol, permethrin, triclosan, chlorinated paraffins, halogenated solvents, organic solvents, phthalates, and PAHs.
8. Detailed Changes V - List Classification Adjustments
Candidate List (Chapter 2): Disperse Orange 61, free vinyl chloride monomer, and UV absorber UV-P have been added. These are potential control targets for future versions only and do not currently require mandatory MRSL compliance testing.
Archived List (Chapter 3): Respirable crystalline silica particles and carbon trichloride have been moved to the archived list.
9. What Should Companies Focus On?
Although MRSL V4.0 provides a transition period of nearly 20 months, the tightening of PFAS management, newly restricted substances, and further lowered limits all reflect the continuously rising demands of global brands for chemical management and supply chain transparency. Companies are advised to begin the following work as early as possible:
✔ Assess gaps between existing products/formulations and MRSL V4.0
✔ Identify PFAS and other newly restricted substance risks
✔ Review the impact of adjusted limits on products
✔ Maintain communication with raw material suppliers, customers, and certification bodies
✔Develop substitution and upgrade plans in line with the transition timeline
The earlier assessment and verification begin, the lower the future conversion costs – and the better positioned your supply chain will be to meet brand and market requirements.
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