The Apparel & Footwear International RSL Management Group (AFIRM) has recently released the 2025 mid-year update (Version 10.1) of its Restricted Substances List (RSL). Building upon Version 10 released in February 2025, this update further responds to global regulatory changes and introduces significant revisions to the testing methods and restriction requirements for Per- and Polyfluoroalkyl Substances (PFAS), UV Absorbers/Stabilizers, and Volatile Organic Compounds (VOCs). It provides the latest compliance guidance for the global apparel, footwear, and textile supply chains.
I. Overview of Key Changes
1. PFAS Method Updates
- Textiles & Other Materials (excluding Polymers): Recommends using the latest standard EN 17681-1:2025 for analyte analysis.
- Leather: The testing method remains unchanged, with EN ISO 23702-1:2023 still recommended.
- Polymers (Coated Fabrics, Polymers, Plastics, Foams, and Rubber): Added EN ISO 23702-1:2023 as a method, explicitly specifying the sample preparation procedure using THF extraction followed by methanol precipitation for testing.
- Total Organic Fluorine Screening: Added EN 17813:2023 as a testing method for total organic fluorine, providing more standardized basis for preliminary PFAS screening in the supply chain.
2. Expanded UV Absorbers List with Tightened Limits
- In response to updates in the EU REACH SVHC Candidate List and the Persistent Organic Pollutants (POPs) Regulation, AFIRM has adjusted the UV absorber category:
- New Substance: UV 329 has been added to the restricted list with a limit set at 1000 ppm.
- Tightened Limit: The limit for UV 328 has been significantly reduced from 1000 ppm to 100 ppm due to its inclusion in the EU POPs Regulation.
3. Optimized VOC List & Release of VOC Testing Guidance
- Significant adjustments have also been made to the VOC section to enhance testing practicality and relevance:
- Removed Substance: 2,4-Toluene diisocyanate (CAS No. 584-84-9) has been removed from the VOC appendix list due to its boiling point and analytical interference issues.
- New Guidance: Released VOC Testing Guidance, providing detailed operational instructions for VOC screening and confirmatory testing in the supply chain.
II. Industry Impact and Action Recommendations
The AFIRM RSL is a widely recognized chemical management tool in the global apparel and footwear industry, endorsed and utilized by numerous major brands. This mid-year update deepens and optimizes the detection and control of key substances, reflecting the rapid evolution of global regulations and testing technologies.
PFI recommends that our supply chain partners promptly review the latest version of the RSL and related guidance documents to understand and master the latest changing trends, ensuring that testing plans and compliance strategies align with the most current requirements.
About AFIRM
The Apparel & Footwear International RSL Management Working Group (AFIRM) is an industry working group comprised of leading global apparel and footwear companies. Its mission is to reduce the use and impact of harmful substances in the apparel and footwear supply chain by providing unified resources and fostering communication and collaboration.
