Hidden Dangers in Your Supply Chain: Chlorinated Paraffins—The Ticking Bomb for Fashion Industry

1. EU's notification on chlorinated paraffins

During 2025, the European Union’s Rapid Alert System for Non-food Consumer Products (RAPEX, commonly known as the Safety Gate) reported a total of 62 cases of Short-Chain Chlorinated Paraffins (SCCPs) non-compliance in products. The affected products cover multiple categories including electrical appliances and equipment, clothing, textiles and fashion items, Gadgets, and Hobby/sports equipment.

Reported cases have revealed several key patterns and underlying causes of SCCP non-compliance:

  • Extremely high concentrations and combined non-compliance: In most cases, SCCPs were detected at high levels, alongside high concentrations of phthalates (e.g., DEHP). This indicates the potential use of untested low-cost recycled materials or inferior additives.
  • Failure in supply chain control: As plasticizers or flame retardants, SCCPs may be concealed in basic materials such as flexible PVC, plastics and rubbers. Manufacturers that fail to conduct targeted control and testing on the above raw materials are highly susceptible to such non-compliance issues.
  • High geographic concentration of origin: An overwhelming majority of SCCP-noncompliant products in the reports are of Chinese origin. This reflects prevalent risks in the supply chain of specific raw materials within relevant industrial clusters, which has also made these clusters a key subject of regulatory scrutiny by the EU.

RAPEX reported three cases of SCCPs recall in 2025. It was found that the SCCPs detected from 1.38-5.8% in the products. The recall might be due to the less control in upstream chemicals in their productions. The production chemicals might contain SCCPs, resulting in exceeding the limits of SCCPs in the finished products.

The following are three notification cases regarding footwear products in 2025:

2. Chlorinated Paraffins Introduction

Chlorinated Paraffins are mixtures produced by the chlorination of straight-chain alkanes. Thanks to their flame retardancy, plasticizing properties, and low cost, they are widely used in the processing of footwear and clothing materials. They are classified into SCCPs (C10 – C13), MCCPs (C14 – C17), and LCCPs (C18 – C30) according to the carbon chain length. Among them, SCCP and MCCP are key control targets for environmental protection compliance in the footwear and clothing industry due to their environmental persistence and bioaccumulation.

Chlorinated paraffins – Examples of different chain lengths

Applications of chlorinated paraffins in the fashion industries
Application
Application instructions
Leather production
They often exist as impurities in leather fatliquoring agents or are used for leather degreasing and fatliquoring to increase the softness and luster of leather.
Plastic and rubber products
They are used in PVC shoe soles, synthetic leather (PU/PVC), rubber accessories, etc., serving as plasticizers and flame retardants.
Printing inks and adhesives
They enhance the adhesion and fire resistance of shoe upper printing, brand logos, and assembly adhesives.
Surface coatings
They are used for waterproof or anti - mildew surface treatment of textiles to improve the durability of fabrics.

It is worth noting that the residual SCCPs/MCCPs in finished products or are inadvertently introduced into the supply chain through recycled materials (such as recycled plastics). This makes source control extremely important.

4. Environmental and health hazards: From scientific consensus to global action

The hazardous characteristics of chlorinated paraffins have been confirmed by a large number of studies and have become the core basis for international convention control:

Environmental hazards
Health risks
SCCPs and MCCPs have the typical characteristics of persistent organic pollutants (POPs), that is, they are extremely difficult to degrade in the environment, can remain in water bodies and soil for a long time, and have the ability to migrate over long distances. They are lipophilic and easily accumulate in the fat of organisms and are magnified through the food chain, posing a high risk to the aquatic ecosystem.
SCCPs are classified as suspected carcinogens and may damage the liver, kidneys, thyroid, and immune system; the evaluation of MCCPs focuses on their reproductive and developmental toxicity, which may endanger the health of fetuses.
5. Regulatory highlights

Currently, short-chain chlorinated paraffins (SCCPs) are strictly prohibited globally, while medium-chain chlorinated paraffins (MCCPs) are becoming a new global focus of strict control.

On November 21, 2025, the European Union officially released the draft amendment to the “POPs Regulation” (EU) 2019/1021, planning to include three major categories of substances, namely chlorpyrifos, medium-chain chlorinated paraffins (MCCPs), and long-chain perfluorocarboxylic acids (C9 – 21 PFCAs), in the Annex I control list. This means that the production, placing on the market, and use of MCCPs within the EU will be comprehensively prohibited, with only a very small number of transitional exemptions for certain industries retained.

Main markets/regions
Core control measures and status
Global (Stockholm Convention)
It was included in Annex A (Elimination List) in 2017, requiring the elimination of its production and use globally.
European Union
• POPs Regulation: Limit in articles < 0.15% (1500 mg/kg)
• Substances of Very High Concern (SVHC): Limit < 0.1% (1000 mg/kg)
China
As of January 1, 2024, production, use, and import/export are prohibited.
• GB 25038 - 2024 (General safety requirements for footwear): Limit < 0.15% (1500 mg/kg)
• GB 30585 - 2024 (Safety technical specification for children's shoes): Limit < 0.15% (1500 mg/kg)
Main markets/regions
Core control measures and status
Global (Stockholm Convention)
It was included in Annex A (Elimination List) in May 2025, requiring global phase-out.
European Union
• Substances of Very High Concern (SVHC): Limit < 0.1% (1000 mg/kg)
• It is proposed to be included in the POPs Regulation, with a limit of ≤ 0.1% (1000 mg/kg) set, and it is planned to take effect in the second quarter of 2026.
6. Commonly used testing methods for chlorinated paraffins
  • ISO 22818: 2021 Textiles – Determination of short-chain chlorinated paraffins (SCCPs) and medium-chain chlorinated paraffins (MCCPs) in textile products of different matrices by gas chromatography – negative ion chemical ionization mass spectrometry (GC-NCI-MS)
  • ISO/TR 17881-3: 2018 Textiles – Determination of flame retardants – Part 3: Chlorinated paraffin flame retardants
  • GB/T 40263-2021 Textiles – Determination of short-chain chlorinated paraffins
  • ISO 18219-1: 2021 Leather – Determination of chlorinated hydrocarbons in leather – Part 1: Chromatographic method for short-chain chlorinated paraffins (SCCPs)
  • ISO 18219-2: 2021 Leather – Determination of chlorinated hydrocarbons in leather – Part 2: Chromatographic method for medium-chain chlorinated paraffins (MCCPs)
  • GB/T 38405.1-2025 Leather and fur – Determination of chlorinated hydrocarbons – Part 1: Short-chain chlorinated paraffins (SCCPs)
  • GB/T 38405.2-2025 Leather and fur – Determination of chlorinated hydrocarbons – Part 2: Medium-chain chlorinated paraffins(MCCPs)

SN/T 3814-2014 Determination of short-chain chlorinated paraffins in rubber and plastic products – Gas chromatography – tandem mass spectrometry

SN/T 4118-2015 Determination of short-chain chlorinated paraffin content in paints and coatings

7. PFI's Services
  • Regulatory Interpretation: Provide interpretation of regulations related to chlorinated paraffins for enterprises and customize exclusive compliance implementation paths.
  • Risk Assessment: Conduct special risk screening and assessment of chlorinated paraffins for footwear, apparel products, and raw and auxiliary materials.
  • Testing and Verification: Provide professional testing services for chlorinated paraffins, verify product compliance, and issue authoritative reports.
  • Root Cause Analysis: Conduct traceability analysis of chlorinated paraffins in products, locate the source of problems, and provide targeted solutions.

Share this article

Other Articles

Blogs

Update of 2026 AFIRM RSL

In February 2026, the Apparel and Footwear International RSL Management Group (AFIRM) has released the 2026 Restricted Substances List (RSL) (Version 11). It highlights the

Read More »