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 challenges of the interaction between chemical restrictions and circularity in the industry. RSL also reports changes in chemical requirements. It includes addition and tightening the RSL limits for relevant restricted substances. The update is shown below.
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Substance/Material
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Modification
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Circular (Recovered or Recycled) Materials
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Added note about growing tension between chemical restriction policies and circular economy goals.
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Materials Submitted for Testing
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Added definitions for "Sample" and "Composite Sample."
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Acetophenone Azine (CAS No. 729-43-1)
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Added with a 50 ppm limit due to skin sensitization potential. Includes separate test method.
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Bisphenols
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• Reduced limit for BPS, BPB, and BPF in leather to 500 ppm each.
• Added limit for BPA in polycarbonate materials at 100 ppm. • Reduced limit for all bisphenols in other materials to 200 ppm each. |
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Cyclosiloxanes
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Updated method to Ultrasonic extraction with TBME or acetone for 30 min at 40°C, then GC/MS.
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Heavy Metals (Non-Jewelry)
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• Updated total content method for leather to EN ISO 17072-2:2022 for several metals.
• Changed extraction method for leather from DIN EN ISO 17072-1:2019 to EN ISO 17072-1:2019 for method reference consistency. • Changed methods for all other materials from DIN EN 16711:2016 to EN 16711:2015 for parts 1 & 2 for method reference consistency. • Updated method EN 16128:2015 for nickel release (eyewear frames) to 2025 version. |
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Organotin Compounds
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Updated test method to ISO 16179:2025.
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Per- & Polyfluoroalkyl Substances (PFAS)
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• Added important note and link to recently published Decree imposing new PFAS limits in France, with exemptions for secondhand and recycled goods as well as some highly specialized products.
• Re-added several PFAS substances to Appendix B that were previously removed during the 2025 midyear update because they cannot be directly measured with EN 17681-1:2025. Additional testing information is provided. |
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Solvents & Residuals
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Updated test method for textiles to EN 17131-1:2025.
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Formamide
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Adopted 200 ppm limit for play mats, baby mats, and yoga mats.
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UV Absorbers / Stabilizers
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Lowered the reporting limit to 50 ppm for entire category.
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UV 328 (CAS No. 25973-55-1)
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Added important clarification regarding stabilized THF used for extraction.
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About AFIRM RSL
The Apparel and Footwear International RSL Management (AFIRM) Group is a member-driven organization of apparel and footwear companies collaborating to promote chemicals management in the global supply chain. The AFIRM RSL is an authoritative chemical management tool published by this group. It has been widely adopted by numerous international brands as a crucial basis for supply chain compliance management.
With the release of the 2026 AFIRM RSL, it is expected that relevant brands will also update their internal RSL requirements accordingly. We recommend that concerned companies pay close attention to these changes to prepare in advance.
