In November 2022, ZDHC released the latest ZDHC MRSL V3.0 with its guidance documents now available on its official website. What is the difference compared to V2.0? Any key takeaway? We are now here to break it down for you.
1. What files have been updated by ZDHC?
Four documents have been released by ZDHC, including:
- ZDHC Manufacturing Restricted Substances List version 3.0
- ZDHC MRSL Conformance Guidance version 2.0
- ZDHC MRSL Industry Standard Implementation Approach version 2.0
- ZDHC MRSL Update Principles and Procedures version 3.0
2. ZDHC MRSL V3.0 Major Updates
- Clarifications in introductory text (e.g. Archived List substances)
- CAS number updated;
- Formulation limits either unchanged or revised downward;
- Test methods updated and clarified;
- New additions to Candidate List and Archive List;
- NP, OP, NPEO, OPEO limits made stricter;
- Any formulation based on, or including PFAS, not permitted (for fashion, sport or outdoor clothing apparel and home textiles), except for end uses where legally or contractually mandated standards may only be achieved using these substances (e.g., military, medical, protective clothing, oil & gas exploration);
- Navy Blue Colorant moved to Archived List;
- Several substances moved from Candidate List to ZDHC MRSL V 3.0 (including free aniline, Cyclic Siloxanes, Organic Solvents, FRs);
- Some solvent based technologies to be judged through the ZDHC Supplier Platform and supported by Responsible Solvents Guideline.
3. ZDHC MRSL Conformance Guidance Major Updates
The ZDHC MRSL Conformance Guidance has updated the requirements for ZDHC MRSL Level 1, 2, and 3 with the deletion of Level 0 as follows:
Level 1 Attributes
- Review of SDS for information on ZDHC MRSL substances
- Analytical testing for ZDHC MRSL substances using professional judgement and Smart Testing Grid
- An analytical test report from the ZDHC-approved MRSL certifier.
Level 2 Attributes
- Level 1 principles of analytical evaluation for ZDHC MRSL conformance are fulfilled;
- Onsite review of management systems at manufacturing facility
Level 3 Attributes
- Principles of analytical testing for ZDHC MRSL Conformance Level 1 and the principles of management systems for Level 2 are being achieved;
- Onsite review of Chemical Hazard Assessment (CHA) capability at manufacturing facility (in-house or sub- contracted).
4. Transition Period
Chemical Formulators, suppliers and brands will have a 12-month transition period (until November 2023) to implement MRSL V3.0 and Conformance Guidance V2.0. During the transition period, MRSL V2.0 and V3.0 are available simultaneously.
From 1 February 2023, chemical formulators can certify products against the ZDHC MRSL V3.0 with ZDHC approved MRSL Certifiers and upload ZDHC MRSL V3.0 conformant products on ZDHC gateway. Wherever possible, suppliers start purchase of ZDHC MRSL V3.0 conformant formulations.
After the transition period ends on 1 November 2023, the ZDHC gateway will only accept uploads of ZDHC MRSL V3.0 conformant products.
5. PFI Fareast Solutions
PFI Fareast is the ZDHC-approved MRSL certifier to provide testing protocols in accordance with the ZDHC MRSL Conformance Guidance for testing and verifying MRSL Level 1 compliance of chemicals used in the production of textiles, synthetic leather and leather. We support textile, garment, leather and footwear manufacturers and their chemical suppliers to implement chemical control and enhance the market competitiveness of chemical suppliers by verifying their compliance.
