Manufacturing Restricted Substances List (MRSL): FAQ’s

A holistic, responsible approach to chemical management is fast becoming an absolute requirement for any brand or retailer as part of a sustainable product offering. This is invariably placing pressure on upstream manufacturers to provide materials that are produced with responsible chemistry.

A major milestone for the textile, synthetics and leather industries was the release of the Zero Discharge of Hazardous Chemicals (ZDHC) Leather Manufacturing Restricted Substances List (MRSL).

With the shift in emphasis moving upstream to material manufacturers and chemical suppliers, Eurofins | BLC have produced this FAQ document as a guide to managing chemicals through the implementation of a MRSL.

 

Question Answer
What is a Manufacturing Restricted Substances List (MRSL)?

 

The function of the MRSL is to list chemical substances subject to a usage ban; the MRSL establishes acceptable concentration limits for substances. There should be no intentional use of a MRSL listed substance in commercially available chemical formulations nor in those from earlier stages of chemical synthesis.

 

How was the MRSL developed?

 

The content of the MRSL was developed by the Zero Discharge of Hazardous Chemicals (ZDHC) Technical Advisory Committee (TAC) and member brands. Industry experts were consulted to determine appropriate concentration limits necessary to ban intentional use.
The first ZDHC MRSL was published in June 2014 specific for textile and synthetic leather chemical manufacturers. In December 2015, a leather specific MRSL was also launched.; The ZDHC MRSL will become an industry standard tool and, if managed well, will be a vital resource for the textile, synthetics and leather industries, in effectively managing hazardous chemistry and setting the standards for a genuine reduction of the damaging impacts of chemicals used within material production. 
Why do we need a MRSL?

 

The current restricted chemical regulations for finished products are extensive. However, in spite of this, compliance to finished product regulations in multiple jurisdictions could still allow for the use of hazardous chemistry upstream. It is for this reason that NGO’s such as Greenpeace have pressured brands into ‘detoxing’ their supply chains and making public commitments around the removal of certain chemicals. This has created a major shift in attitude around the way chemicals are managed throughout supply chain.

 

What chemicals are covered in the MRSL?

 

The MRSL includes applicable substances from 11 priority chemical groups in the ZDHC Joint Roadmap commitments along with additional substances identified by the ZDHC TAC and member brands.

 

What is the difference between a MRSL and a Restricted Substances List (RSL)?

 

A RSL is a list of chemicals that must not be present in a finished article above certain specified limits. These chemicals and limits are driven by legislation, eco labels and brand/retailer decisions (which may go beyond compliance).
The MRSL, however, addresses hazardous substances which workers may be exposed to during the production life cycle as well as those that may be potentially used and discharged into the environment during manufacturing and related processes, not just those substances that are contained within finished product. 
Does the publication of the MRSL replace the need for RSL?

 

No. RSL’s remain extremely important tools for brands and retailers to ensure that they are providing product that is fit for the indented user and they make an important commitment to stakeholders around their responsibility to consumer safety. Such commitments around restricted chemicals remain fundamental to product safety management and are extremely important to guard against potential consumer safety issues and brand integrity.
Whilst there is some overlap between the MRSL and many brand’s RSL’s, not all RSL listed substances feature in the MRSL. The MRSL is focused on the eliminating the intentional use of certain substances during manufacturing processes. There are many substances restricted at RSL level which do not need to be banned from intentional use but the limits in finished materials/product must be controlled in order to satisfy regulatory requirements. 
Why are the limits in the MRSL higher than those in the RSL?

 

Chemicals used in manufacturing/processing contain much more concentrated levels of chemicals which then become diluted during their use in wet processing. Therefore, any substances residual in finished leather/product will almost always be present in lower concentrations that that of the chemical formulation. The limits appointed in the MRSL account for this dilution effect – it is not the case that the RSL is ‘more stringent’.

 

Will chemical formulations need to be tested for MRSL conformity?

 

Testing chemical formulations for conformity against the limits set out in the MRSL is likely to be used as a method to demonstrate compliance. The ZDHC MRSL does include references to methods (where they exist); in absence of this new test methods will need to be developed through partnership with ZDHC TAC, member brands and testing laboratories.

 

 

What is the timeframe for compliance to the MRSL?

 

There are no set timelines for the implementation of the MRSL; these are decisions to be made between brands and their individual supply chain.

 

How will the MRSL be communicated?

 

The MRSL is intended to be communicated to material manufacturers, raw material suppliers, including wet-processing facilities and sub-contractors and factories assembling or manufacturing textile, synthetics and leather product. ZDHC brands expect that material suppliers and factories will communicate with their chemical suppliers to ensure that the listed substances are not present in chemical formulations above established limits.

 

How will these industries implement the MRSL?

 

There are no set guidelines as to how implementation of the MRSL should work. It is likely that brands will be seeking assurance from suppliers regarding the absence of the listed chemicals. This may be through authorised lists of propriety chemicals (white list), declarations, testing and training. This will necessitate a change in procurement (where necessary) to approved chemicals.

 

Can brands outside of the ZDHC adopt the MRSL?

 

The MRSL, along with other guidance tools, are publicly available documents. The ZDHC brands encourage distribution and adoption of the MRSL and hope that other brands will implement the contents as a common standard in the supply chain.

 

Where can I access the MRSL?

 

You can download a copy of the ZDHC MRSL here: http://www.roadmaptozero.com/fileadmin/pdf/MRSL_v1_1.pdf

 

Is there any guidance about alternative chemicals that may be used?

 

Chemical substitution is a growing business with large investment assigned to research into the development of alternative, sustainable chemicals and technologies. The ZDHC group has issued a “research list” which outlines its research and development efforts to prioritise replacements for substances that currently do not have safer alternatives and that are restricted on the MRSL.

 

 

How Chem-Map Can Help

Begin your route to responsible Chemistry with Chem-MAP. Chem-MAP is a ZDHC approved MRSL verification system which is fully aligned with ZDHC objectives and can provide ZDHC Conformance Level 3.

View Chem-MAP’s MRSL Testing Page to see the packages that Chem-MAP offers for MRSL Testing. Also see MRSL Testing benefits for your company for more information.

Chem-MAP is the future of chemical management in leather, textile and synthetic materials supply chains.

 

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Watch the Chem-MAP video to see how this new ZDHC approved MRSL verification programme is engaging all organisations in the leather, textile and synthetic materials supply chains to drive the use of responsible chemistry in the manufacture of consumer products.

Chem-MAP is a preventative system that protects businesses, workers, consumers and the environment, and rewards businesses that engage through certification, approved status, training and technical support. Chem-MAP offers three programmes which are specifically designed for chemical companies (c-MAP Programme), manufacturers (m-MAP Programme) and brands and retailers (b-MAP Programme).

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