AFIRM RSL 2025 Update

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Vol. 1461 | 25 Feb 2025

AFIRM 2025 Restricted Substances List Updates

The Apparel and Footwear International RSL Management (AFIRM) Restricted Substances List (RSL) is a list of chemicals that are restricted in the apparel and footwear industries. AFIRM is a group of companies that work together to manage chemicals in the supply chain.

AFIRM has released the 2025 version of its Restricted Substances List. A detailed log of these changes is available on page 11 of the 2025 RSL document.

Following is a high-level summary of changes:

  • Tightened limits on Bisphenols based on material type.
  • Added three Cyclosiloxanes to the restricted substances list, aligned with REACH and SVHC regulations.
  • Expanded the "Flame Retardants" section, renaming it to "Brominated and Organophosphorus Substances" and adding Triphenyl Phosphate (TPP).
  • Strengthened PFAS regulations by lowering the Total Organic Fluorine limit, revising PFOS restrictions, and adding PFHxA and related substances.
  • Introduced UV 326 and updated the Volatile Organic Compounds (VOCs) Appendix and list.

Following is a comparison of key changes (2024 versus 2025) for Bisphenols, PFAS, Cyclosiloxanes and Volatile Organic Compounds:

Chemical Group

2024 Version

2025 Version

Comments
Bisphenol Requirement Items intended to come in contact with the mouth: BPA: 1 ppm All Other Materials: 1000 ppm each [BPA,BPS,BPB,BPF]  BPA: Textiles & Leather: 10 ppm Items intended to come in contact with the mouth: 1 ppm Other Materials: 1000 ppm BPS, BPB, BPF:Textiles: 200 ppm each Leather: 800 ppm eachOther materials: 1000 ppm each     BPA limit in textiles and leather lowered to 10 ppm.BPS, BPB, and BPF limits lowered to 200 ppm in textiles and 800 ppm in leather
PFAS Total Organic Fluorine:100 ppm by 2025 50 ppm by 2027 Total Organic Fluorine: 50 ppm  Changed total organic fluorine limit to 50 ppm.   Divided PFOS restriction into “PFOS and its salts” and “PFOS-related substances” with new limits.
PFOS:Perfluorooctane Sulfonate (PFOS) and related substances:1 μg/m2 total   PFOS:Perfluorooctane Sulfonate (PFOS) and its salts: 25 ppb TotalPFOS-related substances: 1000 ppb total
Cyclosiloxane NA  NEW ADDITION:Octamethylcyclotetrasiloxane (D4),Decamethylcyclopentasiloxane (D5),Dodecamethylcyclohexasiloxane (D6) 1000 ppm Each   Added new category for Cyclosiloxanes restricted under REACH and as SVHCs with limit of 1000 ppm each.
VOCs Benzene: 5 ppmAll other VOCs [19 substances] Total: 1000 ppm   Benzene: 5 ppmAll other VOCs Total: 500 ppm Remark: Added new VOCs [22 substances] to the list under new Appendix  D  VOC substances moved to new Appendix D.  Updated section to include existing VOCs from previous RSL versions, added 10 existing RSL substances from other RSL sections that are also VOCs; and added 22 new VOCs based on hazard trait and ability to test with a single analysis.

Insight Author: Harini Ramaswamy, Technical Expert. 

If you have further questions, please contact our technical expert Pankaj Sarda (Pankajkumar.Sarda@intertek.com).

If you have any questions, please contact:

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Harini Ramaswamy

Technical Manager, Softlines

Harini provides technical and regulatory support on consumer products testing to retailers in North America. She supports global labs, engages with regulatory bodies, industry groups and standards organizations. Harini holds a master’s degree in Design (Apparel Studies) from the University of Minnesota and B. Tech in Apparel Technology from Anna University, Chennai. Her functional apparel design projects presented at the Industrial Fabrics Association International (IFAI) and Techtextil conferences have won her numerous accolades. 

Email:  harini.ramaswamy@intertek.com

Pankajkumar Sarda

Director, Program Management & Development, Sales & Marketing

Pankaj Sarda has nearly 20 years of experience in consumer goods, focusing on regulatory compliance, product testing, and chemical management. He advises on product safety and regulatory changes, serving as a member of the Apparel and Footwear Association’s RSL Working Group. Pankaj holds degrees in Material Science, Business Administration, Textile Chemistry, and Manufacturing from the University of Massachusetts and the Textile & Engineering Institute in India.

Email: pankajkumar.sarda@intertek.com

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