1. Commitment -Restricted Substance Mission Statement
A&F’s Global Regulatory Affairs Department is responsible for conducting comprehensive research, evaluating, and effectively communicating the regulatory requirements applicable to all brands within the company. These regulatory requirements are mandated by the laws and regulations of the countries in which A&F operates its physical stores and websites.
The primary objective of the Regulatory Department is to identify and determine three key aspects. Firstly, the department aims to ascertain which specific laws and regulations have an impact on the products offered by A&F. This involves thoroughly analyzing the legislative frameworks of different regions to ensure compliance with the relevant requirements.
Secondly, the department focuses on understanding how the products offered by A&F affect the consumer. This involves conducting research and analysis to evaluate the potential impact of these products on the health, safety, and overall well-being of the customers.
Lastly, the Regulatory Department aims to determine how A&F’s products comply with environmental laws and regulations. This involves an in-depth coordination with our Legal and Corporate Sustainability Departments to ensure that products adhere to the specified standards set forth by regulatory bodies. By doing so, the department plays a crucial role in maintaining and enhancing A&F’s reputation for quality and compliance within the global market.
A&F Co.’s mission is “COMMITTED TO QUALITY. AUTHENTIC GOODNESS. ALWAYS FORWARD”.
Quality
A&F actively maintains a high standard of quality and safety for all products shipped globally to consumers. One of the ways this is achieved it through the management of A&F’s Restricted Substance Policy.
Authentic Goodness
A&F achieves this by considering the welfare and best interests of consumers of A&F products, the workers who make them, and the environment that provides the resources for their manufacture.
Always Forward
A&F remains committed to the vision of zero discharge of hazardous chemicals from our supply chain. A&F aims to do this while striving to make our business profitable, in order to continuously optimize the benefits for all our stakeholders.
2. Scope
The Scope of the A&F Restricted Substance Policy covers all brands and product categories.
Chemical formulations covered by restrictions include, but are not limited to, textiles, leather, rubber, foam, adhesives, cleaners, paints, inks, detergents, dyes, colorants, auxiliaries, coatings, finishing agents used during raw material production, wet processing agents, process machinery maintenance, and wastewater treatment. Specific to formulated products, ingredients and allergens are listed on each product in accordance with local regulations and the Personal Care Product Councils (PCPC®) Consumer Commitment Code.
The Policy takes into consideration countries in which A&F conducts business. Three channels of management exist:
Apparel, Footwear & Accessories
- A&F Restricted Substances List (RSL) for Textile products, Accessories, & Footwear
- A&F’s Manufacturing RSL (Based on the vision of Zero Discharge of Hazardous Chemicals Manufacturing Restricted Substance List 3.0 (ZDHC MRSL3.0)
Formulated Products
- A&F’s Restricted Substance List for Formulated Products for Formulated Products
3. A&F’s Strategy
A&F’s Quality Assurance and Regulatory Departments maintains a six- part approach to managing and mitigating the risk of restricted substances:
- Align with industry goals and initiatives specific to the most current list of restrictive substance found globally.
- Annually educate and inform the supply chain of specific restricted substance policies and substance control measures based on legislative updates.
- Should A&F be aware of any changes in the legislation regarding hazardous substances and its test methods, they will inform vendors and material suppliers. This, however, does not release vendors and material suppliers from their responsibility to monitor and comply with all legal requirements relevant to the products they supply and to ensure full compliance.
- Seasonally obtain test evidence from your suppliers through due diligence regulatory and quality testing and product audits.
- On demand technical support or corrective actions (as needed) are utilized to further mitigate the risk of substances found in materials and or finished product.
- Biannual wastewater factory training, monitoring, and auditing in partnership with the A&F’s Sustainability Department.
4. Vendor & Material Supplier Responsibilities
Vendors and suppliers are informed of legislative updates through monthly and or quarterly updates as the global regulatory landscape changes. Once informed Vendors and Suppliers are held accountable for compliance based on applicable international laws and regulations that restrict or prohibit the type and concentration of potentially hazardous substances.
The A&F Restricted Substances policy requires the vendor and the suppliers in which they procure materials to prove to themselves, and then prove to A&F, that Restricted Substances (specified hazardous chemicals) are not present in their supply chain, or when their use cannot be avoided, then the levels of the Restricted Substances in the product are well below the minimum levels required by the consumer and environmental protection legislation in our global markets.
- A&F pursues and maintains contractual relationships only with those Vendors and Suppliers that have agreed to comply with the guidelines and directives set out in the A&F Master Vendor Agreement.
- Vendors are ultimately held accountable for the financial burdens in the event of a non-compliance issues. A&F also works with vendors and suppliers in the resolution and proactive preventative measures to further reduce and control the possibilities of unwanted substances in products.
5. How To Read A&F’s RSL Summary
At A&F, we believe in maintaining transparency when it comes to our commitment to limiting certain chemicals in our products. As part of our dedication to sustainability, we have chosen to publish a summary of A&F’s master list of restricted chemicals. This summary provides an overview of the major categories of restricted chemicals, the testing methods employed to ensure compliance, and the legal basis that guides our efforts.
Our master list includes various categories of restricted chemicals, encompassing substances that may pose potential risks to human health or the environment. By categorizing these chemicals, we can effectively manage their presence in our products and work towards safer alternatives.
In order to maintain compliance with our chemical limitation standards, we employ rigorous testing methods. These methods enable us to accurately assess the presence of restricted chemicals in our articles. Our testing procedures adhere to industry best practices and are regularly reviewed and updated to incorporate the latest advancements in technology and scientific understanding.
It is important to note that, in some cases, our standards may be more stringent than what is required by regulations. We believe that by going above and beyond regulatory requirements, we can better protect our customers and the environment. Our commitment to exceeding legal obligations ensures that our products meet the highest standards of safety and sustainability.
For any inquiries or further information regarding our chemical limitation practices, please feel free to contact us at Sustainability@anfcorp.com
6. A&F’s Restricted Substance List Summary
| TEST ITEM | TEST METHOD | LEGAL BASE & REQUIREMENT # |
|---|---|---|
| Azo Dyes + Arylamine salts | Textile: EN ISO14362-1:2017 / EN ISO 14362- 3:2017 Leather: ISO 17234-1:2020/ ISO 17234-2:2011 | REACH Annex XVII Entry 43 & 72*： Each < 20mg/kg |
| BPA/BPB | ACN at 40 °C for 3 hours, LC/MS/MS analysis | Prop 65: Article does not contain more than 1 ppm of BPA/BPB *Pending Settlements |
| Chromium VI Content | Leather: EN ISO 17075-1, 2 :2017 | REACH Annex XVII, Entry 47： < 3 mg/kg Not detected |
| Total Cadmium | Microwave / Acid digestion followed by ICP-OES/MS analysis | REACH Annex XVII Entry 23： < 75 mg/kg <10 mg/kg jewelry |
| Total Lead | Microwave / Acid digestion followed by ICP-OES/MS analysis CPSIA Sec101 16 CFR 1303 CPSC-CH-E1002-08.3 for Non-metal; CPSC-CH-E1001-08.3 for Metal SOR/2018-8 | US CPSIA CANADA SOR 2018-83 (Childrens articles) EU: REACH Annex XVII Entry 63： <90 mg/kg (Substrate); <90 mg/kg (Coating) |
| Nickel Release – only for materials with skin contact | Release: EN 12472:2005+ A1:2009 (abrasion) and EN 1811:2023 Release (eyewear frames): EN 16128:2015 | REACH Annex XVII Entry 27： < 0.5 µg/cm2/week |
| Phthalates | Textiles: GC-MS, ISO 14389: 2022 CPSC-CH-C1001-09.3 CPSC-CH-C1001-09.4 | EU: REACH Annex XVII Entry 51, 52, 72*：SUM< 0.1% by weight USA: DEHP,DBP, BBP, DIBP, DnHP, DPP, DCHP,DINP < 1000mg/kg |
| Polycyclic Aromatic Hydrocarbons (PAH) | AfPS GS 2019:01 PAK | REACH Annex XVII, Entry 50, 72*： Children:<0.5mg/kg Others: <10 mg/kg (each) |
| Formaldehyde | All materials except Leather: JIS L 1041-1983 A or ISO 14184-1:2011 Leather: ISO 17226-2:2018 with ISO 17226-1:2021 confirmation method in case of interferences | Japan Law 112 REACH Annex XVII, Entry 72*： <75 mg/kg * <16 mg/kg Kids <20 mg/kg ESMA |
| PCP | 64 LFGB B 82.02-08 or DIN 50009:2021 | POPs Regulation, Annex I: Not detected 0.5 mg/kg |
| Dimethylfumarate (DMFU) | ISO 16186:2021 | REACH Annex XVII Entry 61： < 0.1mg/kg |
| APEO/ NPEO | Leather: draft EN ISO 18218:2015 Textile: ISO 18857-1-2015 | REACH Annex XVII Entry 46a： < 100 mg/kg |
| Organotin Compounds | CEN ISO / TS 16179:2012 | REACH Annex XVII Entry 20： < 0.1% (each) |
| Short-chain Chlorinated paraffins (SCCPs) | EN ISO 18219:2015 | POPs Regulation, Annex I： < 0.1% by weight |
| (PFOA) C8 Perfluoroocatonic acid and its salts, PFOA-related substances | (EU) 2019/1021 CEN/TS 15968:2010 EN 17681-1/-2:2022 (textiles) ISO/DIS 23702-1:2021 (leather) | shall not contain in a concentration more than 0.025 mg/kg of perfluorooctanoic acid and its salts. PFOA-related substances: < 1000 ppb (individual or sum) |
| (PFOS) Perfluorooctane sulfonates and its derivative | (EU) 2019/1021 CEN/TS 15968:2010 EN 17681-1/-2:2022 (textiles) ISO/DIS 23702-1:2021 (leather) | Shall contain in a concentration less than 1 µg/m² of perfluorooctane sulfonates (PFOS) & its derivatives |
| (PFCA’a) C9 C9-C14 A-related substances2, 3, 4, including their salts and any combinations thereof (inlcudes PFNA) | (EU) 2019/1021 CEN/TS 15968:2010 EN 17681-1/-2:2022 (textiles) ISO/DIS 23702-1:2021 (leather) | < 25 ppb (sum of C9-C14 PFCAs and their salts) < 260 ppb (sum of C9-C14 PFCA-related substances) |
| PFAS Total Fluorine | EN14582 | Usage Ban Commitment 2025 <50 mg/kg |
| Flame retardant-Various | ISO 17881 1,2: -2016 | REACH & POPs：<10ppm Usage Ban |
| Dyestuffs-Carcinogenic | DIN 54231:2022 | REACH Annex XVII Entry 72*： <50 mg/kg EU <30 mg/kg ESMA-UAE |
| Extractable heavy metals | EN 16711-2:2015 | REACH Annex XVII Entry 72*： Cadmium, Arsenic, Lead, Chromium VI <1 mg/kg (each) |
| Chloroganic Carriers | DIN 54232:2010 | REACH Annex XVII Entry 72*： <1 mg/kg |
| Solvents | ISO 16189:2021 | REACH Annex XVII Entry 72*： NMP, DMAC, DMFA < 1 mg/kg (each) |
| Quinoline | DIN 54231:2022 | REACH Annex XVII Entry 72*： <50 mg/kg |
| Volatile Organic Compounds | Headspace GC-MS | REACH Annex XVII Entry 72*： <5 mg/kg |
| Poly Vinyl Chloride | FTIR | Usage Ban Not detected |
| Substances of Very High Concern | Analysis is based on GC, LC, IC, ICP with various detection techniques and UV | EU. Regulation (EC) No.1907/2006 <1000 mg/kg |
| The Safe Drinking Water and Toxic Enforcement Act -Prop 65 | Various | Various |
7. Key
# The limit is not applicable to a composite sample. In the event harmful substances are detected in a composite sample. The separate test is recommended to determine which sample exceeds the limit.
* REACH Annex XVII Entry 72 will apply from 2020.11.1.
MRSL: Manufacturing Restricted Substances List
ppm: Parts per million, which is the same as mg/kg.
Percentage: Percentage is weight by weight, % w/w
REACH: Registration, Evaluation, Authorization and Restriction of Chemicals
SVHC: Substances of Very High Concern