1. Commitment -Restricted Substance Mission Statement
A&F Co.’s Global Regulatory Department conducts research, evaluates and communicates regulatory requirements for all brands. These requirements are mandated by laws and regulations where A&F Co. has stores and active websites. The primary role of the Regulatory Department is to determine 1: which laws and regulations impact our products, 2: how our products impact the consumer and 3: how our product impacts the environment. The Regulatory Team consists of product experts who coordinate across the supply chain and internal cross functional partners. They contribute to process, policy, and product standards that allow our brands to achieve global compliance. We update our Restricted Substance List (RSL) on an annual basis. Simply put, we keep the product compliant and safe.
A&F Co.’s mission is “COMMITTED TO QUALITY. AUTHENTIC GOODNESS. ALWAYS FORWARD”.
Quality
A&F Co. 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 Co.’s Restricted Substance Policy.
Authentic Goodness
A&F Co. achieves this by considering the welfare and best interests of consumers of A&F Co. products, the workers who make them and the environment that provides the resources for their manufacture.
Always Forward
A&F Co. remains committed to the vision of zero discharge of hazardous chemicals from our supply chain. A&F Co. aims to do this while striving to make our business profitable, in order to continuously optimize the benefits for all our stakeholders.
We publish our chemicals of concern, listed in our RSL, in order to provide transparency around our limitation of certain chemicals. We also publish ingredients and allergens on each personal care product in accordance with local regulations and the Personal Care Products Council’s Consumer Commitment Code. Customers can contact customer service about specific questions related to product formulation here.
2. Scope
The Scope of the 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.
The Policy takes into consideration countries in which A&F Co. conducts business. Three channels of management exist:
- RSL for Textile products, Accessories, & Footwear
- RSL for Formulated Products*
- A&F Co.’s Manufacturing RSL (Based on the vision of Zero Discharge of Hazardous Chemicals Manufacturing RSL 2.0 (ZDHC MRSL 2.0)
*Send inquires to sustainability@anfcorp.com
3. Our Strategy
A&F Co.’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 substances 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 Co. 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 Co.’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 Co. Restricted Substances Policy requires the vendor and the suppliers in which they procure materials to prove to themselves, and then prove to A&F Co. 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 Co. 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 Co. Master Vendor Agreement.
Vendors are ultimately held accountable for the financial burdens in the event of a non-compliance issues. A&F Co. 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 Co.’s RSL Summary
Our Restricted Substance List in its entirety includes thousands of chemicals. In the interest of simplicity, A&F Co. RSL Summary includes categories of restricted chemicals. In some instances, our standard may be more stringent than the regulation requires. The method in which an article is tested and the legal bases to measure compliance is also included. Inquiries can be made at sustainability@anfcorp.com.
6. Restricted Substance Summary
| TEST ITEM | TEST METHOD | LEGAL BASE & REQUIREMENT # |
|---|---|---|
| Azo Dyes + Arylamine salts | Textile: EN ISO14362-1:2017 / EN ISO 14362-3:2017 Leather: ISO 17234-1:2015 / ISO 17234-2:2011 | REACH Annex XVII Entry 43 & 72*： Each < 20mg/kg |
| Chromium VI after aging | Aging Method: ISO 10195-A2 EN ISO 17075-1:2017 | REACH Annex XVII, Entry 47： < 3 mg/kg |
| 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 CPSC-CH-E1003-09.1 Coating; CPSC-CH-E1002-08.3 for Non-metal; CPSC-CH-E1001-08.3 for Metal | EU: REACH Annex XVII Entry 63： <100 mg/kg (Substrate); <90 mg/kg (Coating) |
| Nickel Release only for materials with skin contact | Coated metal: EN 12472 + EN 1811 Uncoated metal: EN 1811 | REACH Annex XVII Entry 27： < 0.5 µg/cm2/week |
| Phthalates | ISO/TS 16181 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 PAH | REACH Annex XVII, Entry 50, 72*： Children:<0.5mg/kg Others: <1 mg/kg (each) |
| Formaldehyde | EN ISO 14184-1:2011 | REACH Annex XVII, Entry 72*： <75 mg/kg * <16 mg/kg Kids <20 mg/kg ESMA |
| PCP | ISO 17070 | POPs Regulation, Annex I: N.D. |
| Dimethylfumarate (DMFU) | CEN ISO / TS 16186:2012 | REACH Annex XVII Entry 61： < 0.1mg/kg |
| APEO/ NPEO | Leather: draft EN ISO 18218:2015 Textile: ISO 18254-1:2016 | 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 |
| PFAS Long Chain: (PFOA) perfluorooctanoic acid including its salts & related substances. | Regulation (EU) 2019/1021 | REACH Annex XVII Entry 68 coated materials shall not contain in a concentration more than 0.025 mg/kg of perfluorooctanoic acid (PFOA) including its salt and more than 1 mg/kg of one or a combination of PFOA-related substances. Usage Ban |
| PFAS Long Chain: (PFOS) perfluorooctane sulfonates) and its derivatives | POP’s Regulation(EU)2019/1021 CEN/TS 15968:2010 | PFOS and its derivatives in concentrations less than 1 µg/m² of the coated material: Usage Ban |
| PFAS Total Fluorine | EN14582 | Usage Ban Commitment 2025 |
| Flame retardant-Various | ISO 17881-2016 | REACH & POPs：<10ppm Usage Ban |
| Dyestuffs-Carcinogenic | DIN 54231:2005 | REACH Annex XVII Entry 72*： < xx mg/kg <50 mg/kg EU <30 mg/kg EMSA |
| 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 | REACH Annex XVII Entry 72*： NMP, DMAC, DMFA < 1 mg/kg (each) |
| Quinoline | DIN 54231:2005 | 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 |
| 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 |
| The Safe Drinking Water and Toxic Enforcement Act -Prop 65 | Various | Various |
Key
#: The limit is not applicable to a composite sample. In the event that 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