July 30, 2020
Detailed knowledge of international standards and risk management related to the supply, execution and performance of textile products can help support your business.
To delve deeper into this vast and diverse topic, we interviewed our experts: Angela Donati, EMEA softline technical lead, and Silvia Lai, technical manager — Technical Research and Protocol Development.
Please contact our UL team for more information.
Question: Do color fastness tests have to be carried out on prints when placing them on the Chinese market?
Angela: Yes, color fastness tests must be carried out on all the garment’s components, i.e., on the main fabric and the prints following the appropriate standard. This includes any ribbon, borders or embroideries, whenever they are large enough to perform the test.
Question: In China, are there any special flammability requirements for nightwear?
Angela: No, the same tests are carried out on nightwear as on daywear. For adult garments, the test is Guobiao Standard (GB) 18401, and for children’s clothing, GB 18401 and GB 31701. There are specific flammability tests for other markets such as the U.S., Canada, the U.K. or Australia.
Question: In the United States, what is the General Certificate of Conformity (GCC)? Can it be in an electronic format?
Silvia: Every product manufacturer (and the company that affixes their own brand onto the product, if it features a private trademark) included in the scope of the Consumer Product Safety Improvement Act (CPSIA) of 2008, and any other act of the commission, needs to certify, based on evidence, that the product complies with all applicable notices, rules, standards and regulations. For products not intended for children, certificates must be based on tests carried out on each product or through a reasonable testing program.
The commission has issued a standard in 16 Code of Federal Regulations (CFR) part 1110, which specifically allows for the use of an electronic certificate, provided that:
- the commission and customs have access to it;
- the electronic GCC contains all the information required by law;
- it complies with the other requirements of 16 CFR 1110. For example, the certificate is identified by a unique identifier and can be accessed via a Web address or other electronic means; there must be a way to identify its date of creation or last modification.
Question: How do I add the California Proposition 65 requirements to the Restricted Substances List (RSL)?
Silvia: The most common approach is to include a general request to the suppliers to confirm that the product does not legally require a warning (or if requested, to specify for which substances) and to include in the RSL, the most commonly found and verified substances in similar products. However, it’s important to be aware that this action serves to mitigate the risk without fully hedging it.
Question: In the United States, should all color variants be tested for flammability?
Angela: What a brand must have is a reasonable testing program to ensure that all goods placed on the market are compliant. Consequently, for the fabrics most at risk, it is necessary to extend the sampling and particularly to verify the results obtained from the tests. Depending on the criticality, it may be necessary to select more colors or more production batches.
Question: In the European guideline on the restriction of carcinogenic, mutagenic and reprotoxic (CMR) substances, there is a restriction on some products that come into contact with the skin similar to clothing. Is this list considered exhaustive?
Silvia: No, the list provided in the guideline is not an exhaustive list, but only a list of products which, by way of example, fall under the restriction. Every time a product has contact with the skin similar to a clothing garment, it should be considered to fall under the restriction, even if not explicitly mentioned in the guideline. For example, childcare products such as baby carriers, pushchairs and prams certainly have parts that involve skin contact similar to clothing. Therefore, it is appropriate to assess all products, even those that are not strictly clothing, in order to establish the applicability of the restriction.
Question: In Europe, the persistent organic pollutants (POP) regulation lists a number of substances that are also covered by the registration, evaluation, authorization and restriction of chemicals (REACH) regulation. In such cases, which rules of procedure prevail?
Silvia: Both regulations are applicable. In principle, you need to consider both and select the more restrictive limit and the wider scope. However, a proposal for a regulation has recently been published, which aims to remove certain substances from the REACH regulation (Phencyclidine (PCP), perfluorooctanoic acid (PFOA), decabromodiphenyl ether (DecaBDE)), precisely to avoid these overlaps. Therefore, it is expected that there will no longer be any overlap between the two regulations.
Question: Do natural fiber garments release microfibers during washing?
Angela: Garments with natural fibers do release fiber fragments during washing. These garments are made of materials of animal or vegetable origin and tend to be less persistent in the environment, degrade much faster and therefore are of less concern.
THIS DOCUMENT IS FOR GENERAL INFORMATION PURPOSES ONLY AND IS NOT INTENDED TO CONVEY LEGAL, REGULATORY OR OTHER PROFESSIONAL ADVICE.
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