This report calls for collaboration and alignment around a single set of rules: sound chemical management systems should be a ticket to play, not a market differentiator.

The Transformers Foundation, a non-profit representing the denim supply chain, launched its investigative report titled Fashion’s Chemical Certification Complex: Needlessly Complicated, Woefully Ineffective that equips fashion professionals with the actions they can take to reform chemical management in the fashion industry.

“Fashion has a chemical certification problem,” the Foundation says. “Dozens of private-sector auditors, consultancies, labs, and certifications provide an expensive and inefficient form of surveillance over the supply chain on behalf of brands.”

Many of these organisations offer almost identical services. While brands and retailers use chemical management as a differentiator, a marketing tool, and a way to shirk responsibility, it is the supply chain—from the chemical companies to the denim laundries—that pays for testing, certification, and management of these overlapping safety protocols.

Alberto De Conti, head of marketing and fashion division at Rudolf Group, remarked: “I don’t see why we shouldn’t have one globally-accepted RSL. Can you think of any reason why Diesel jeans should have different requirements, environmentally speaking, than Levi’s jeans, Pepe jeans or Calvin Klein jeans? There is a bad need for alignment.”

This paper calls for collaboration and alignment around a single set of rules, fund research, increase testing and enforcement, increase transparency and information sharing, reduce the number and amount of hazardous chemicals in circulation, and improve the global health of consumers, communities, and ecological systems.

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By GlobalData

Recommendations from the report follow:

Brands and Retailers

  • Ascribe to ZDHC MRSL and the AFIRM RSL: Calling on brands to align themselves with the most respected MRSL (Manufacturing Restricted Substance List) and RSL (Restricted substance list) in the industry. This simple step will cut down on confusion and inefficiencies, so that chemical management is standardized and (more importantly) done well no matter the brand or supplier. In addition, brands and retailers should align on certification equivalence.
  • Develop in-house technical expertise: An RSL is no good unless a brand can understand how to achieve it. Every large brand should have at least one in-house chemical engineer and/or toxicologist who can oversee chemical management and interface with suppliers to ensure that their chemical safety standard, MRSL, and RSL are being met. These experts can also work with the design team to set parameters that ensure suppliers don’t feel pressure to use hazardous chemistry to achieve brand requests.
  • Treat your suppliers ethically: Suppliers cannot adhere to an MRSL unless brands create the economic conditions for them to do so. A brand’s own KPIs must be aligned with the KPIs set for their manufacturers, with a view towards shared profitability instead of a race to the bottom on prices. Brands should select suppliers in part on the basis of their chemical management systems, commit to long-term contracts, and share the financial burden of testing products, equipment upgrades, and more expensive safe chemical products.
  • Lobby government to incorporate standards into law: Strong chemical management systems should be a ticket to play, not a market differentiator. Brands and retailers should lobby governments in countries where their products are sold to put the ZDHC MRSL and the AFIRM RSL into law as a bare legal minimum standard applicable to all.
  • Provide ingredient lists for consumers: Every consumer fashion product should carry a label or code that lists all known carcinogenic, mutagenic, reproductive toxic, bio-accumulative, persistent, allergenic, or sensitizing chemicals present.


  • Fund and empower governing bodies to focus on consumer product chemical safety: Calling for additional funding for both the Consumer Product Safety Commission and the EPA, to expand their mandate to research, test, approve or disapprove new chemical product use.
  • Align with other countries to unify chemical guidance: Ideally, chemical standards would be harmonized, and there would be no more than a few RSLs that differ only according to product category, material or, in rare cases, religious beliefs. To achieve that, governments need to work together to agree upon higher standards of chemical safety, with aligned regulations both on what can be used in fashion production, and what can be on the final product. The strictest RSLs by a handful of brands show what is possible—their limits should be the standard to which governments aspire.
  • Pass due diligence laws that hold fashion companies liable for worker exposure: We have a good understanding of the health risks for workers of exposure to substances like powdered indigo with aniline, potassium permanganate, hypochlorite, and formaldehyde. We support due diligence legislation, which is currently being considered in several European countries and at the EU level. It would allow workers in production facilities to hold brands liable for injury, sickness, and death due to poor practices in a factory the brand sources from.

Chemical companies

  • Collaborate on a collective position on chemical complexity: The ZDHC’s success so far is based on the industry’s willingness to collaborate in an organization with a clear governing structure. Chemical manufacturers and formulators should come together and decide which chemical products need to be officially retired from the market. This working group could also work on language that is more accessible to non-chemistry-educated advocates, journalists, and legislators.

Last month, the apparel sector presented joint recommendations in a letter supporting the commitment of EU decision makers to implement a regulatory approach to due diligence, in order to ensure companies are taking their responsibility to respect human rights and the environment throughout their value chains.

You can access the full report here.