Frankfurt, August 19,2020
First, there is – in general – a limited consumer risk from textile and leather articles. Secondly, the restriction proposal is demanding a restriction of all substances with a harmonised classification as „sensitiser“ – completely independent of their actual use in textile or leather production, and not considering whether allergies may be caused by them or not.
This would, in practice, not only lead to an enormous number of unnecessary testing and monitoring costs, because textile and leather articles would have to be tested for non-occurrence of regulated substances – which are not even used for the manufacture of these consumer articles. Many dyes (being used for many years, some of them for decades) would be banned, even though there is no indication that textiles which had been dyed with them have ever caused allergies. As an alternative, the association TEGEWA proposes to regulate well-known, strong sensitisers with individual limits and, by doing so, to focus on real relevance and exposure by those substances through textiles and leather – as successfully implemented in the “Restriction of CMR substances in textile articles and clothing for consumer use under REACH” of 2018.
In 2019, Sweden and France published a proposal to restrict sensitising substances in textiles and leather. Not only textile and leather industry themselves, but also the textile and leather auxiliaries industry as well as the dyestuff industry are affected by this proposed restriction. This had been the reason for the association to develop a joint position on this first restriction proposal with its member companies, the international organization representing the dye and pigment industries ETAD and various German and European textile and leather industry associations. The association’s comments on this proposal had been submitted at the first public consultation in December 2019. Following the common legislative process in the EU, the two ECHA committees RAC (Risk Assessment Committee) and SEAC (Socio-Economic Analysis Committee) discussed the submitted comments and developed their opinions.
SEAC’s „Draft Opinion“ had been subject to a further public consultation (deadline August 24th). Due to the high relevance and importance of this topic, TEGEWA developed and submitted (again in cooperation with the above mentioned associations) a further position regarding the SEAC draft opinion (see weblink of this post to ECHA’s website). Focus of this position was an extensive argumentation against the intended restriction of specific disperse and reactive dyes. For textiles that have been dyed with these substances there is no indication – neither from the view of market relevant dyes manufactures nor from the view of the associations ETAD and TEGEWA – of sensitising effects to consumers by leather or textile articles.
On the other hand, these dyes do have – for decades – such a huge market relevance, that a ban would imply incalculable consequences for the companies producing dyes; for the textile and leather dyeing companies as well as for the consumers who could not purchase numerous articles any more.
As an alternative, the association developed a process based on a list of substances which can in fact be present on textile and leather articles and may lead to allergies to consumer. This process is also comprising a course of action regarding a regular update of the substances concerned – after verification whether they are relevant or not.
Apart from these important dye classes the association TEGEWA also pointed out implications for the manufacture of leather and textile articles; among others flame retardant and non-iron finishing of textiles and tanning of leather. Furthermore, TEGEWA sees a high risk for the European textiles and leather producers, as especially the European industry will be affected by the restriction – whereas, in parallel, articles are imported from outside the EU with unclear quality and consumer exposure.
The association TEGEWA is doing its best to contribute to a regulation as reasonable and justifiable as possible which actually is helping to improve consumer safety.