II REFERENCE MANUAL: SUBSTANCES OF LIMITED USE Organochlorinated Compounds Isocyanates...46

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4 INDEX INDEX I DEFINITION OF clear to wear II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE Formaldehyde...23 Arylamines...25 Phenols: Pentachlorophenol (PCP) and Tetrachlorophenol (TeCP) Cadmium Lead...30 Mercury Chromium...33 Chromium (VI) Nickel Phthalates. 36 Polybrominated Flame Retardants Pesticides. 38 Short Chain Chlorinated Paraffins Perfluorooctane Sulfonates (PFOS) Dimethyl Fumarate Organotin Compounds Allergenic Dyes II REFERENCE MANUAL: SUBSTANCES OF LIMITED USE Organochlorinated Compounds Isocyanates III LEGALLY LIMITED PARAMETERS: ph Composition Tolerance Colour Fastness in Water Colour Fastness to Perspiration Colour Fastness on Rubbing Colour Fastness to Saliva IV OTHER EU REGULATIONS OF MANDATORY COMPLIANCE: REACH This Referece Manual is a free translation from the Spanish Version. 13

5 INDEX ANNEX I: SUMMARY TABLE clear to wear ANNEX II: List of Controlled Individual Substances ANNEX III: Commitment to Comply with the Inditex group s Clear To Wear Product Health Standards...79 This Referece Manual is a free translation from the Spanish Version. 15

6 I DEFINITION OF clear to wear

7 I DEFINITION OF clear to wear I DEFINITION OF clear to wear clear to wear is defined as a product health Standard: has been developed by Inditex in conformity with the most stringent legislation on product health and safety. In addition to the composition, ph and colour fastness. regulates those substances whose use is legally limited and which, if present in the product above certain levels, could be hazardous for human health, such as: Formaldehyde, Arylamines, Phenols (PCP and TeCP), Cadmium, Lead, Mercury, Chromium, Chromium (VI), Nickel, Phthalates, Polybrominated Flame Retardants, Pesticides, Short Chain Chlorinated Paraffins, Perfluorooctane Sulfonates (PFOS), Dimethyl Fumarate, Organotin Compounds and Allergenic Dyes, additionally, clear to wear sets limits to the use of two parameters not contemplated by the legislation in effect: Organochlorinated Compounds and Isocyanates, finally, clear to wear includes REACH as the EU regulation of mandatory compliance for all Inditex suppliers. clear to wear is of general and mandatory application for all clothing products, footwear, accessories and/or fabrics supplied to Inditex. The Supplier is the only party responsible for the compliance of the products supplied to Inditex with clear to wear. Finally, and regardless of the commitment accepted by the Supplier to control the parameters regulated in clear to wear, Inditex will verify its correct implementation at any phase of the manufacturing process of those products that are manufactured, commercialized and/or distributed by it, by carrying out Routine and Random Sample analyses on determined Models/Quality at any point of their production cycle. clear to wear is applied through the following 10 families of products, which are defined according to article type, degree of contact with the skin and age of the end user: - Products for users younger than 3 years old (babies) - Clothing in direct and prolonged contact with the skin. - Clothing not directly in contact with the skin. - Parts of footwear in direct and prolonged contact with the skin. - Parts of footwear not directly in contact with the skin. - Accessories in direct and prolonged contact with the skin. - Accessories not directly in contact with the skin. - Metallic-only accesories. - Home textiles in direct and prolonged contact with the skin. - Home textiles not directly in contact with the skin. This Referece Manual is a free translation from the Spanish Version. 19

8 II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE. This Referece Manual is a free translation from the Spanish Version. 21

9 II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE. II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE. FORMALDEHYDE (1/2) 1. What is it? Formaldehyde (CAS No ) is a volatile chemical widely used in the textile and leather industries as: (1) preservative for vegetable and animal raw materials; (2) anti-wrinkling and anti-shrinking agent for cotton products; (3) dyeing and printing fixative, and (4) leather tanning agent. 2. Where can it be found? Formaldehyde can be found in many textile and leather products, due to its presence in the composition of a variety of chemical auxiliaries used in the textile and leather industries, such as: a) Fixing agents for direct and reactive dyes in cellulose fibers. b) Anti-wrinkle and anti-shrinking resins used in the finishing processes in cotton products. c) Resins used in permanent wrinkles in textile articles made of cellulose fibers, mainly in jeans. d) Heat transfer adhesives used as binders in dye printing. e) Heat transfer adhesives used in several types of printing processes, such as flock and foil, among others. f) Reducing agent present in printing by corrosion (rongeant) (Zinc Formaldehyde-Sulfonate) g) Resins and/or binding agents in some special finishes and/or coatings. h) Products for tanning and softening of leather. i) Anti-microbial agents in pastes used in water-based positional printing, and j) Preservatives for vegetable and animal raw materials. 3. How is it regulated? Japanese Legislation 1 : Guide to the Law for the Control of Household Products Containing Harmful Substances, enacted in Standard of mandatory use in the Russian Federation 2 : Textile- Maximum Allowable Concentrations of Free Formaldehyde, enacted in Norwegian Regulation 3 : Regulations Relating to Restrictions on the Manufacture, Import, Export, Sale and Use of Chemicals and Other Products Hazardous to Health and the Environment (Product Regulations), enacted in Standard and code of mandatory use in the People s Republic of China 4 : National General Safety Technical Code for Textile Products GB , enacted in 2005 and National Standard of the P.R.C., Leather and Fur-Limit of Harmful Matter GB , enacted in Limits: No detection (0.05 (A-A0) spectrophotometric absorption- or 16 ppm) for textile products aimed at users younger than 2 years old, and 75 ppm for underwear, sleepwear, gloves and socks. 2 Limits: No detection for textile products aimed at users younger than 1 year old; 75 ppm for textiles for underwear and bed linen; 300 ppm for textiles for shirts and a like; and 1000 ppm for textiles for coats, pant suits and a like, mainly. 3 Limits: 30 ppm for textile products aimed at users younger than 2 years old; 100 ppm for textiles that are usually in contact with the skin, 300 ppm for textiles that are not usually in contact with the skin. Additionally, if the labels indicate that the clothes should be washed before use, the indicated limits will apply to the items after washing, following the instructions marked by the preservation symbols in the label. 4 Limits: 20 ppm for textile products aimed at users younger than 2 years old; 75 ppm for textile products in direct contact with the skin, and 300 ppm for textile products with no direct contact with the skin, mainly for ornamental use. 5 Limits: 20 ppm for textile products aimed at users younger than 2 years old; 75 ppm for textile products in direct contact with the skin, and 300 ppm for leather products with no direct contact with the skin, mainly for ornamental use. This Referece Manual is a free translation from the Spanish Version. 23

10 II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE. FORMALDEHYDE (2/2) Finnish Decree 6 : Decree on Maximum Amounts of Formaldehyde in Certain Textile Products (210/1988), enacted in Polish Regulation 7 : ROZPORZ_DZENIE RADY MINISTRÓW z dnia 19 pa_dziernika 2001 r. w sprawie bezpiecze_stwa i znakowania produktów w_ókienniczych. (Dz. U. z dnia 17 grudnia 2001 r.) (Regulation on Safety and Textile Marking), enacted in Lithuanian Regulation 8 : Hygiene Norm HN 96:2000 (Hygiene Standards and Regulations), enacted in How is it analyzed? Textiles: Japanese Norm: JIS L and/or ISO/EN Norm Leather: Norm ISO/TS 17226: This Norm offers two methods of analysis: ISO/TS :2008 and ISO/TS :2008. Method ISO/TS :2008 is not selective, and thus compounds other than Formaldehyde can interfere with the analysis, therefore the method of analysis must be selected carefully. By using the Standard Operational Procedures 9 : SOP-A-011 Ed.1 and SOP-A-012 Ed Which are the acceptable limits? No detection for textile, fur and leather products for children younger than 3 years old. Maximum 75 ppm for textile, fur and leather products in direct and prolonged contact with the skin, aimed at customers older than 3 years old (clothing, accessories, footwear, and home textiles mainly) Maximum 300 ppm for textile, fur and leather products in no direct or prolonged contact with the skin, aimed at customers older than 3 years old (clothing, accessories, footwear, and home textiles mainly) 6. How can it be avoided? The presence of Formaldehyde, above the levels indicated in point 5 can be prevented: a) By obtaining from our suppliers of chemicals the commitment and guarantee that all the products supplied to be used in the manufacturing process are Formaldehyde-free. 10 b) In those cases where its use is unavoidable, by following the instructions for its use provided by the supplier, so as to comply with the minimum requirements established in clear to wear. c) By washing the clothing items after the printing by corrosion process has been carried out, so as to completely remove any Formaldehyde residue. 6 Limits: 30 ppm for textile products aimed at users younger than 2 years old, 100 ppm for textiles that are usually in contact with the skin, and 300 ppm for textile products that are not usually in contact with the skin (including decorative textiles) 7 Limits: 20 ppm for textile products aimed at users younger than 3 years old; 150 ppm for textile products in direct contact with the skin; 300 ppm for textile products that are not usually in contact with the skin and 500 ppm for decorative products. 8 Limits: 20 ppm for textile products aimed at users younger than 2 years old; 75 ppm for textiles that are usually in contact with the skin and 300 ppm for textile products with no direct contact with the skin. 9 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances. 10 Nowadays the producers of chemicals for the textile industry, such as resins, fixing agents and catalysts, have interesting (in price and properties) alternatives for substituting Formaldehyde containing products. 24 This Referece Manual is a free translation from the Spanish Version.

11 II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE. ARYLAMINES (1/2) 1. What are they? Arylamines are chemical substances, harmful for human health, that can be part of the structure of some dyes Azo Dyes and which, under certain conditions, can be released from them and absorbed by the human body through the action of sweat and/or spit. 2. Where can they be found? Arylamines can be present in colored and printed textile and leather products. Particularly, there is a high risk of finding Arylamines in dyestuff 11, such as: (1) direct dyes for cellulose fibers in very intense red, bright scarlet and/or black shades; (2) dyes for animal fibers and polyamides in red and bright scarlet shades, and (3) prints containing the aforementioned shades. 3. How are they regulated? European Directive 12 : 76/769/EEC and 2003/3/EC, enacted in Spanish Royal Decree 13 : 1406/1989, of November 10 th, which imposes limits for the commercialization and uses of certain dangerous substances. BOE no. 278 of November 20 th, enacted in 2003, and its latest modification: 1114/2006 of September 29 th. Standard and code of mandatory use in the People s Republic of China 14 : GB National General Safety Technical Code for Textile Products, enacted in 2005 and: National Standard of the P.R.C., Leather and Fur - Limit of Harmful Matter GB , enacted in Turkish decree 15 : Communique on Audit of Certain Textile and Clothing Products (Import: 2009/22), enacted in How are they analyzed? Textiles: Norm UNE-EN (2003) for natural fibers and (2003) for synthetic fibers. Leather: Norm ISO/TS 17234: If the presence of aniline and/or 1,4-phenylenediamine has been detected, the corresponding analysis must be repeated using method LFBG B to confirm the presence of aminoazobenzene. By the use of the Standard Operational Procedures 16 : SOP-A-005 Ed.2 and SOP-A-007 Ed Which are the acceptable limits? Maximum 20 ppm for textile products (clothing, footwear, accessories and home textiles) Maximum 30 ppm for leather products (clothing, footwear, accessories and home textiles) 11 A list with those dyestuff which can release Arylamines can be found in Annex II. List of controlled individual substances in Forbidden Dyes section (pages 74 and 75) 12 Limits: 30 ppm for textile and leather products in direct and prolonged contact with the skin or products that can be inserted in the mouth. 13 Limits: 30 ppm ppm for textile and leather products in direct and prolonged contact with the skin or products that can be inserted in the mouth. 14 Limits: 20 ppm for textile products in general and 30 ppm for leather products in general. 15 It is forbidden to import textile, leather, and ready to wear products manufactured using the substances included as Forbidden Dyes in Annex II.List of Controlled Individual Substances (pages 74 and 75) 16 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances specified. These procedures are reserved to laboratories accredited by Inditex s Corporate Social Responsibility Department. This Referece Manual is a free translation from the Spanish Version. 25

12 II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE. ARYLAMINES (2/2) 6. How can they be avoided? The presence of Arylamines, above the levels indicated in point 5, can be avoided by applying the following preventive measures: a) By obtaining from our suppliers the commitment that the dyes and pigments they supply will not give off this type of substances Arylamines 17 at any stage of the production process, according to the limits established in point 5. b) By using only dyes and/or pigments made by internationally reputed suppliers, who show public commitments and compliance with the most stringent product health laws for all the dyes and pigments they market See Annex II: List of Controlled Individual Substances (pages 73, 74, 75 and 76) 18 Information about this can be obtained from ETAD Ecological Toxicological Association of Dyestuffs ( 26 This Referece Manual is a free translation from the Spanish Version.

13 II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE. PHENOLS: PENTACHLOROPHENOL (PCP) AND TETRACHLOROPHENOL (TeCP) 1. What are they? Phenols PCP (CAS No.: ) and TeCP (CAS No.: ) are polychlorinated compounds that act as: (1) preservatives for vegetable and animal raw materials and (2) insecticides. 2. Where can they be found? PCP and TeCP can be found in fungicides used for textile and leather products and wood (unprocessed textiles and/or leather are the items that present a higher risk of containing these substances) 3. How are they regulated? Swiss Ordinance 19 : Ordinance on the Reduction of Risks linked to Chemical Products (ORRChim) (Verordnung vom 18. Mai 2005 zur Reduktion von Risiken beim Umgang mit bestimmten besonders gefährlichen Stoffen, Zubereitungen und Gegenständen (Chemikalien-Risikoreduktions-Verordnung, ChemRRV), enacted in Polish Regulation 20 : ROZPORZ_DZENIE RADY MINISTRÓW z dnia 19 pa_dziernika 2001 r. w sprawie bezpiecze_stwa i znakowania produktów w_ókienniczych. (Dz. U. z dnia 17 grudnia 2001 r.) (Regulation on safety and textile marking), enacted in South Korean Law 21 : Safety Confirmation Notice (Notice No ) Annex 4, enacted in How are they analized? Textiles: By Chromatographic Methods and/or German Method 64 LFGB BVL B Leather: Norm ISO/TS 17070:2006. By the use of the Standard Operational Procedures 22 : SOP-A-009 Ed.1 and SOP-A-010 Ed Which is the acceptable limit? No detection for all textile and leather/fur products (clothing, accessories, footwear, and home textiles mainly) 6. How can they be avoided? The presence of PCP and TeCP, above the levels indicated in point 5, can be avoided by applying the following preventive measures: a) By obtaining from our suppliers the commitment that the chemicals they supply: (1) will not contain PCP nor TeCP, nor their respective salts, (2) that these chemicals will not be transferred to the final product at any stage of the production process. b) By avoiding contamination in the leather processing due to the use of drums in which Phenols are used Limits: PCP, TeCP, any of their derived salts, and compounds of pentachlorophenoxide and/or tetrachlorophenoxide are forbidden in textile and leather products. 20 Limits: PCP is forbidden in textile products used in direct and prolonged contact with the skin and/or in products that can be introduced in the mouth. 21 Limits: 0.05 ppm for PCP and TeCP, including their salts, in textile products for babies; 0.5 ppm for PCP and TeCP, including their salts, in underwear, and 5 ppm PCP and TeCP, including their salts, in bed linen. 22 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances specified. These procedures are reserved to laboratories accredited by Inditex s Corporate Social Responsibility Department. 23 Wood has the tendency to absorb the products used on it and liberate them afterwards. This Referece Manual is a free translation from the Spanish Version. 27

14 II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE. CADMIUM (1/2) 1. What is it? Cadmium (CAS No.: ) is a heavy metal that is used as: (1) pigment in plastic materials; (2) ultraviolet stabilizing agent to avoid degradation of plastics; and (3) brightening and antioxidizing agent for metallic accessories. 2. Where can it be found? Cadmium can be found in a great variety of textile and leather/fur products due to its presence in the composition of several chemicals used in the textile and leather industries, such as: a) Stabilizers for plastic materials, such as: Polyvinyl Chloride (PVC), Polyurethane and Polyethylene. b) Pigments used in dyes, prints and tinctures for plastics (pigments with a higher probability of containing Cadmium are those of red, orange, yellow or green colors) c) Cadmium coatings in metallic accessories. 3. How is it regulated? Swiss Ordinance 24 : Ordinance on the Reduction of the Risks linked to the Use of Particularly Dangerous Substances, Preparations and Objects (Ordinance on the Reduction of Risks linked to Chemical Products (ORRChim)) Draft for consultation of The Swiss Federal Council), enacted in Polish Regulation 25 : ROZPORZ_DZENIE RADY MINISTRÓW z dnia 19 pa_dziernika 2001 r. w sprawie bezpiecze_stwa i znakowania produktów w_ókienniczych. (Dz. U. z dnia 17 grudnia 2001 r.) (Regulation on safety and textile marking) and The Ordinance of the Council for Ministers on Safety and Labelling of Textile Products of 19 October 2001 enacted in Swedish Ordinance 26 : Section 3 of the Ordinance (1998:944) on Prohibitions Etc. in Connection with Handling, Importing and Exporting Chemical Products, enacted in Austrian Ordinance 27 : Ordinance of February 18 th, 1994 on Bans and Restrictions of Cadmium and its Compounds, Including White Lead, Federal Law Gazette No 855/1993 enacted in Decree of the Netherlands 28 : Cadmium Decree 1999 (Chemical Substances Act) enacted in Danish Statutory Ordinance 29 : Statutory Order No.1199 of December 23 th, 1992 on the Prohibition of Sale, Import and Manufacture of Cadmium Containing Products, enacted in Limits: Its use for metals employed in plating is forbidden. 100 ppm for products and accessories made from Cadmium-containing plastics; 250 ppm for metals that use Zinc as plating; 100 ppm for paints and varnishes and painted or varnished products and accessories. 25 Limits: Forbidden for products that are in direct and prolonged contact with the skin or that can be introduced in the mouth. 100 ppm for colored plastic products and accessories; 100 ppm for stabilized PVC; 100 ppm in paints (except paints with a high Zinc content, in which case the limit is 1,000 ppm) 26 Limits: Forbidden for any products that contains Cadmium as a dye, pigment, stabilizer and or galvanizer. 27 Limits: 100 ppm for all products in which Cadmium has been used as pigment and/or stabilizer, among other functions; 100 ppm for paints (except in those paints with a high Zinc content, in which case the limit is 1,000 ppm), and 250 ppm for metals used in Cadmium plating. 28 Limits: 100 ppm for any products that contain Cadmium as a dye, pigment, stabilizer and/or galvanizer. 29 Limits: 75 ppm for all products, and their parts, for which Cadmium had been used as surface-treating agent or as a pigment in the dyeing or stabilization of plastics. 28 This Referece Manual is a free translation from the Spanish Version.

15 II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE. CADMIUM (2/2) 4. How is it analyzed? Textiles, Leather, Plastic and Metals: the Total Cadmium amount is determined following analytical procedures that include microwave digestion with HNO 3 /H 2 O 2, followed by quantification by Inductively Coupled Plasma-Mass Spectrometry (ICP-MS) By the use of the Standard Operational Procedures 30 : SOP-A-001 Ed.3 and SOP-A-002 Ed Which are the acceptable limits? Maximum 1 ppm for textile and leather products (clothing, footwear, accessories and home textiles, mainly) Maximum 75 ppm for metallic and plastic parts (clothing, footwear, accessories and home textiles, mainly) Maximum 75 ppm for surface paints and coatings (metallic and plastic parts and accessories in clothing, footwear, accessories and home textiles, mainly) 6. How can it be avoided? The presence of Cadmium, above the levels indicated in point 5, can be avoided by: a) Not using Cadmium as a plastic stabilizer or as a brightening agent for metals. b) Obtaining from our suppliers of dyes and pigments the commitment and guarantee that the dyes and pigments supplied do not contain Cadmium above the levels indicated in point 5 above. c) By using only dyes and/or pigments made by internationally reputed suppliers, who show public commitments and compliance with the most stringent product health laws for all those dyes and pigments they market These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances specified. These procedures are reserved to laboratories accredited by Inditex s Corporate Social Responsibility Department. 31 Information about this can be obtained from ETAD Ecological Toxicological Association of Dyestuffs ( This Referece Manual is a free translation from the Spanish Version. 29

16 II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE. LEAD (1/2) 1. What is it? Lead (CAS No.: ) is a heavy metal that is used as: (1) metal; (2) alloy for the production of accessories; and (3) pigment. 2. Where can it be found? Lead can be found in a great variety of textile and leather/fur products, such as: a) accessories and/or parts made from metals or alloys, and b) some components of a variety of chemicals used in the textile and leather industries, such as: pigments used in paints, prints and plastics, among others (pigments with a higher probability of containing Lead are those of red, orange, yellow or green colors) 3. How is it regulated? Swiss Ordinance 32 : Ordinance on the Reduction of the Risks linked to the Use of Particularly Dangerous Substances, Preparations and Objects (Ordinance on the Reduction of Risks linked to Chemical Products (ORRChim) Draft for consultation of The Swiss Federal Council), enacted in Danish Statutory Ordinance 33 : Statutory Order no of 1997 (as amended) and Statutory Order no of 2007 on Prohibition, Import and Sale of Products Containing Lead, enacted in United States Act 34 : Consumer Product Safety Improvement Act (CPSIA), enacted in California Law 35 : The Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65), enacted in Polish Regulation 36 : The Ordinance of the Council for Ministers on Safety and Labelling of Textile Products of October 19 th 2001 enacted in How is it analyzed? Textiles, Leather, Plastic and Metals: the Total Lead amount is determined following analytical procedures that include microwave digestion with HNO 3 /H 2 O 2, followed by quantification by Inductively Coupled Plasma-Mass Spectrometry (ICP-MS) Paints and Surface Coatings: ASTM Method E1645 & E1613. By the use of the Standard Operational Procedures 37 : SOP-A-001 Ed.3 and SOP-A-002 Ed Limits: 100 ppm for paints and varnishes and painted or varnished products and accessories, mainly. 33 Limits: Forbidden for any Lead-containing product. 34 Limits: 600 ppm (300 ppm since August 14 th 2009 and 100 ppm since August 14 th 2011) for Lead in substrates and 600 ppm (90 ppm since August 14 th 2009) for Lead in paints and surface coatings. 35 Limits: 30 ppm for Lead in clothing made with PVC (including gloves), Neoprene and/or plastic materials and rainwear; 200 ppm for Lead in Non-fabric component (zippers, drawstrings, snaps, buttons, among others); 90 ppm for Lead in PVC in personal carrying products (bags, purses, among others), 100 ppm for Lead in any other fabric than PVC in personal carrying products (bags, purses, among others); 90 ppm for Lead in exterior surface coating in personal carrying products (bags, purses, among others); 90 ppm for Lead in leather in personal carrying products (bags, purses, among others); and 300 ppm for other materials (except ZIrconia, glass or rhinestone) in personal carrying products (bags, purses, among others) 36 Limits: Forbidden for products that are in direct and prolonged contact with the skin or that can be introduced in the mouth. 37 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances specified. These procedures are reserved to laboratories accredited by Inditex s Corporate Social Responsibility Department. 30 This Referece Manual is a free translation from the Spanish Version.

17 II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE. LEAD (2/2) 5. Which are the acceptable limits? 1) Maximum 100 ppm for textile products without direct contact with the skin and aimed at customers older than 3 years old; metallic and plastic elements (parts, accessories, imitation leather, plastic coatings for fur and leather and positional prints, mainly) 2) Maximum 90 ppm for all painted materials and those with surface coatings: metals, plastics, wood, raffia, among other (clothing, footwear, accessories and home textiles, mainly) 3) Maximum 1ppm for all textile and leather products aimed at children younger than 3 years old, and for textile and leather products in direct and prolonged contact with the skin aimed at customers older than 3 years old (clothing, footwear, accessories and home textiles, mainly) 4) Maximum 30 ppm for clothing made with PVC, Neoprene and other plastic materials. 6. How can it be avoided? The presence of Lead, above the levels indicated in point 5, can be avoided by: a) Not using Lead as a base metal or any of its alloys. b) Obtaining from our suppliers of dyes and pigments the commitment and guarantee that the dyes and pigments supplied do not contain Lead above the levels indicated in point 5 above. c) By using only dyes and/or pigments made by internationally reputed suppliers, who show public commitments and compliance with the most stringent product health laws for all those dyes and pigments they market Information about this can be obtained from ETAD Ecological Toxicological Association of Dyestuffs ( This Referece Manual is a free translation from the Spanish Version. 31

18 II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE. MERCURY. 1. What is it? Mercury (CAS No.: ) is a heavy metal that can be found in the solid, liquid or gas states (in organic or inorganic compounds) 2. Where can it be found? Mercury can be found in textile and leather/fur products in general. The main causes for the presence of Mercury are: a) Contamination during the production of sodium hydroxide and/or sodium chloride using the Mercury-cell process. b) Contamination during the extrusion of polymers. c) Its use as a preservative. d) Contamination from the water used during the processing of textiles and leather. 3. How is it regulated? Japanese Law 39 : Law for the Control of Household Products containing Harmful Substances, enacted in Polish Ordinance 40 Safety and Labelling of Textile Products October 19 th 2001, enacted in Swiss Ordinance 41 Ordinance on Risk Reduction related to Chemical Products (ORRChim) of May 18 th 2005 as amended, beyond the EU Restrictions of the Directive 76/769/EEC, 89/101/EC enacted in How is it analyzed? Textiles, Leather, Plastic and Metals: the Total Mercury amount is determined following analytical procedures that include microwave digestion with HNO 3 /H 2 O 2, followed by quantification by Inductively Coupled Plasma-Mass Spectrometry (ICP-MS) By the use of the Standard Operational Procedures 42 : SOP-A-001 Ed.3 and SOP-A-002 Ed Which are the acceptable limits? No detection for textile, synthetic and leather/fur products (clothing, footwear, accessories and home textiles, mainly) 6. How can it be avoided? The presence of Mercury compounds can be avoided by obtaining from our suppliers of dyes and pigments the commitment and guarantee that the dyes and pigments supplied do not contain Mercury, nor do they transmit it to the final product, above the levels indicated in point 5 above. 39 Limits: 1 ppm for organic compounds of Mercury for textile products, such as: diapers, aprons, bibs, underwear, stockings, socks and gloves, mainly. 40 Limits: No detection in textiles in direct and prolonged contact with the skin and/or that can be introduced in the mouth, such as: underwear, bed linen, towels, hats, diapers, athletic footwear, gloves, bags, purses, wallets, cloth toys, textile parts and accesories for babies, and carpets, mainly. 41 Limits: No detection in all products. 42 These procedures are owned by Inditex S.A.and have been developed by the University of Santiago de Compostela. They describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances specified. These procedures are reserved to laboratories accredited by Inditex s Corporate Social Responsibility Department. 32 This Referece Manual is a free translation from the Spanish Version.

19 II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE. CHROMIUM 1. What is it? Chromium (CAS No.: ) is a heavy metal that can be present as pure metal or as Chromium compounds and/or complexes such as salts and dyes. 2. Where can it be found? Chromium can be found in textile and leather products, due to its presence in the composition of dye stuff and chemical auxiliaries used in the textile and leather industries, such as: a) Dye stuff for Wool, Silk and Polyamide (Nylon) textiles especially for dark shades. b) Dyeing Fixative agents and other dyeing additives for after-treatments in order to improve colour fastness specially for dark shades. c) Chromium salts used for tanning of leather ( for limits see Chromium (VI) ) 3. How is it regulated? Chinese Mandatory Standard 43 : China FZ/T (Textile Industry Standard of the People s Republic of China ISC Y76), enacted in How is it analyzed? Textiles: the Total Chromium amount is determined following analytical procedures that include microwave digestion with HNO 3 /H 2 O 2, followed by quantification by Inductively Coupled Plasma-Mass Spectrometry (ICP-MS) and/or GB/T Textiles-Determination of heavy metals Part 1: Atomic Absorption Spectrophotometry. By the use of the Standard Operational Standards 44 : SOP-A-001 Ed.3 and SOP-A-002 Ed Which are the acceptable limits? 1.0 ppm for textile products intended for children younger than 3 years old (clothing, footwear, accessories, home textiles and adornments, mainly) 6. How can it be avoided? The presence of Chromium, above the levels indicated in point 5, can be avoided by applying the following preventive measures: a) For Textiles (except Polyamide, Polyamide blends & worsted wool) by obtaining from our suppliers the commitment and guarantee that all the products used in the manufacturing process, mainly dyestuff 45 and colorant additives, are Chromium-free. b) For Polyamide, Polyamide blends & worsted wool - most important for dark shades by exhaustive control of dyestuff concentration after consulting your dyestuff supplier to make sure the dye is bound strongly enough and not using more Chromium than needed. 43 Limits: 1 ppm for total content of Chromium for textile products. 44 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances specified. These procedures are reserved to laboratories accredited by Inditex s Corporate Social Responsibility Department. 45 Most Chromium containing dyes can be classified in one of the following categories: I.Metal complex dyes 1:1 metal complex. 2:1 metal complex. II.Mordant dyes Metachrome. After-chrome This Referece Manual is a free translation from the Spanish Version. 33

20 II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE. CHROMIUM (VI) 1. What is it? Chromium (CAS NO.: ) is a heavy metal that, in its (VI) oxidation state, is harmful to humans. Under certain circumstances Chromium (VI) salts can be formed from some chemicals used in leather tanning. 2. Where can it be found? It can be found in products made of leather, such as: shoes, clothing and accesories. 3. How is it regulated? German Law 46 : 30 of the Food and Commodities Law (LMBG) (1/1/96), enacted in How is it analyzed? Leather/Fur and Textiles: Norm ISO 17075:2007. By the use of the Operational Standard Procedures 47 : SOP-A-013 Ed.2 and SOP-A-014 Ed Which are the acceptable limits? Maximum 3 ppm for textiles and leather/fur products (garments, shoes, accessories and home textiles in direct and prolonged contact with the skin) 6. How can it be avoided? The presence of Chromium (VI), above the levels indicated point 5, can be avoided by: a) Substituting tanning processes involving Chromium by other Chromium-free tanning processes, that use different tanning agents, such as: Glutaraldehyde, Phosphonium salts, Aluminum, Zirconium, and/or Titanium (a commonly used process in the tanning sector, technically denominated as wet white tanning) b) If Chromium is used in the tanning processes, its presence in the final products must be avoided by: Performing enough washes at the final stage of the tanning procces, in order to avoid high concentrations of Chromium (III) in the final tanned leather. Avoiding the use of materials with a high oxidizing power, such as: unsaturated fats of fish oil. Ensuring that the Chromium (III) used in the tanning process comes from a provider that guarantees a clean tanning process and free of Chromium (VI) Using neutralizing agents with reducing power. And, finally, preventing that the ph of the final product be higher than 6,5. 46 Limits: The corresponding authorities advise that Chromium (VI) concentrations higher that 3 ppm must be avoided for those textile and leather products destined to be in direct contact with the skin. 47 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances specified. These procedures are reserved to laboratories accredited by Inditex s Corporate Social Responsibility Department. 34 This Referece Manual is a free translation from the Spanish Version.

21 II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE. NICKEL. 1. What is it? Nickel (CAS NO: ) is a heavy metal that can be used as: (1) a brightening agent for metallic parts, and (2) an antioxidizing agent. 2. Where can it be found? Nickel can be present mainly in shiny metallic parts and accesories. 3. How is it regulated? European Directive 48 : 76/769/EEC, 94/27/EC and 2004/96/EC, enacted in Spanish Royal Decree 49 : ROYAL DECREE 1406/1989, of November 10th, in which limitations are imposed to the commercialization and use of certain dangerous substances and mixtures. BOE 278 of November 20th, modified subsequently by Decree 1114/2006 enacted in Norwegian Regulation 50 : The Regulations No. 922 of June 1 st 2004, as amended, enacted in How is it analyzed? Metals: (1) Norm EN for accelerated wear and corrosion, and later (2) Norm EN 1811:1999 to evaluate Nickel release. By the use of the Standard Operational Procedures 51 : SOP-A-004 Ed.2 and SOP-A-002 Ed Which are the acceptable limits? Maximum release 0.5 µg/cm 2 /week for all metallic garments and accesories. 6. How can it be avoided? The presence of Nickel, above the levels indicated in point 5, can be avoided by obtaining from our suppliers the commitment and guarantee that all the products they supply are tested in accordance with the method contemplated in point 4 above. 48 Limits: Maximum release 0.5 µg/cm 2 /week for those products in direct and prolonged contact with the skin: (1) buttons, buckles, rivets, zippers and metallic labels which will be in direct and prolonged contact with the skin; (2) jewels and (3) watches, among others. 49 Limits: Maximum release 0.5 µg/cm 2 /week for those products in direct and prolonged contact with the skin: (1) buttons, buckles, rivets, zippers and metallic labels which will be in direct and prolonged contact with the skin; (2) jewels and (3) watches, among others. 50 Limits: Maximum release 0.5 µg/cm 2 /week for those products in direct and prolonged contact with the skin: (1) buttons, buckles, rivets, zippers and metallic labels which will be in direct and prolonged contact with the skin; (2) jewels, (3) watches and (4) glasses and chains for glasses, among others. 51 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances specified. These procedures are reserved to laboratories accredited by Inditex s Corporate Social Responsibility Department. This Referece Manual is a free translation from the Spanish Version. 35

22 II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE. PHTHALATES. 1. What are they? Phthalates are chemical substances with plastifying properties added mainly to plastics and to PVC to make them flexible. 2. Where can they be found? Phthalates can be found in a great variety of textile and leather industry products, such as: a) Flexible plastics. b) Positional prints of the plastisol type. c) Surface coatings. d) And as demolding agent for plastics. 3. How are they regulated? European Directive 52 : 2005/84/CE, enacted in Spanish Royal Decree 53 : ROYAL DECREE 1406/1989, of November 10 th, in which limitations are imposed to the commercialization and use of certain dangerous substances and mixtures. BOE 278 of November 20th, modified subsequently by Decree 1114/2006 enacted in South Korean Law 54 : Korean Agency for Technology and Standards Issued a Self Regulatory Safety Confirmation Notice (Notice No ), enacted in Icelandic Regulation 55 : Regulations on Restriction of the Manufacture, Importation and Distribution of Toys and Objects Containing Phthalates, enacted in Italian Decree 56 : Decree on Phthalates Adopted on September 30th 1999, enacted in How are they analyzed? Textiles, Leather, Plastics: By Chromatographic Methods. By the use of the Standard Operational Procedure 57 SOP-A-016 Ed Which are the acceptable limits? No detection for all textile, plastic and synthetic products (clothing, Footwear, accessories and home textiles, mainly) 6. How can they be avoided? The presence of Phthalates, above the levels indicated in point 5, can be avoided by: a) Substituting solvent based prints (plastisol prints) by water-based prints. b) Avoiding all possible cross-contamination in the printing lines for those processes using water-based technologies from those using water-based technologies, in order to do so, products and machinery used in printing with both technologies must be separated/isolated. c) Obtaining from our suppliers of chemicals and/or plastic materials the commitment and guarantee that the products supplied do not contain neither PVC nor Phthalates above the levels indicated in point 5 above. 52 Limits: 1,000 ppm (DEHP, DBP and BBP) for toys and products for children younger than 3 years old, and 1,000 ppm (DINP, DIDP and DNOP) for toys and products for children younger than 3 years old that can be inserted into the mouth. 53 Limits: 1,000 ppm (DNOP, DEHP, BBP, DBP) in coated textiles, rubber and plastics for babies, mainly. 54 Limits: 500 ppm for products destined for children younger than 3 years old that can be inserted into the mouth (teething aids, feeding bottles and bath accesories, mainly) 55 Limits: 500 ppm for toys aimed for children younger than 3 years old which, according to their nature or design, can be inserted into the mouth. 56 See Annex II: List of Individual Controlled Substances (pages 73, 74, 75 and 76) 57 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances specified. These procedures are reserved to laboratories accredited by Inditex s Corporate Social Responsibility Department. 36 This Referece Manual is a free translation from the Spanish Version.

23 II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE. POLYBROMINATED FIRE-RESISTANT COMPOUNDS. 1. What are they? Polybrominated Fire-Resistant Compounds are chemical substances that are added to textile fibers to act as flame retardants. 2. Where can they be found? Polybrominated Fire-Resistant Compounds can be found in home textile products and in garments for special purposes, such as: Individual Protection Equipment (IPEs) and flame-resistant sleepwear, among others. 3. How are they regulated? European Directive 58 : 2003/11/EC that modifies 76/769/EEC, enacted in Japanese Law 59 : Law for the Control of Household Products Containing Harmful Substances, enacted in Swedish Ordinance 60 : KIFS 1998:8, enacted in How are they analyzed? Textiles: By Chromatographic Methods. By the use of the Standard Operational Procedures 61 : SOP-A-020 Ed.2 and SOP-A-021 Ed Which are the acceptable limits? No detection of: TRIS, TEPA, PBB and BBPP for all types of textile products (clothing, footwear, accessories and home textiles, mainly) Maximum ppm of: PentaBDE, DecaBDE and OctaDBE, for all types of textile products (clothing, footwear, accessories and home textiles, mainly) 6. How can they be avoided? The presence of Polybrominated Fire-Resistant Compounds, above the levels indicated in point 5, can be avoided by: a) Using only fire-resistant compounds made by internationally reputed suppliers, who show public commitments and compliance with the most stringent product health laws for all those dyes and pigments they market. b) Obtaining from our suppliers the commitment and guarantee that the chemicals supplied do not contain Polybrominated Fire-Resistant Compounds above the levels indicated in point 5 above. 58 Limits: ppm (Penta BDE, and OctaDBE) for all products, and forbidden (TRIS, TEPA and PBB) for those products in direct contact with the skin, such as: underwear and/or bed linen, mainly. 59 Limits: Forbidden (TRIS, TEPA, PBB and BBPP) in textiles for sleepwear, bed linen, curtains and carpets/rugs, mainly. 60 Limits: ppm (PentaBDE, OctaDBE and DecaDBE) for all products, and forbidden (TRIS, TEPA and PBB) for those products in direct contact with the skin, such as: underwear and/or bed linen, mainly. 61 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances specified. These procedures are reserved to laboratories accredited by Inditex s Corporate Social Responsibility Department. This Referece Manual is a free translation from the Spanish Version. 37

24 II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE. PESTICIDES. 1. What are they? Pesticides are chemical substances usually employed in the textile and leather industries as: (1) insecticides for wool fibers, (2) insecticides and herbicides for growing vegetable fibers, and (3) preservatives for natural raw materials. 2. Where can they be found? Pesticides can be present in: (1) natural fibers of vegetable origin, such as: cotton, flax, and/or linen, (2) natural fibers of animal origin, such as: wool and silk, and (3) in furs. 3. How are they regulated? Swiss Ordinance 62 : Ordinance on Risk Reduction Related to the Use of Certain Particularly Dangerous Substances, Preparations and Articles (Ordinance on Risk Reduction Related to Chemical Products (ORRChim), enacted in Polish Ordinance 63 : The Ordinance of the Council for Ministers on safety and labelling of textile products of October 19 th 2001 enacted in Finnish Decree 64 : Government Decree on Persistent Organic Substances (735/2002), issued in Helsinki on August 22 nd, enacted in Japanese Law 65 : Law for the Control of Household Products containing Harmful Substances, enacted in How are they analyzed? Textiles and Furs: By Chromatographic Methods. 5. Which are the acceptable limits? No detection for those Pesticides included in Annex II, for all types of textile and leather/fur products (clothing, footwear, accessories and home textiles, mainly) 6. How can they be avoided? The presence of the regulated Pesticides can be avoided, among other measures, by obtaining from our suppliers the commitment and guarantee that all the chemicals that have been used for the growing of vegetable fibers and for the preservation of animal fibers and leather, do not contain any of the forbidden Pesticides Limits: Those Pesticides listed in the ordinance and those containing Mercury are forbidden in textiles and leather/fur products. 63 Limits: The use of Arsenic and Mercury in textile products in direct and prolonged contact with the skin, such as: underwear, sheets, towels, hats, footwear, textile toys and carpets/rugs, mainly, is forbidden. 64 Limits: Aldrine, DDT (1,1,1 trichlorine-2,2 bis (4-chlorophenyl)ethane), Dieldrine, Endrine, Hexachlorobenzene (HCB), Heptachlorine, Chlordane, Mirex, Polychlorinated biphenyls and Toxaphene are forbidden in all articles. 65 Limits: 30 ppm for Dieldrin in textile products, such as: diapers, underwear, sleepwear, gloves, socks, stockings, middlewear and outerwear, hats, caps, sheets and rugs. 66 See Annex II: List of Individual Controlled Substances (pages 73, 74, 75 and 76) 38 This Referece Manual is a free translation from the Spanish Version.

25 II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE. SHORT-CHAIN CHLORINATED PARAFFINS. 1. What are they? Short Chain Chlorinated Paraffins (CAS NO ) are chemical substances mainly used in the leather industry as a greasing agent for use after the tanning procces and also as flame-resistant and plastifying agents. 2. Where can they be found? In leather products, such as: footwear, clothes and accessories. In textiles, rubbers and plastics, as flame-resistant agents. In surface paints and coatings, as varnishes. 3. How are they regulated? Swiss Ordinance 67 : The Ordinance on Risk Reduction related to Chemical Products (ORRChim) of May 18 th 2005, enacted in How are they analyzed? Leather : By Chromatographic Methods. By the use of the Standard Operational Procedure 68 SOP-A-027 Ed.1 5. Which are the acceptable limits? Maximum 1000 ppm for textile, leather and plastic products (clothing, footwear, accessories and home textiles, mainly) 6. How can they be avoided? The presence of the regulated Short Chain Chlorinated Paraffins can be avoided by, among other measures, obtaining from our suppliers the commitment and guarantee that they have not used these substances as (1) greasing agents for leather, (2) flame-resistant agents for textiles and plastics, and/or (3) plastifying agent for paints. 67 Limits: 1% in paints, varnishes, plastics, rubbers, textiles, leather-processing products and metal-processing products, mainly. 68 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances specified. These procedures are reserved to laboratories accredited by Inditex s Corporate Social Responsibility Department. This Referece Manual is a free translation from the Spanish Version. 39