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This document summarises lessons learned from the various project activities in three sectors: electrical and electronic equipment (EEE); building and construction; and toys. It also formulates key messages addressed to different stakeholder groups and provides links to guidance and tools developed under the GEF project

The video covers the crucial issues surrounding chemical policies in today's world, the unseen effects of chemicals in everyday life and the global push for policies that foster sustainable practices. The video highlights the challenges and innovative solutions that aim to to protect our environment and health, setting the stage for a greener, safer and sustainable future.

When it comes to exposure to chemicals of concern (CoC), children are one of the most vulnerable populations due to their rapid metabolic rate, high surface-area-to-body-weight ratio, and rapid growth of organs and tissues. Despite this, some CoC have been used in the manufacturing and production of toys. Young children put toys in their mouths and chew on them. They can also be exposed through inhalation and contact with the skin. Parents should not have to worry whether the toys their children play with pose a risk to their health.

Like many consumer products, toys are composed of a range of materials, such as plastics, textiles, and metals. The chemical composition of toys is often not known, and some of the chemicals that are present in toys, may have hazardous properties. Increased circularity and recycling rates of materials, for example, can lead to the introduction of hazardous chemicals as unintentional contaminants to the toys value chain. CoC in toys often enter the lifecycle during plastic production, painting, and coating, or through recycled plastic materials.

While CoC provide toys with certain functions such as fragrance, color, and plasticity, exposure can result in long-term health effects for children, interfering with the hormone system or cognitive development. Such chemicals include mercury, lead, arsenic, and cadmium. Lead affects brain development. Cadmium (found, for example, in batteries) is an endocrine disruptor that affects reproductive development. Persistent organic pollutants (POPs), like phthalates, are associated with higher rates of childhood cancer and endocrine disruption.

Since children are more vulnerable to the health impacts of such CoC, their use in toys is regulated, although that does not mean that, in practice, such chemicals are not present. For this reason, the Strategic Alliance for International Chemicals Management (SAICM) considers toys a priority sector under its Chemicals in Products (CiP) Programme, which aims to accelerate the adoption of measures by value chain stakeholders, including governments, to track and control chemicals in the toy supply chain. 

This policy brief explores efforts and initiatives to advance the issue of CoC in toys, particularly under the Global Environment Facility (GEF)-funded project on Global Best Practices on Emerging Chemical Policy Issues of Concern under SAICM, launched in 2019. The project focuses on: lead in paint; chemicals in products, including toys, electronics, textiles, and building and construction; and knowledge and stakeholder engagement. Implemented in over 40 countries, the project also seeks to contribute to the 2030 Agenda for Sustainable Development and the achievement of the SDGs. The brief highlights relevant tools and reports, as well as recommendations and opportunities the newly agreed Global Framework on Chemicals, the successor to SAICM, provides.

 Impacts of CoC in toys

In 2006, one of every three toys in a study of 1,500 had potentially harmful lead, arsenic, and mercury. A four-year old boy in Minnesota, US, accidentally swallowed a heart-shaped locket that had broken off from a bracelet. Instead of passing harmlessly through the boy’s system, the locket contained a high concentration of lead. The boy died.

In 2021, US Customs and Border Protection seized a shipment of children’s toys from China, determining the items were “excessively” coated in unsafe levels of heavy metals, including lead and cadmium. The shipment included nearly 300 packages of Lagori 7 Stones, a popular children’s game in India where a ball is thrown at seven stacked square “stones.”

In 2022, a report published by the Campaign for Healthier Solutions found that harmful chemicals in toys were prevalent in US discount stores. Of the more than 200 tested products, more than half had at least one CoC, such as lead and/or phthalates, present in colorful baby toys and Disney-themed headphones, for example. Costume products like fake teeth made of polyvinyl chloride (PVC) can contain endocrine-disrupting chemicals, potentially harming reproductive and cognitive development.

More recently, the EU announced its aim of banning harmful chemicals, especially those that disrupt growth hormones, in imported toys under new rules proposed by the European Commission in July 2023. The Commission’s proposed Toy Safety Regulation aims to address loopholes in existing legislation that dictates safety standards in toys sold in the EU. For some chemicals, regulations in different countries are aligned, but differences remain in many areas between chemical requirements of toy safety policies. For example, the EU Toy Safety Directive severely restricts chemicals known, presumed, or suspected to have carcinogenic, mutagenic, or reprotoxic effects for use in toys. This differs from a chemical-by-chemical approach applied in many other toy safety regulations.

SAICM efforts to address CoC in toys

Although highly regulated in the EU, the US, and other developed countries, CoC in low- and middle-income countries (LMICs) are another matter. A 2021 SAICM/GEF project report reviews chemicals-related toy safety policies and regulations in selected LMICs, providing an overview of safety policies addressing CoC in toys and detailing activities SAICM should prioritize in those countries. The report focuses on those LMICs with the highest total import value of toys from China. The middle-income countries (MICs) reviewed (Brazil, India, Indonesia, Kazakhstan, Malaysia, Mexico, Philippines, the Russian Federation, Thailand, and Viet Nam) have toy safety policies with provisions for the content of certain chemicals in toys, namely on material-specific migration limits for antimony, arsenic, barium, cadmium, chromium, lead, and selenium. In the low-income countries (LICs) reviewed, Tajikistan and Tanzania have some existing regulations. However, no information was found regarding toy safety policies in the other LICs, including Benin, the Democratic Republic of Congo (DRC), Guinea, the Democratic People’s Republic of Korea, Madagascar, Mozambique, Syria, and Yemen.

Other project outputs include a report on regulations for chemicals in toys in China, which provides an overview of related regulations that dictate the use of chemicals in toys produced in China, and a USEtox toys module, developed to help producers assess chemicals used in toy components and potential risks for children. USEtox is a scientific consensus model for characterizing human and ecotoxicological impacts of chemicals.

In addition, a 2021 UN Environment Programme (UNEP)-commissioned report, undertaken by the Technical University of Denmark (DTU), found that 25% of children’s toys contain harmful chemicals. According to the report, chemical additives used in plastic toys that provide certain properties, such as hardness or elasticity, include plasticizers or softeners, flame retardants, surface-active substances (to create foam), stabilizers, colorants, and fragrances. While softer plastic toys lead to higher exposure to harmful chemicals than hard toys, exposure from inhalation is more prevalent than touching since children inhale chemicals diffusing out of all toys in the room. The report recommends ensuring children’s rooms are ventilated to avoid the inhalation of dangerous chemicals. Acknowledging that avoiding all plastic toy use would be difficult, it recommends prioritizing substances for phase out in toys and replacing them with safer alternatives.

The study explains that:

• since most plastic toys are not labelled, parents do not know whether an item is harmful;
• currently, no international agreement exists regarding which substances should be banned from use in toys;
• regulations and labeling schemes differ across regions and countries; and
• existing priority substance lists lack information on levels at which use of a CoC is safe and sustainable in product and material applications.

Researchers combined reported chemical content in toy materials with material characteristics and toy use patterns, such as how long a child plays with a toy, whether he/she puts it in the mouth, and the number of toys per household per child. Based on this, the study introduces a new metric to benchmark chemical content in toys, based on exposure and risk.

A SAICM policy brief aims to enhance understanding of CoC in products, and efforts to reduce them in toys, textiles, buildings and construction, and electronics. It notes that transparency of information about chemicals in global supply chains has been an emerging policy issue under SAICM since 2009. This led to UNEP’s CiP programme in 2015, under which SAICM proposed cooperative actions to address information gaps regarding the presence of hazardous chemicals in the four sectors.

The policy brief details measures to reduce CoC through:

• legislation and information system tools, such as regulations, standards, and certification mechanisms;
• holistic tools that consider the entire value chain, such as life cycle assessment tools and eco-innovation;
• production tools that seek to minimize exposure and focus on cleaner and responsible production; and
• consumption tools that focus on consumer behavior, including sustainable public procurement and ecolabels. 

UNEP, in collaboration with the Baltic Environment Forum and within the framework of the SAICM/GEF project, developed an International Chemicals Management Toolkit for the Toys Supply Chain to facilitate regulatory compliance in the toy sector. Providing useful information, guidance, and tools, the toolkit aims to support stakeholders in the toys industry at multiple stages of the value chain, including:

• manufacturers of toys or toy parts from plastic pellets;
• assemblers of toys from individual parts;
• importers and retailers of toy products; and
• policymakers in the field of chemicals management, toy or product safety, and/or the toy value chain.

The toolkit aims to help stakeholders track and manage chemicals in toys, fulfil chemicals-related legal obligations, and ultimately protecting children from CoC in toys. With a focus on raising awareness on occurrences and risks related to CoC in toy materials at the early stages of the value chain, the toolkit: informs users on how to employ substitute and alternatives; presents guidance on how to convey information to consumers; and provides information, tips, and guiding questions for stakeholders interested in going further than regulatory compliance.

Figure 1: Steps for establishing and improving chemicals management in toy production

Source: SAICM

Based on the steps described in Figure 1 above, the toolkit’s sections (see Figure 2 below) elaborate on the steps:

• Compile background information, including on the challenges of CoC in toys, plastics and the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), and information on the risks and effects of CoC in the toys supply chain;
• Compile information on legislation and identify regulatory requirements for chemicals in toy products, depending on where the toy is placed on the market;
• Establish good, clear, and efficient communication with suppliers, for example, to get information on chemicals or to discuss potential quality problems with them;
• Build or review an inventory of chemicals in raw materials and in products, explain why such a chemical inventory should be used, and make the best use of it;
• Take action, including using guidance and tools for replacing a CoC with alternative chemicals, another technology, or a different material; and
• Inform customers by providing guidance on how to communicate on chemicals-related issues with downstream supply chains and end-use consumers.

Figure 2: Toolkit sections

Source: SAICM

As mentioned above, when children are young, they mouth toys, teethers, and pacifiers, all of which contain different chemical additives such as plasticizers, flame retardants, and antimicrobials that help optimize specific properties. However, many of these additives migrate from products into saliva since they are not covalently bound to the polymer chains. While assessing exposure pathways in children is crucial, pathways such as mouthing are often poorly quantified or neglected. In light of this, a study on Estimating mouthing exposure to chemicals in children’s products, supported by the SAICM/GEF project, developed a model to predict migration into saliva, mouthing exposure, and related health risks of different chemical-material combinations in children’s products. The study adapted an earlier migration model for chemicals in food packaging materials, as well as a regression model based on identified chemical and material properties. The model represents a green and sustainable chemistry tool that industries can apply to assess whether the chemicals in their products could pose a risk to children, as well as to evaluate safer alternatives during the design process.

In June 2023, SAICM convened a multi-stakeholder virtual Workshop on Tools and Guidance to Manage Chemicals in Toys to present the tools and guidance developed throughout the SAICM/GEF project’s duration, share key lessons from the project, and facilitate the exchange of knowledge and best practices among stakeholders. It was targeted at stakeholders working to enhance toy safety, including: industries in the toy value chain, such as raw material suppliers and manufacturers; retailers; regulators and government representatives; international standardization organizations; and civil society representatives.

Continuing to reduce CoC in toys going forward

According to the UNEP-commissioned DTU report, international standards are a key entry point for countries establishing chemical-related toy safety policies. To ensure success, standards and trade policies must be ambitious and flexible. They must facilitate the establishment of stricter safety requirements. Compliance and enforcement are also key to protecting children from chemicals-related risks in toys. Toy manufacturers must understand the regulatory requirements of the markets they are selling to. In addition, countries manufacturing or importing toys should establish enforcement mechanisms to ensure compliance with local regulatory requirements. However, small and medium-sized companies or companies not integrated into highly controlled supply chains of original equipment manufacturers or large retailers will face challenges that must be overcome.

It is also important to enhance collaboration among stakeholders in the toy value chain and improve synergies among regulatory requirements, industry capacity for compliance, transparency along the supply chain, and coordinated enforcement.

For example, in the EU, consumers have the right to know about the inclusion of harmful chemicals in products sold in Europe and the right to ask for information about them. Consumers can contact producers directly or do so through platforms like the Scan4Chem app if they suspect a product may contain chemicals above a certain limit that could be harmful to health and the environment. Substances of very high concern (SVHCs) are included in the EU’s REACH Candidate List of SVHCs. By law, suppliers must provide this information, free of charge, within 45 days from the date of request. The right to know applies to toys, as well as textiles, furniture, shoes, sports equipment, toys, and electronic equipment.

Other recommendations from the DTU report policymakers and other stakeholders could take onboard include the following:

• Countries should align policies targeting circularity and CoC, for example banning the use of recycled plastics in the manufacturing of toys or strictly controlling the source. Children’s toys made from recycled plastic contain toxic flame-retardant chemicals OctaBDE, DecaBDE, and HBCD. High concentrations of the toxic chemicals have been found in, for example, the Rubik’s cube toy, with 90% of examined cubes containing OctaBDE and/or DecaBDE. Toxic chemicals end up in toys when electronic equipment casings are used in recycling processes. Although the use of toxic flame retardants is prohibited in the EU, plastic recycling often happens in African or Asian countries where regulations are less strict, with chemicals ending up back in the supply chain. Thus, products made from recycled plastic should not be allowed to contain high concentrations of flame retardants, electronics casings should be removed before recycling, and stronger international limits on hazardous chemicals are needed.

• When adopting regulatory action, policymakers must ensure coherency across different regulatory domains, for example on products, chemicals, and waste, as well as across countries and regions, given the global flows of materials, products, and waste. Regulations and policies should be ambitious, as well as flexible enough to facilitate, rather than hamper, the establishment of stricter safety requirements where needed.

• Policymakers could establish platforms for training, dissemination, and information exchange related to CoC and for raising awareness about the risks from CoC for all stakeholders. Upstream small and medium-sized enterprises (SMEs) and e-commerce could benefit from training on relevant regulations, laboratory testing, and customs rules, while policymakers would benefit from the dissemination of good practice policies.

The new Global Framework on Chemicals presents further opportunities to address CoC in toys. For example, participating governments have pledged to create a regulatory environment to reduce chemical pollution and promote safer alternatives by 2030, while industry has committed to responsible chemical management to reduce pollution and its adverse effects by 2030.

* * *

This document has been developed within the framework of the Global Environment Facility (GEF) project ID: 9771 on Global Best Practices on Emerging Chemical Policy Issues of Concern under the Strategic Approach to International Chemicals Management (SAICM). This project is funded by the GEF, implemented by UNEP, and executed by the SAICM Secretariat. The International Institute for Sustainable Development (IISD) acknowledges the financial contribution of the GEF to the development of this policy brief.

This Policy Brief is the ninth in a series featuring cross-cutting topics relating to the sound management of chemicals and waste. It was written by Leila Mead, Earth Negotiations Bulletin (ENB) team leader, editor, and writer. The series editor is Elena Kosolapova, Senior Policy Advisor, Tracking Progress Program, IISD.

When negotiators convene at the fifth International Conference on Chemicals Management (ICCM5) in Bonn, Germany, in September 2023 to decide on a new global framework for the sustainable management of chemicals and waste, they will consider draft targets, and one of the proposals for implementation of the new framework seeks to encourage select “chemical intensive economic sectors and value chains” to scale-up global action that produces concrete results. One specific draft target calls for the development of sustainable chemical and waste management strategies in chemical intensive sectors and industries across value chains. The negotiations seek to develop a new global framework to replace the Strategic Approach to International Chemicals Management (SAICM) created by ICCM1 in 2006.

At a January 2023 workshop convened in Paris, France, by the proponent of the implementation proposal, the Inter-Organization Programme for the Sound Management of Chemicals (IOMC), textiles was discussed as a candidate sector for implementation. The IOMC plans a further stakeholder consultation from 20-21 June 2023 to flesh out ideas for guidance to support strategies and a possible global programme on advancing chemicals and waste management in economic industry sectors and their value chains.

At a negotiating session held in Bucharest, Romania, in August 2022, the textiles sector was an active participant in the talks: the Zero Discharge of Hazardous Chemicals (ZDHC) – a multi-stakeholder organization comprising over 150 contributors, including leading brands such as Adidas, Nike, and Levi Straus – made statements about the sector’s desire to actively engage in the future framework, and offered proposals for framework elements such as sectoral targets and indicators.

The UN Environment Programme (UNEP) has identified textiles – which encompasses not only apparel and footwear, but also some home furnishings (e.g., carpets, curtains, and upholstery) and “technical textiles” (e.g., medical textiles, geotextiles, seat covers, and protective clothing) – as a high-priority industry sector in shifting to a circular economy. Its importance to economies, natural resource management, gender equality, and sustainable development has been reflected in UNEP’s Medium-Term Strategy, resulting in the development of UNEP’s Textile Flagship Initiative. The Initiative aims to align UNEP’s work across three priorities needed to deliver system change towards sustainability and circularity – shifting consumption patterns, improving practices, and investing in infrastructure. These priorities are reflected in UNEP’s forthcoming report titled, ‘Sustainability and Circularity in the Textile Value Chain: A Global Roadmap.’ One of the impact areas of the project aims to reduce pollution in the environment and its impacts on human health by managing chemicals of concern across the textiles value chain.

This Policy Brief discusses SAICM’s longstanding interest in the textiles sector, the IOMC’s proposal, and how an implementation programme under the successor framework might engage with the industry.

SAICM and its interest in the textiles sector

SAICM grew out of a goal endorsed by the 2002 World Summit on Sustainable Development (WSSD) for the world to use and produce chemicals by 2020 in ways that minimize significant adverse effects on human health and the environment. The WSSD also called for developing “a strategic approach to international chemicals management” by 2005. This led to SAICM’s launch at ICCM1 in 2006 as a flexible, voluntary, non-binding, multi-stakeholder, and multi-sectoral initiative dedicated to promoting collaboration aimed at achieving the 2020 goal.

As originally conceived, SAICM was due to expire when ICCM5 convened in 2020. However, by the time ICCM4 convened in September 2015, it became clear that the 2020 goal would not be achieved in most countries. ICCM4 decided to launch an intersessional process aimed at designing a post-2020 framework or platform for the sound management of both chemicals and waste for consideration by ICCM5 in 2020. Due to delays in negotiations caused by the COVID-19 pandemic, ICCM5 was postponed until September 2023.

SAICM’s interest in the textiles sector as a significant user of chemicals came early, primarily through its Chemicals in Products (CiP) initiative. CiP was designated as an Emerging Policy Issue in 2009, and a CiP Programme was created by ICCM3 in 2012, led by UNEP, with a focus on four priority sectors, one of which was textiles. In the run up to ICCM3, UNEP produced a CiP case study on chemicals in textiles.

SAICM has also produced relevant knowledge products, such as the report and a policy brief on addressing per- and polyfluoroalkyl substances (PFAS) as a chemical class in the textile industry. The report and brief suggest how SAICM might advance the concept of approaching PFAS as a class of chemicals for control purposes, rather than chemical-by-chemical as the Stockholm Convention on Persistent Organic Pollutants (POPs) does, and phase out non-essential uses, the textile sector serving as a test case.

IOMC’s proposal for sectoral implementation programmes under a new global framework

The IOMC is an international coordinating group bringing together nine Participating Organizations to promote sound chemical management worldwide through coordination of policies and activities. Participating Organizations include UNEP, the Food and Agriculture Organization of the UN (FAO), the International Labour Organization (ILO), the UN Development Programme (UNDP), the UN Industrial Development Organization (UNIDO), the UN Institute for Training and Research (UNITAR), the World Health Organization (WHO), the World Bank, and the Organisation for Economic Co-operation and Development (OECD).

In a discussion paper presenting its proposals for an implementation programme under the new global framework, the IOMC suggests encouraging further action “based on industry initiatives that have been initiated voluntarily, resulted from regulatory requirements, or responded to pressure from public interest groups.” It also suggests choosing industry sectors and product value chains whose retailers have already undertaken “frontrunner” initiatives demonstrating commitment and willingness to engage, with a view to strengthening, linking, and expanding such initiatives.

The textiles industry qualifies on all counts. Major brands and retailers form the backbone of ZDHC. They have already developed several chemical restriction lists, management guidance, and standards, and backed certification and labeling schemes. Major brands, retailers, trade associations, and others in the sector have also engaged in the Ellen MacArthur Foundation’s Make Textiles Circular initiative, the Fashion Pact, the Policy Hub, and the Fashion Industry Charter for Climate Action.

In addition, the Global Environment Facility (GEF) can be recruited for realizing this implementation programme, as it is already committed to such work under GEF-8 programming directions. The GEF’s new Elimination of Hazardous Chemicals from Supply Chains Integrated Program commits the Facility to work on the textiles supply chain. A recently launched UNEP-implemented GEF project will work with four Asian nations – Bangladesh, Indonesia, Pakistan, and Viet Nam – representing 15% of global clothing exports to address chemicals of concern in their textiles industries.

The IOMC paper suggests engaging a candidate economic industry to develop, through dialogue, a sector vision and roadmap concerning important sustainability parameters, such as minimizing the use of hazardous substances, or advancing circularity objectives, which cover at least four areas:

• advancing the science on chemicals of concern;
• advancing green and sustainable chemistry technology innovation;
• strengthening regulations and policies; and
• mobilizing finance.

The textile sector already has a head start on this front, since it has been engaged with UNEP in dialogue to develop the aforementioned global roadmap for sustainability and circularity for the sector.

The paper further suggests that each sector and industry initiative outline specific measures or steps to take, such as:

• developing a list of hazardous substances causing concern in raw materials and supplies and production processes, such as a manufacturing restricted substances list (MRSL);
• developing standards that specify acceptable levels of chemical residues in finished products, either through a restricted substances list (RSL) or maximum residue levels;
• developing and implementing risk reduction measures to minimize occupational and public exposure, as well as emissions to air, land, and water, when hazardous substances cannot be phased out;
• identifying and implementing sustainable practices and alternatives, including through green and sustainable chemistry innovation, such as changes in processes, recipes, or product design, based on robust criteria and guidance on what constitutes safer alternatives; and
• developing sector-specific indicators to measure progress.

Here, too, the textile sector has a head start on these tasks. Oeko-Tex, the American Apparel & Footwear Association (AAFA), Apparel & Footwear International RSL Management Working Group (AFIRM), and Bluesign have developed RSLs, and most major brands have developed their own RSLs aligned with one or several of these four. Oeko-Tex and ZDHC have developed MRSLs, and individual companies, if they have an MRSL, tend to align theirs with ZDHC’s. There are also several relevant certification and labeling schemes (see Figure 1), and textile-sector goals and targets have been developed to provide indicators for measuring progress (see Figure 2).

Figure 1: Relevant restricted lists, certification schemes and labels regarding chemicals in textiles

Figure 2: Existing goals/targets regarding chemicals/circularity in textiles

Focusing on chemicals of concern in textile production under a future framework implementation programme

The textile sector may have a head start, but much work on chemicals management in the sector remains that could be taken up by an implementation programme under the new global chemicals and waste framework.

For example, while ZDHC’s MRSL is well regarded, its adherents currently account for only a limited percentage of the industry and the list notably is not taken up by the many small and medium-sized enterprises (SMEs) that comprise much of the textile value chain.

As for RSLs, while many companies have adopted their own, these vary, as do the competing attempts at developing harmonized RSLs (Okeo-Tex, AFIRM, AAFA). Furthermore, existing RSLs tend to reflect only the chemical restrictions currently in place by major regulators – primarily the European Union (EU) – and the principal international convention restricting hazardous substances, the Stockholm Convention on POPs. In addition, these restrictions cover only dozens of the thousands of chemicals used in textile production, usually do not address all categories of concern (prioritizing carcinogens, mutagens, and teratogens, but not always toxins to aquatic life, endocrine disruptors, allergens, or irritants), and involve substances selected on a slow substance-by-substance basis that requires years to arrive at final regulatory decisions.

Figure 3: A timeline of existing initiatives on chemicals of concern in textiles

What would it take to address all potential chemicals of concern in the textile value chain?

Among the fibers used in textile production globally in 2021, cotton has the largest share among natural fibers (22% of all fibers), and polyester the largest among synthetic fibers (54% of all fibers). Other inputs include man-made cellulosic fibers, nylon, acrylic, leather, wool, polyurethane, bamboo, and silk.

In the case of natural fibers, chemical use starts during farming. Cotton is a significant consumer of chemical pesticides and fertilizers. In 2019, cotton accounted for 4.71%, by value, of all the chemical pesticides sold globally, and 10.24%, by value of all insecticides used in global crop protection. In 2018, cotton accounted for around 4% of global nitrogen and phosphorus fertilizer consumption. A push for greater global adherence to an organic cotton or organic textile standard, while recognizing the need for in-conversion/ transitional periods and support for farmers to move towards organic practices, could significantly cut consumption of chemicals at this stage in the value chain.

Whether made from natural or synthetic fibers or some combination thereof, all textiles undergo significant chemical treatment at many production and processing stages before their sale to the final consumer.

Figure 4: Types of Chemicals Used in the Textiles Industry Source: Adapted from NRDC, A Review of PAS as a Chemical Class in the Textile Sector (2021)

Currently, obtaining complete, accurate, and up-to-date information on the number, volumes, and identities of the chemicals used in textile production is difficult. Two oft-cited estimates are that over 8,000 chemicals are used in textile production and that for every one kilogram (kg) of cotton textiles made, 0.35-1.5 kg of chemicals are used. However, the origins of both estimates are hard to pin down. These figures are also from over ten years ago and may not reflect current market realities.

A comprehensive survey, inventory, or database of chemicals used in textile production would be difficult to complete due to the complexity and global nature of the textiles value chain, involving stages and actors across many countries and jurisdictions with varying ranges of capacity, regulation, industry standards, and diligence. Inter-party communication about, and tracking of, chemicals used among the points in the chain is often minimal. A concerted effort by IOMC Participating Organizations, governments, industry (including SMEs), and non-governmental organizations (NGOs) from across the globe under the umbrella of an implementation programme such as the one the IOMC proposes might be able to accomplish this task.

Without better accounting of the universe of chemicals used in textiles production, it is difficult to identify, triage, assess, and regulate chemicals of concern, deciding which need to be banned, which need to be subjected to occupational exposure and/or emission limits (wet processing of textiles, for example, is a major source of wastewater discharges), and the presence of which chemicals in textile products (and at what levels) should be mandatory to disclose to consumers. Some have already been identified (see Figure 4), but the current extent of their use worldwide remains unclear – another data gap an implementation programme might address.

Figure 5: Some Chemicals of Concern Used in the Textiles Industry Source: Compiled by the author from various sources

The stakeholder consultation process involved in an implementation programme could address how to prioritize and allocate reviews of possible chemicals of concern, possibly through the chemical class or family approach instead of substance-by-substance, such as the Natural Resources Defense Council (NRDC) has suggested for PFAS. Identified chemicals of concern could be added to a globally harmonized MRSL. The value chain could then use the MRSL to prioritize chemicals for restrictions or phaseout and for targeting for substitution without waiting for regulatory agencies to act. A commonly agreed certification and/or labeling scheme could identify which brands and products align with the harmonized MRSL. In those cases where emissions or occupational exposure are involved, maximum permissible levels could be identified in accordance with best practice and shared as guidance across the value chain, as ZDHC is seeking to do with its wastewater guidelines.

Another chemicals in textiles issue an implementation programme might address is trade. Several recent studies have shown that even when a jurisdiction outlaws chemicals of concern in textiles, imported apparel found for retail sale in that jurisdiction still contains values violating the restrictions. The new programme can identify trade issues for follow-up in appropriate fora such as the World Trade Organization (WTO) and could also identify and/or provide support required to downstream chemical users, including SMEs.

A possible waste management component for a textiles sector implementation programme?

While SAICM has tended to focus more on chemicals management than waste issues, negotiators of the successor framework conceive of it addressing the latter as well. The IOMC’s proposal for an implementation programme reflects this expected broader mandate, although it elaborates on chemicals management but not on waste management.

The textiles sector is very wasteful and almost entirely linear, so there could be much to discuss under an implementation programme of the type conceived by the IOMC. While textile production volumes doubled from 2000-2015, the clothing utilization rate, that is the number of times a garment is worn before it ceases to be used, decreased by an average of 36%. Reportedly, more than half of “fast fashion” is disposed of within a year. Of the total fiber input used to produce clothing, 87% ends up being landfilled or incinerated – the equivalent of one garbage truck full of clothes disposed every second. Less than 1% of material used to produce clothing is recycled into new clothing, a recycling rate ranking below that of most single-use plastic packaging.

Figure 6: Global material flows for clothing in 2015

Source: Ellen MacArthur Foundation, A new textiles economy: Redesigning fashion’s future (2017)

Circularity goes well beyond waste management and recycling fibers. As outlined by UNEP (Figure 6), “reduce by design” aims to reduce the amount of material, particularly raw material, and hazardous chemicals consumed during production and during use, from the very beginning of product and service conceptualization. Production and consumption patterns as well as end-of-life processes of textile products are optimized via innovative product designs and business models, resulting in not only eliminated harmful impacts and waste but also improved social protections and business resilience. However, there is a need to reduce the harm of the linear textile system we have today, while preparing for the needs and wants of the circular textile system of tomorrow, and this includes better waste management.

Figure 7. A circular textile value chain

Source: UNEP, Sustainability and Circularity in the Textile Value Chain: Global Stocktaking (2021)

Strategies for a circular economy specific to the textiles value chain have been proposed by UNEP, the Ellen MacArthur Foundation, the EU, Germany, and the Netherlands. The UN Alliance for Sustainable Fashion has engaged the fashion industry in discussions on steps to create a circular economy in textiles, as has UNEP. The Global Fashion Agenda (GFA) has created a Global Circular Fashion Forum and worked with UNEP to identify and converge existing industry targets, including on smart material choices, resource stewardship (including a specific target on chemicals of concern management/phaseout), and circular systems. The GEF has already approved two projects on circular economy and textiles covering four African countries, one implemented by UNEP, the other by UNIDO.

Figure 8: A Timeline of select initiatives regarding a circular economy in textiles

Hence, the building blocks are there to work with in any waste management component of the proposed implementation programme and also look at circularity more widely (with a focus on chemicals), but a rationale for the value added that the SAICM successor can bring needs to be elaborated and the issues for the waste component to focus on remain to be fleshed out.

The new global chemicals and waste framework might contribute to the existing work on circularity in the textiles sector by:

• linking together the disparate country- and regional-focused initiatives, and giving them true global scope, while elevating the challenges and support required into strategic high-level discussions;
• broadening the circular textiles discussions to involve interested IOMC Participating Organizations that are not part of the UN system, such as the OECD and the World Bank, and tabling the central role of chemicals management for circularity in the discussions;
• engaging the GEF in helping to develop the initiative, since IOMC Participating Organizations UNEP, UNIDO, UNDP, and the World Bank are GEF Implementing Agencies, and GEF-8 envisions work in this vein;
• broadening the circular textiles discussions to include more parts of the textiles value chain than just apparel; and
• broadening the discussions beyond the limited group of major brands and retailers already involved in existing circular textile initiatives, particularly by engaging the many SMEs in the chain.

The Road to Bonn: Paving the way for textiles to take the spotlight in implementation of the new chemicals and waste framework

The IOMC plans a stakeholder consultation from 20-21 June 2023 to further flesh out ideas for a possible global programme on advancing chemicals and waste management in economic sectors and value chains. The IOMC, working with Participating Organizations, the SAICM Secretariat, and perhaps engaging the GEF Secretariat as well, should use the stakeholder consultation as a springboard for active dialogue with stakeholders in the months leading up to ICCM5 in September on which chemical-intensive sectors to focus on. The textiles sector is a good candidate to become one of the first focus sectors. With a view to presenting a robust proposal for consideration at ICCM5 in Bonn, the dialogue should outline and flesh out what an implementation programme for the textiles sector might look like, which chemicals and waste management issues the implementation programme could provide value added on and should address, and possible objectives, targets, and indicators for the programme. The dialogue might also highlight global work undertaken in the textile industry which could be relevant for other chemical-intensive sectors facing challenges.

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This document has been developed within the framework of the Global Environment Facility (GEF) project ID: 9771 on Global Best Practices on Emerging Chemical Policy Issues of Concern under the Strategic Approach to International Chemicals Management (SAICM). This project is funded by the GEF, implemented by UNEP, and executed by the SAICM Secretariat. The International Institute for Sustainable Development acknowledges the financial contribution of the GEF to the development of this policy brief.

 This Policy Brief is the sixth in a series featuring cross-cutting topics relating to the sound management of chemicals and waste. It was written by Keith Ripley, Earth Negotiations Bulletin (ENB) team leader and writer. The series editor is Elena Kosolapova, Senior Policy Advisor, Tracking Progress Program, IISD.

RELATED EVENTS

• Fifth Meeting of the International Conference on Chemicals Management (ICCM5)

This study, commissioned by DG Environment for the European Commission and produced by Wood and Ramboll.  The objective was to assess the use of PFASs and fluorine-free alternatives in textiles, upholstry, carpets, leather and apparel, including specific focus on volumes of use, technical function, and emissions.

Non-fluorine alternatives considered were hydrocarbons, silicones, dendrimers, polyurethane, nanomaterials, and alternative technologies.  The study makes recommendations for policy, including a REACH restriction on the placing on the market and use of these products that contain any PFAS, and a listing under the Stockholm Convention.  It is also recommended in the report that a restriction could be combined with voluntary industry measures and provisions in public procurement to encourage substitution of PFAS before mandatory legislation is introduced.

In this report, we present a list of Chemicals of Concern (CoCs) in plastic toys, with supporting information on the applied selection criteria. To identify the CoCs, we started from a literature review of available plastic toys compositions studies, and obtained the chemical mass fraction in plastic toy as well as the chemical functions. The chemical emissions from the plastic toys and subsequent human exposures were then estimated using a series of models and the coupled nearfield and far-field exposure assessment framework. Finally, the human exposure doses were compared to toxicity measures such as the reference dose (RfD), or median effective dose (ED50) for cancer effects, to evaluate the health risks on children. Chemical-material combinations that have a hazard quotient (HQ) > 10, a margin of exposure (MoE) < 100, or a lifetime cancer risk > 10-6 were included in the list of CoCs. In total, 35 (less than 10%) of all chemical-material combinations studied were identified as CoCs. The results indicate that a relevant amount of chemicals used in plastic toys may pose a non-negligible health risk to children, calling for more refined investigations and more human- and eco-friendly alternatives.

This document has been developed within the framework of the Global Environment Facility (GEF) project ID: 9771 on Global Best Practices on Emerging Chemical Policy Issues of Concern under the Strategic Approach to International Chemicals Management (SAICM). This project is funded by the GEF, implemented by UNEP and executed by the SAICM Secretariat.