AFIRM RSL explained for apparel and footwear supplier testing
The AFIRM RSL sets component limits for restricted substances in apparel and footwear. It is an industry list, not a law or every buyer's pass.
The AFIRM RSL is the Apparel and Footwear International RSL Management Group's Restricted Substances List for components in finished apparel and footwear. Its 2026 edition, Version 11, provides substance limits, test methods, reporting limits and a material-based testing matrix. Download the official AFIRM RSL.
RSL means "restricted substances list." AFIRM provides a common testing reference, but it isn't a law or universal certification. Your customer's requirements and applicable legislation still apply. A passing report does not guarantee acceptance by every brand. AFIRM explains these limits in its introduction and guidance on use.
What the AFIRM RSL covers
Apparel and footwear are its main focus. AFIRM says the list can also apply to accessories, jewelry, sporting equipment, wearables and home textiles. For wearables, its scope concerns external skin-contact components, not all electronics. Product-specific requirements outside the list remain applicable, including those for toys, food-contact materials, PPE, and electrical or electronic components. See AFIRM's scope guidance.
Read restrictions at component level. The limit applies to a component material in the finished product, not an average across the whole garment. AFIRM defines a component as a uniformly composed material, or an inseparable combination as the RSL defines it. Don't dilute a component's test result by calculating it against the weight of the complete product. See the definitions and restriction table headers.
AFIRM's matrix says recycled materials may need extra Level 1 testing, subject to the brand's requirements. Recycled content does not remove the check for restricted substances, including legacy chemicals. Read the matrix footnotes.
How to plan AFIRM RSL testing
Confirm the edition and buyer requirements
Start with the official AFIRM download page and the customer's specification. Record the edition on the file you download, plus the buyer instructions your plan uses. AFIRM says it updates the RSL annually by February 1. That is the update policy, not the publication day of Version 11.
Before ordering tests, ask the customer whether it requires extra substances, stricter limits or a specific sampling plan. AFIRM's FAQ says some brands specify sample numbers while others leave that choice to suppliers. Brand-specific requirements can prevent report acceptance even where AFIRM limits are met. Check AFIRM's supplier FAQ.
Map components to the testing matrix
List the product's component materials, then match them to the matrix. Also identify the intended sales markets so applicable legal requirements remain part of the assessment. The AFIRM testing matrix uses these categories:
| Matrix entry | Meaning | Testing implication |
|---|---|---|
| 1 / red | Higher risk | Testing required |
| 2 / orange | Lower risk | Testing recommended, and the brand may require it |
| Blank | Lowest risk | The substance is not anticipated in that material |
Level 1 is the matrix's minimum testing to satisfy AFIRM member requirements. But individual brand testing programs supersede it unless the brand says otherwise. Read the footnotes before you set the test scope. And a blank cell is not an exemption from customer or legal obligations. See AFIRM's matrix instructions.
Use the relevant substance rows and matrix guidance to select tests for each material. Where your material is absent, consult the testing laboratory. AFIRM also explains how to interpret "All Materials".
Agree methods and sampling before testing
Check the specified method for each substance and material, including sample preparation. Agree on the sampling plan and reporting requirements with the laboratory and customer before you send samples. AFIRM's methods are material-dependent, so a substance name alone does not define the full test. Use the method columns in the official list.
Discuss composite samples explicitly. They combine two or more samples and have correspondingly higher quantification and reporting limits. Do not assume compositing suits every test or buyer requirement. See AFIRM's composite-sample definition.
Read concentrations, not just pass or fail
The restriction limit and reporting limit answer different questions. The restriction limit sets the permitted concentration for the component. Above the reporting limit, the laboratory should report a detected substance, even below the restriction limit. It is not a second failure threshold. AFIRM defines both terms.
For example, the row for acetophenone, 2-phenyl-2-propanol and related substances sets a 50 ppm restriction limit and a 25 ppm reporting limit. A reportable detection therefore does not automatically mean failure against that row's restriction limit. Read the reported concentration alongside both columns, then check any customer-specific requirement. See AFIRM's acetophenone entry.
Finished-product testing may still be needed after materials pass. Manufacturing and later treatments can introduce restricted substances. Ask the buyer what finished-product evidence it requires rather than treating a material report as final approval. AFIRM addresses this in its FAQ.
AFIRM RSL, AAFA RSL and ZDHC MRSL
Suppliers use the AFIRM RSL to plan component tests: substance limits, material-specific methods and a testing matrix. Brands can still impose a tighter list.
The AAFA restricted substance list compiles regulatory restrictions and bans on finished home textiles, apparel and footwear worldwide. AAFA identifies its 2026 edition as RSL 26. Use is voluntary and informational, not legal advice, and it is not a US law.
ZDHC's Manufacturing Restricted Substances List restricts intentional use of harmful substances in fashion, leather and footwear manufacturing. Meeting that input rule does not prove a finished component passes AFIRM RSL testing. Treat the manufacturing control and the finished-product list as separate checks.
Keep testing decisions traceable
Keep reports linked to the tested components, RSL edition and buyer specification. As a practical precaution, reconsider testing after material, supplier, chemistry or process changes. Don't assume an earlier report covers a changed product.
RegAffairs AI answers what the AFIRM RSL is and how it differs from an MRSL, with citations to the source documents.