AFIRM Restricted Substances List
What is the AFIRM RSL?
The AFIRM RSL is a voluntary Restricted Substances List for finished products. It is published by the Apparel and Footwear International RSL Management (AFIRM) Group, an industry working group set up in 2004, and it sets limits on harmful substances in apparel and footwear [1]. It is an industry tool, not a law. The current edition is 2026.
Who issues it and why
- AFIRM says its mission is "to reduce the use and impact of harmful substances in the apparel and footwear supply chains." It also wants to share chemicals-management information along the supply chain [1].
- The list is meant to help suppliers improve product quality and safety, or cut environmental impact, by limiting certain substances [1].
Legal status
- The RSL is information from AFIRM only. It does not represent any individual member, and brands' own RSLs "may differ in specific parameters" [1].
- It "is not intended to and does not establish any industry standard of care" and is not legal advice. Where a brand has implementation guidelines, suppliers "must follow those guidelines where required" [1].
- Anyone may reuse or adapt it, with or without crediting AFIRM [2].
Scope
- The main focus is apparel and footwear. It "may also be applied to" accessories, jewelry, sporting goods equipment, wearables (only the skin-contact components) and home textiles. Its Table 1 gives examples such as shirts, boots, handbags, helmets, smart watches and bed linens [3].
- Some products have their own regulatory requirements that the RSL does not cover, so suppliers must meet those separately [4]:
- toys
- sunglasses and children's jewelry
- personal protective equipment (for example Regulation (EU) 2016/425)
- food-contact materials
- electrical and electronic components that don't touch the skin (for example RoHS and the EU Batteries Regulation)
- It also covers recycled materials, which can bring back older "legacy" chemicals. AFIRM prefers to eliminate these where possible; where that can't be done, suppliers should consult their brand customers [4].
What the 2026 document contains [2]
- Definitions: ages, "child care article", limit, component, reporting limits, sample and composite sample, and material types.
- A change log and a testing matrix.
- The restricted-substances table itself.
- Appendices on:
- South Korea KC Mark soluble heavy metal requirements
- PFAS
- agricultural pesticides and herbicides
- volatile organic compounds
How it is used
- AFIRM lists these uses [5]:
- giving vendors a tool to build chemical-management knowledge and processes
- building full or base compliance with member brands' restrictions
- providing a common testing base that several brands may accept
- Each member brand decides its own testing requirements and which test reports it accepts [5].
Related AFIRM tools [5]
- A Packaging RSL, a Chemistry Toolkit, PFAS Phaseout Guidance, Chemical Information Sheets and Sampling Guidance.
- The RSL cross-refers to the ZDHC Manufacturing Restricted Substances List (MRSL). The MRSL is a separate list covering chemicals used intentionally in manufacturing facilities; the AFIRM RSL covers the finished product.
Approach: I read the English 2026 edition of the AFIRM RSL as published at afirm-group.com/AFIRM_RSL_EN.
How is it different from an MRSL?
The difference is what each list tests and at what point in the supply chain. The AFIRM RSL limits substances in the materials of the finished product [6]. An MRSL, such as the one from the ZDHC Foundation, lists chemicals restricted from intentional use in manufacturing facilities. Its limits apply to the chemical formulations that factories use, not to the finished garment or shoe [7].
| AFIRM RSL (product list) | ZDHC MRSL (manufacturing list) | |
|---|---|---|
| What it covers | Component materials in the finished product. The table columns are "Limits: Component Materials in Finished Product" plus reporting limits [6] | Chemicals "restricted from intentional use" in textile, leather and footwear manufacturing [7] |
| What is tested | Product samples, with methods for each material (textiles, leather, polymers, down) [6] | Chemical formulations, with a "formulation limit" for each substrate (Textile, Leather, Polymers) [8] |
| Typical instruction | Meet a numeric limit in the product and report results above the reporting limit [6] | "No intentional use" [9] |
| Structure | A restricted-substances table plus appendices (PFAS, pesticides, VOCs, KC Mark heavy metals) | A main restricted list (Chapter 1) and a Candidate List of substances still being evaluated (Chapter 2) [10] |
The same substance on both lists: alkylphenol ethoxylates (APEOs)
- AFIRM RSL: in the finished product, total alkylphenols plus APEOs is limited to 100 ppm, and total alkylphenols to 10 ppm. The RSL also says APEOs and formulations containing them "are prohibited from use throughout supply chain and manufacturing processes." It admits that trace residues above 100 ppm may still occur while the supply chain phases them out [6].
- ZDHC MRSL: nonylphenol ethoxylates (NPEO) and octylphenol ethoxylates (OPEO) carry a formulation limit of "Sum = 250 mg/kg" for textile, leather and polymers, with the guidance "No intentional use" [7][11].
The two numbers measure different things, one in a chemical formulation and one in a finished material, so they can't be compared directly.
Formaldehyde shows the two lists at different stages
- AFIRM RSL: formaldehyde is restricted in products because "legislation in major markets around the world restricts the presence of formaldehyde in finished products." AFIRM's information sheet tells buyers to require materials with no intentionally added formaldehyde in some processes (heat transfer, prints, adhesives, finishing agents) [12].
- ZDHC MRSL: formaldehyde is only on the Candidate List. ZDHC says that in version 4 "it is intended to introduce a maximum allowable limit of 250 mg/kg formaldehyde for the majority of formulations." It plans a 1000 mg/kg limit for state-of-the-art uses such as non-iron finishes and resin tanning agents [13].
The two lists overlap and are meant to be used together
- The AFIRM RSL sometimes gives process instructions too. For example, its Appendix D VOCs "should not be used in textile auxiliary chemical preparations" or for facility or spot cleaning [14].
- AFIRM lists the ZDHC MRSL (mrsl.roadmaptozero.com) among the references suppliers should visit regularly [5].
- In practice, the MRSL controls what goes into the factory, and the RSL checks what ends up in the product.
- Neither list is law. Both are voluntary industry tools, and brands set their own testing and acceptance requirements [5].
Approach: I compared the English 2026 edition of the AFIRM RSL with the ZDHC MRSL entries for the same substances. The AFIRM RSL only points to the MRSL and does not define the term itself, so the MRSL side is described from the ZDHC MRSL entries.