Strengthened chemical restrictions and updated PFAS requirements
ZDHC MRSL V4.0 strengthens science-based chemical restrictions, improves implementation guidance across the value chain and introduces a clearer framework for managing intentional PFAS use and unintentional contamination.
[Amsterdam, 29 October 2026] – The ZDHC Foundation today launched Version 4.0 of its ZDHC Manufacturing Restricted Substances List (ZDHC MRSL). This update reflects the latest scientific developments and evolving industry needs.
The ZDHC Manufacturing Restricted Substances List provides a harmonised, science-based framework for restricting hazardous substances in chemical formulations used during manufacturing. Unlike traditional Restricted Substances Lists, which focus on finished products, the ZDHC MRSL addresses chemicals at their source, helping to prevent hazardous substances from entering production processes in the first place.
The update was developed through ZDHC’s established MRSL governance process and independently assessed by the ZDHC MRSL Council, drawing on scientific, regulatory and industry evidence as well as stakeholder review.
The updates in ZDHC MRSL V4.0 build on the ongoing review process led by the ZDHC MRSL Council, an independent group of technical experts representing diverse segments of the textile, apparel, leather and footwear industries, alongside other relevant stakeholders.
The Council uses an objective, science-based approach to assess proposed substances and recommend their inclusion in the ZDHC MRSL or MRSL Candidate List. For Version 4.0, this assessment took into account developments in relevant regulatory lists, including Persistent Organic Pollutants (POPs) and Substances of Very High Concern (SVHC), as well as inputs from the ZDHC Chemical Watchlist.
The proposed updates also underwent a stakeholder review to gather broader industry feedback. All substances in ZDHC MRSL V4.0 are relevant to the covered industries, with identified hazards including toxicity to aquatic life, endocrine disruption, and carcinogenicity. This approach ensures that the updated restrictions reflect evolving scientific knowledge, regulatory developments and industry-specific chemical risks.
“With version 4.0, we have added some significant harmful chemicals and, against a backdrop of increasing legislative complexity, we have improved the clarity of the listings to keep its practical application at the forefront. Our goal is to help the industry make better-informed chemical choices and drive meaningful progress towards safer manufacturing.”
Phil Patterson, ZDHC MRSL Council Chair
Version 4.0 introduces 16 new substances not previously covered under ZDHC MRSL V3.1, reflecting evolving industry standards and regulatory requirements. These include bisphenols, formaldehyde, polychlorinated biphenyls (PCBs), and certain UV absorbers, addressing chemical risks such as endocrine disruption, carcinogenicity, and aquatic toxicity.
The update also strengthens existing restrictions by lowering limits for substances including alkylphenol ethoxylates (APEOs), chlorinated paraffins and certain organic solvents.
Three additional substances have been added to the ZDHC MRSL Candidate List for continued monitoring, while two substances have been moved to the Archive List. Titanium dioxide has been removed from the ZDHC MRSL following changes to its regulatory classification.
Alongside these changes, V4.0 updates chemical restrictions, formulation limits, analytical methods and material-specific guidance covering textiles, leather, rubber, foams and adhesives.
It also provides tailored information for suppliers, chemical formulators and testing organisations, outlining considerations and responsibilities for specific substances. Together, these updates strengthen the ZDHC MRSL’s systematic approach to identifying hazardous substances, supporting the transition to safer alternatives and maintaining transparency as scientific knowledge and industry practices evolve.
ZDHC MRSL V4.0 sets defined limits for unintentional contamination by per- and polyfluoroalkyl substances (PFAS), including 25 µg/kg for individual PFAS, 250 µg/kg for the sum of PFAS, and 50 mg/kg for total fluorine content.
It also confirms that intentionally added PFAS are not permitted in MRSL-conformant chemical formulations.
Alongside the MRSL update, ZDHC is publishing its PFAS position paper and practical interpretations. Using the OECD’s 2021 definition, the paper reinforces ZDHC’s position against the intentional use of PFAS across the textile, apparel, leather and footwear supply chain.
It provides practical guidance on assessing ZDHC MRSL conformance, distinguishing intentional use from unintentional contamination and addressing the limitations of current analytical testing methods.
The approach is designed to build, wherever technically appropriate, on existing industry practices, recognised certification schemes and available analytical evidence rather than create unnecessary duplication. This supports more harmonised implementation across the value chain while maintaining the assurance level needed for credible MRSL conformance.
ZDHC MRSL V4.0 provides clearer guidance for brands, suppliers, chemical formulators, certifiers, and testing organisations on how to apply the updated requirements.
Where credible evidence already exists through recognised industry systems, the intention is to make appropriate use of that evidence rather than create parallel requirements.
ZDHC will continue to work with Chemical Formulators, suppliers, testing organisations and certification bodies to support consistent implementation as science, regulation and analytical capabilities evolve.
A defined implementation and transition approach will help stakeholders adapt formulations, testing, certification, and Gateway processes to the updated requirements.
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